| Comment Number: | 536798-00020 |
| Received: | 9/10/2008 3:41:03 PM |
| Organization: | Smokefree Pennsylvania |
| Commenter: | Bill Godshall |
| State: | PA |
| Agency: | Federal Trade Commission |
| Rule: | Proposal to Rescind FTC Approval of the Current Cigarette Test Method |
| No Attachments |
Comments:
Smokefree Pennsylvania strongly urges the Federal Trade Commission (FTC) to approve its proposal in July to rescind the FTC’s 1966 Guidance on Statements Concerning Tar and Nicotine Yields. The FTC method for testing cigarette emission yields (aka the Cambridge Filter Method) is inaccurate and unreliable, as most smokers who switch to so-called low-tar, light or ultralight cigarettes simply change their smoke inhalation patterns in order to attain similar doses of nicotine, usually by inhaling the smoke longer and deeper, by inhaling more puffs or smoking more cigarettes, and/or by covering the vent holes near the cigarette filter. Furthermore, a recent study by leading international experts (1) concluded that NO cigarette emission testing regime (including the FTC method) accurately measures human exposure, and that none should be relied upon for establishing government regulatory standards. Unfortunately for tobacco consumers and public health, the FTC’s cigarette testing method, the FTC’s 1966 Guidance on Statements Concerning Tar and Nicotine Yields and the subsequent aggressive marketing by cigarette companies of so-called low-tar, light and ultralight cigarettes has created and perpetuated the myth/fraud believed by many (if not most) smokers that those types of cigarettes are less hazardous than other cigarettes. A 2000 survey (2) of 36,012 young adults entering the U.S. Air Force found that an overwhelming majority of smokers (77%), ex-smokers (72%) and never smokers (73%) inaccurately believed that switching to a low-tar/nicotine cigarette would reduce health risks of smoking. Meanwhile, 75% of respondents inaccurately believed that switching from cigarettes to a smokeless tobacco product would reduce health risks despite the fact that cigarette smoking poses at least ten times greater mortality risks than does using smokeless tobacco products. A more recent survey (3) of 411 college freshman found that 40% of respondents incorrectly perceived ultra-light cigarettes as less harmful than regular cigarettes, while 35% incorrectly perceived light cigarettes as less harmful than regular cigarettes. Meanwhile, 89% of respondents incorrectly perceived dip and chew to be as harmful as or more harmful than regular cigarettes. This massive public misinformation about the health risk of different cigarettes (along with the desire by most smokers to reduce their health risks) is why the market share of so-called low-tar, light and ultralight cigarettes has steadily increased during the past forty years, and why those types of cigarettes now account for a majority of cigarettes consumed in the United States. In sum, there is no such thing as a safer cigarette, and no government agency should encourage or allow the perpetration of this consumer myth/fraud. Noncombustible tobacco/nicotine products are the only less hazardous nicotine alternatives to cigarettes for addicted smokers. 1. Hammond D, Wiebel F, Kozlowski LT, et al, Revising the machine smoking regime for cigarette emissions: implications for tobacco control policy, Tobacco Control 2007;16:8-14. http://tobaccocontrol.bmj.com/cgi/content/abstract/16/1/8 2. Haddock CK, Lando H, Klesges RC, et al, Modified Tobacco Use and Lifestyle Change in Risk-Reducing Beliefs About Smoking, American Journal of Preventive Medicine, 2004 Vol. 27, No. 1, 35-41. 3. Smith SY, Curbow B, Stillman FA, Harm perception of nicotine products in college freshmen, Nicotine Tob Res. 2007 Sep; 9(9):977-82. http://www.informaworld.com/smpp/content~content=a781712955~db=all~tab=content~order=page William T. Godshall, MPH Executive Director Smokefree Pennsylvania 1926 Monongahela Avenue Pittsburgh, PA 15218