From: SMOKEFREE@compuserve.com
Date: Wed, 09/10/08
The US Federal Trade Commission's proposal to rescind its 1966 guidance
(that enabled and perpetuated the safer cigarette fraud based upon
inaccurate and unreliable tar and nicotine yields) is at:
http://www.ftc.gov/os/2008/07/P944509cigarette.pdf
To submit a supportive public comment (deadline September 12, 2008), go to:
https://secure.commentworks.com/ftc-CigaretteTestMethod
Smokefree Pennsylvania submitted the following comment.
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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=cont
ent~order=page
William T. Godshall, MPH
Executive Director
Smokefree Pennsylvania
1926 Monongahela Avenue
Pittsburgh, PA 15218
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