Submit your own here: http://www.regulations.gov/#!documentDetail;D=FDA-2014-N-1051-0001
Other resources: http://www.e-cigarette-forum.com/fo...chs-mrtp-application-tpsac-consideration.html
My comment (1jy-8fpw-yy0d):
I strongly encourage FDA to swiftly approve the Modified Risk tobacco Product Application submitted by Swedish Match North America for ten of its snus brands because smokeless tobacco products are far less hazardous alternatives to cigarettes, because hundreds of thousands of smokers in Sweden and Norway have quit smoking by switching to snus, and because the 1986 Comprehensive Smokeless tobacco Education Act and the US DHHS have been deceiving the public to inaccurately believe that smokeless tobacco products are as hazardous as cigarettes for nearly three decades.
On a scale of harm/risk from 1 to 100, on which FDA approved NRT products are 1 and cigarettes are 100, existing scientific and empirical evidence indicate that ALL noncombustible tobacco products marketed in the US are below 2, as all have very similar health/safety risk/benefit profiles as NRT products. Even in the absence of reduced risk marketing claims, population surveys found that several million smokers have already switched to smokeless tobacco products, despite numerous surveys finding that most smokers inaccurately believe smokeless products are as hazardous as cigarettes. So smokeless tobacco products have already saved more lives (of smokers) than could be offset even if every American non tobacco user begins to use smokeless tobacco.
The intentional deceptive messaging on smokeless tobacco products constitutes gross public health malpractice and must stop. As long as FDA continues to post and maintain inaccurate and misleading information about electronic cigarettes, smokeless tobacco, and other smokefree tobacco products, the agency cannot be trusted to make any objective decisions about MRTP Applications, any other tobacco regulations, or any other public health issue.
Instead of falsely claiming that all tobacco products are as hazardous as cigarettes, FDA must distinguish between these vastly different types of tobacco products and users. Public health benefits every time a cigarette smoker substitutes a smokefree tobacco product for a cigarette, and FDA needs to acknowledge this important fact. Thus, FDA also should correct or clarify ALL of the many inaccurate and misleading information about the health risks of different tobacco products, including those not explicitly covered in this MRTP application.
Other resources: http://www.e-cigarette-forum.com/fo...chs-mrtp-application-tpsac-consideration.html
My comment (1jy-8fpw-yy0d):
I strongly encourage FDA to swiftly approve the Modified Risk tobacco Product Application submitted by Swedish Match North America for ten of its snus brands because smokeless tobacco products are far less hazardous alternatives to cigarettes, because hundreds of thousands of smokers in Sweden and Norway have quit smoking by switching to snus, and because the 1986 Comprehensive Smokeless tobacco Education Act and the US DHHS have been deceiving the public to inaccurately believe that smokeless tobacco products are as hazardous as cigarettes for nearly three decades.
On a scale of harm/risk from 1 to 100, on which FDA approved NRT products are 1 and cigarettes are 100, existing scientific and empirical evidence indicate that ALL noncombustible tobacco products marketed in the US are below 2, as all have very similar health/safety risk/benefit profiles as NRT products. Even in the absence of reduced risk marketing claims, population surveys found that several million smokers have already switched to smokeless tobacco products, despite numerous surveys finding that most smokers inaccurately believe smokeless products are as hazardous as cigarettes. So smokeless tobacco products have already saved more lives (of smokers) than could be offset even if every American non tobacco user begins to use smokeless tobacco.
The intentional deceptive messaging on smokeless tobacco products constitutes gross public health malpractice and must stop. As long as FDA continues to post and maintain inaccurate and misleading information about electronic cigarettes, smokeless tobacco, and other smokefree tobacco products, the agency cannot be trusted to make any objective decisions about MRTP Applications, any other tobacco regulations, or any other public health issue.
Instead of falsely claiming that all tobacco products are as hazardous as cigarettes, FDA must distinguish between these vastly different types of tobacco products and users. Public health benefits every time a cigarette smoker substitutes a smokefree tobacco product for a cigarette, and FDA needs to acknowledge this important fact. Thus, FDA also should correct or clarify ALL of the many inaccurate and misleading information about the health risks of different tobacco products, including those not explicitly covered in this MRTP application.
