American Public Health Association
800 I Street, NW • Washington, DC 20001-3710
(202) 777-APHA • Fax: (202) 777-2534
comments@apha.org • http://www.apha.org

Opposition to Marketing of "Reduced Risk" Tobacco Products

June 2, 2003

Dear Representative

On June 3, 2003, the House Committee on Energy and Commerce and the Committee on Government Reform will hold hearings on so-called "reduced risk" tobacco products including smokeless (spit) tobacco. The Partners for Effective Tobacco Policy Coalition and others are writing to express our concerns about these products and the misleading marketing and health claims associated with them. We urge Congress to oppose current efforts by the tobacco companies to acquire governmental approval for its misleading claims.

In November of 2001, the National Cancer Institute (NCI) released a landmark study entitled Risks Associated with Smoking Cigarettes with Low Machine-Measured Yields of Tar and Nicotine that clearly demonstrated that light and low-tar cigarettes have not reduced smokers' health risks and have been deceptively marketed by the tobacco industry to discourage smokers from quitting. The NCI study concluded that smokers who use low-tar brands are exposed to the same amount of toxins as those who use full-flavor cigarettes in part because smokers use low-tar brands differently in order to obtain the same amount of nicotine. The NCI study also revealed that despite knowing that low-tar cigarettes delivered the same amount of tar to smokers, the cigarette companies marketed them as reduced risk, especially to smokers thinking of quitting.

Today, 30 years after the introduction of "light" and "low-tar" cigarettes, tobacco companies are keenly interested in expanding their marketing of a new set of products with claims of reduced risk. In the last couple of years the tobacco companies have introduced a number of so-called "reduced risk" products designed to encourage new tobacco users and discourage current smokers from quitting. Currently, Brown and Williamson is marketing Advance cigarettes with the slogan "All of the tasteā€¦ Less of the toxins" and Vector Tobacco has embarked on an extensive marketing campaign of Omni cigarettes with ads proclaiming "Reduced Carcinogens. Premium Taste." Philip Morris recently announced that it plans to launch a new "reduced risk" product next year.

The marketing of so-called "reduced-risk" products is not limited to cigarette manufacturers. United States Smokeless Tobacco Company has recently asked the FTC to approve a claim that its products are less harmful than cigarettes despite the fact that similar advertising by this company in the past has led to a large expansion of smokeless tobacco users, many of them young males, with no reduction in the use of cigarettes. The industry makes claims that these products will help smokers quit. However, there has been no independent scientific evidence to support or confirm any of these claims. The U.S. Surgeon General, the NCI and other scientific organizations have determined smokeless tobacco products sold in the United States increase the risk of serious disease, including oral cancer. Smokeless tobacco is simply not a safe alternative to smoking: users are up to 50 times more likely to get oral cancer than non-users and these cancers can form within five years of regular use. Moreover, although UST and other manufacturers claim otherwise, there is no evidence that smokeless tobacco products help smokers quit.

The lesson to be learned from the NCI report and an Institute of Medicine Report entitled Clearing the Smoke, Assessing the Science Base for Tobacco Harm Reduction is that in the absence of effective government regulation, harm reduction has been and will continue to be a fallacy. Without strong and meaningful Food and Drug Administration (FDA) regulation, tobacco product manufacturers do not have to pre-clear claims or scientifically substantiate them. They also do not have to disclose how they make their products, including what they add in during the manufacturing process. Moreover, they do not have to produce any evidence regarding human exposure or data that would justify claims that their products are less harmful because they reduce exposure to one or more toxic substances.

We are calling on the members of the Committee on Energy and Commerce and the Committee on Government Reform to protect the public from these inaccurate and misleading statements. Industry advertising that falsely states that tobacco products are less hazardous is not only misleading but also has a serious public health consequence as it leads smokers to believe that these "reduced-risk" products are a safe alternative to quitting. It also results in more children starting to use these products. In the absence of meaningful FDA authority over tobacco products, we urge you to publicly oppose the tobacco industry's claims that smokeless and low-yield products result in harm reduction to consumers.

We thank you for your attention to our concerns and stand ready to work with you on these critical public health issues.

Sincerely,

Action on Smoking and Health
American Academy of Family Physicians
American Academy of Nurse Practitioners
American Cancer Society
American College of Chest Physicians
American College of Preventive Medicine
American Heart Association
American Legacy Foundation
American Lung Association
American Medical Association
American Medical Women's Association
American Psychological Association
American Public Health Association
Association of Asian Pacific Community Health Organizations
Campaign for Tobacco-Free Kids
Center for Tobacco Cessation
Community Anti-Drug Coalitions of America/Drug-Free Kids Campaign
Hadassah, the Women's Zionist Organization of America
Interreligious Coalition on Smoking OR Health
Latino Council on Alcohol and Tobacco Prevention
Mautner Project
National Association of County and City Health Officials
National Association of Local Boards of Health
National Center for Policy Research (CPR) for Women & Families
National Women's Law Center
Oncology Nursing Society
Oral Health America
Partnership for Prevention
Society for Public Health Education