I sent the following to the CO Board of Health as testimony for today's hearing, and was told that it would be sent to all BOH members.
Colorado Board of Health Members:
According to extensive epidemiological research, cigarettes are 100 times more hazardous (i.e. morbidity/mortality risks) than smokeless
tobacco products marketed in the US and Sweden.
HRJ | Full text | Tobacco harm reduction: an alternative cessation strategy for inveterate smokers
BioMed Central | Full text | Systematic review of the relation between smokeless tobacco and cancer in Europe and North America
http://www.aaphp.org/Resources/Documents/20081026HarmReductionResolutionAsPassedl.pdf
American Association of Public Health Physicians - Tobacco Update
http://www.harmreductionjournal.com/content/pdf/1477-7517-8-19.pdf
http://download.thelancet.com/pdfs/journals/0140-6736/PIIS0140673607615190.pdf
Tobacco smoking, harm reduction, and nicotine product regulation : The Lancet
http://nzhta.chmeds.ac.nz/publications/smokeless_tobacco.pdf
The daily inhalation of
tobacco smoke causes more than 99% of
tobacco attributable mortality in the US
Annual Smoking-Attributable Mortality, Years of Potential Life Lost, and Productivity Losses --- United States, 1997--2001 and more than 99% of all tobacco attributable healthcare costs. Meanwhile, the evidence indicates that the use of smokefree tobacco/nicotine products causes less than than .1% of tobacco attribatable mortality and healthcare costs.
Smokers who switch to smokeless tobacco products reduce their health risks nearly as much as if they quit all tobacco/nicotine use. During the past several decades, several million cigarette smokers in the US have switched to smokeless tobacco products, and more than 25% of male smokers in Sweden quit smoking by switching to smokeless tobacco (see attached Ramstrom-Foulds article). More male smokers in Norway have quit smoking by switching to smokeless tobacco than have quit by using NRT smoking cessation products.
The use of snus for quitting smoking compared with medicinal products
Scientific research on one dissolvable tobacco product at
http://www.starscientific.com/404/stepanov tsna in.pdf
and
http://static.mgnetwork.com/rtd/pdfs/20090712_toba.pdf indicate that dissolvable tobacco products are virtually identical to dissolvable nicotine products like GlaxoSmithKline's Commit and Nicorette
Nicorette Lozenge - Nicotine Lozenge | To Help You Quit, which are also marketed with flavorings.
According to US survey data, smokeless tobacco is not a gateway to cigarette smoking, as far more smokers have switched to smokeless tobacco than vice versa.
Smokeless Tobacco Use, Initiation, and Relationship to Cigarette Smoking: 2002 to 2007
Evidence against a gateway from smokeless tobacco use to smoking
Last year, an article
Unintentional Child Poisonings Through Ingestion of Conventional and Novel Tobacco Products reported that calls to US Poison Control Centers in 2006-2008 included 10,573 calls for cigarettes, 1,768 calls for smokeless tobacco products, 167 calls for cigars, but no calls for dissolvable tobacco products. Unfortunately, the article's authors grossly misrepresented their own findings by alleging that many children are being poisoned by dissolvable tobacco products.
Tobacco
Another researcher
Tobacco Truth: Poisoning Public Health Issues who reviewed 2008 data provided by the American Association of Poison Control Centers
http://www.aapcc.org/dnn/Portals/0/2008annualreport.pdf reported that tobacco products accounted for less than 1% (i.e. 7,310) of the 684,572 reported exposures (to youth under six years), that smokeless tobacco products accounted for just .15% (i.e. 1,105) of reported tobacco exposures, and that there were 589 reported exposures to NRT drugs. While all accidental ingestions by children are of concern, it is critically important to note that cosmetics and personal care products, household cleaners, pesticides, plants, alcohol, solvents, chemicals, paint, paint strippers, adhesives and glues all accounted for more accidental ingestions by children than tobacco products, and that there is no evidence that accidental ingestions of tobacco by children have actually caused injuries or harm.
Dissolvable tobacco products are marketed to adult tobacco consumers (primarily cigarette smokers), not to children. Federal and state laws already prohibit tobacco sales to minors, and the 1998 Master Settlement Agreement between state AGs and tobacco companies explicity bans target marketing of tobacco products to youth.
If anyone who has alleged that dissolvable tobacco products (or any other tobacco products) are marketed to youth actually had any evidence indicating that dissolvable tobacco products are marketed to youth, they should/would have notified the US FDA, the Colorado Dept of Public Health and/or the Colorado Attorney General for law enforcment and/or prosecution of offenders. Unless and until allegations (that dissolvable tobacco products are marketed to youth) have been reported to federal and/or state officials for prosecution, all such allegations should be considered as unsubstantiated.
After campaigning since 1990 to sharply reduce tobacco marketing to youth, and after extensively evaluating the marketing of dissolvable and other new smokefree tobacco products during the past decade, I can only conclude that allegations accusing tobacco companies of marketing these products to minors are ALL false.
Organizations that have accused dissolvable tobacco product makers of marketing to youth (e.g. CTFK, ACS, AHA, ALA, AAP) unsuccessfully petitioned the FDA to ban the sale of dissolvable tobacco products in 2002, and all of those organizations have adopted abstinence-only policies that oppose adult smokers reducing their health risks (by switching to far less hazardous smokefree alternatives). Ironically and hypocritically, none of those who advocate banning dissolvable tobacco products have yet to endorse banning far more hazardous cigarettes.
Cigarette smokers have a human right to be truthfully informed that smokeless tobacco products are far less hazardous alternatives to cigarettes, and public health officials have an ethical duty to provide truthful information about the comparable risks of different tobacco products.
If the CO Board of Health is truly interested in reducing tobacco attributable morbidity, mortality and healthcare costs, I encourage the Board to truthfully inform Colorado smokers that smokefree tobacco products (including dissolvables) are far less hazardous alternatives to cigarettes, and to encourage smokers to consider switching.
Since 1990, Smokefree Pennsylvania has advocated policies and laws to reduce indoor tobacco smoke pollution, increase cigarette taxes, reduce tobacco marketing to youth, preserve civil justice remedies for those injured by cigarettes, expand smoking cessation services, and inform smokers that smokefree tobacco/nicotine products are far less hazardous alternatives to cigarettes. In 2007, I encouraged Sen. Mike Enzi (R-WY) to offer the amendment to the Family Smoking Prevention and Tobacco Control Act that will require graphic warnings on all cigarette packs sold in the US next year.
In 2010, I filed an amicus brief with the DC Court of Appeals in support of federal Judge Leon's ruling at
https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2009cv0771-54 that redefined and reclassified all products containing nicotine (including dissolvable nicotine products) that are intended for human consumption as "tobacco products" under the FSPTCA (as long as no therapeutic claims are made by manufacturers). The FDA has subsequently agreed
Regulation of E-Cigarettes and Other Tobacco Products to comply with Judge Leon's ruling.
For disclosure, neither I nor Smokefree Pennsylvania have ever recieved any funding from a tobacco, drug or electronic cigarette company or trade association.
William T. Godshall, MPH
Founder and Executive Director
Smokefree Pennsylvania
1926 Monongahela Avenue
Pittsburgh, PA 15218
412-351-5880
smokefree@compuserve.com