FDA TPSAC Meeting on Dissolvable Tobacco Products
January 19, 2012
Statement
by
William T. Godshall, MPH
Executive Director
Smokefree Pennsylvania
1926 Monongahela Avenue
Pittsburgh, PA 15218
412-351-5880
FAX 351-5881
smokefree@compuserve.com
Hi,
I’m Bill Godshall, founder and executive director of Smokefree Pennsylvania. Since 1990, we’ve advocated local, state and federal policies to reduce indoor tobacco smoke pollution, reduce tobacco marketing to youth, increase cigarette tax rates, and in 2007 I convinced Senator Mike Enzi to amend the FSPTCA to require picture warnings on cigarette packs.
For disclosure, neither Smokefree Pennsylvania nor I have ever received any funding from any tobacco, drug or electronic cigarette company.
I urge TPSAC members to carefully review the 100 pages of comments I submitted evaluating hundreds of studies and other evidence finding that smokefree tobacco products are about 99% less hazardous than cigarettes, and that several million smokers in US have already quit smoking cigarettes by switching to smokefree alternatives, far more than in Sweden.
Since >99% of tobacco attributable deaths in the US are caused by inhaling tobacco smoke, it is vitally important that TPSAC’s report on dissolvables acknowledge the exponential differences of risk between cigarettes and smokefree tobacco products.
Smokers have a human right to be truthfully informed that smokefree tobacco products are far less hazardous alternatives to cigarettes. Consistently, health agencies have an ethical duty to truthfully inform smokers that smokefree tobacco products are far less hazardous alternatives to cigarettes.
Since several million smokers in the US have already switched to smokefree tobacco alternatives, it is mathematically impossible for smokefree tobacco products to increase tobacco attributable mortality even if every American begins using dissolvables or other smokefree tobacco products.
Dissolvable tobacco products are target marketed to smokers as cigarette alternatives. Most new users of smokefree tobacco products are adult smokers, and most smokefree products pose no health risks to nonsmokers.
On a scale of mortality risk from 1 to 100 where NRT products are 1 and cigarettes are 100, all smokefree tobacco products sold in the US and Sweden appear to be below 2. Smokefree tobacco products and NRT products have very similar health/safety risk/benefit profiles.
Unfortunately, the FDA has falsely stated “To date, no tobacco products have been scientifically proven to reduce risk of tobacco-related disease, improve safety or cause less harm than other tobacco products."
In 2009 the FDA misrepresented its own laboratory test findings on e-cigarettes to scare the public and falsely claimed the products were target marketed to youth. Those and other false and misleading claims are still on FDA’s website.
In preparing for meetings in July and this week, the FDA instructed TPSAC to focus its report on nonexistent, miniscule and hypothetical risks of dissolvables, but not to consider the health benefits that occur every time a smoker consumes a dissolvable tobacco product instead of a cigarette.
It was wrong for cigarette companies to mislead the public about the risks of cigarettes for decades. But it is far worse when public health agencies misrepresent the comparable health risks of cigarettes and noncombustible tobacco products.
Human rights, ethics, science and public health must no be compromised by abstinence-only policies and anti-tobacco propaganda.
Thank you
