I read the comment your organization left on Regulations.gov regarding implementation of
tobacco regulations.
Were the FDA to place the type of warning labels you describe on smokeless tobacco products, they would be in violation of the Data Quality Act, as well as guidelines for data quality issued by the Office of Management and Budget, Department of Health and Human Services, and Substance Abuse and Mental Health Services. Such labeling implies that there are no health benefits conveyed by switching from smoking to smokeless tobacco and that no additional harm would be incurred by smokeless tobacco users who switch to smoking.
If you are unaware of the fact that smokeless tobacco presents a small fraction (perhaps 1-2%) of the health risks associated with smoking, then go to this web site PubMed Home and type the following into the box next to the Go button: smokeless tobacco smoking risk
The evidence is overwhelming that many more people get sick and die from smoking than from smokeless tobacco.
The NSDUH Report March 5, 2009: Smokeless Tobacco Use, Initiation, and Relationship to Cigarette Smoking: 2002 to 2007, states that 65.5% of smokeless tobacco users started using cigarettes first, which negates your gateway to smoking theory. Furthermore, if the 31.8% who did start with smokeless tobacco had been provided with accurate information, it is quite possible that they would not have moved on to the much more dangerous practice. These converts to smoking have organizations such as the American Lung Association to thank for their ignorance.
Consider the Scripps motto: Give light and the people will find their own way. It is long past time for respected health organization such as yourself to start living up to their mission statements. Your mission is To prevent lung disease and promote lung health. Smokeless tobacco use does not expose the body to the harmful combustion products and assault on the lungs that result from smoking.
Do I believe smokeless tobacco is harmless? Absolutely not! But the fact that the number of smokers in this country has remained relatively unchanged over the past 20 years should tell you something: There are tens of millions of people who are unwilling or unable to give up their dependence on nicotine. Standing in the way of their access to reduced-harm products such as smokeless tobacco and electronic cigarettes is tantamount to medical malpractice.
