September 21, 2012
City of Omaha officials:
Mayor Jim Suttle (FAX: 402-444-6059)
Paul D. Krantz, City Attorney (FAX: 402-444-5125)
Thomas O. Mumgaard, Deputy City Attorney (FAX: 402-444-5125)
Buster Brown, City Clerk (FAX: 402-444-5263)
City Council Members:
District 1: Pete Festersen
District 2: Ben Gray
District 3: Chris Jerram
District 4: Garry Gernandt
District 5: Jean Stothert
District 6: Franklin Thompson
District 7: Thomas Mulligan
Dear Omaha City Council Members and Officials:
The Consumer Advocates for Smoke-free Alternatives Association (CASAA) encourages the City Council of Omaha to correct scientifically inaccurate information in the proposed ordinance to amend Chapter 12, Article VII of the Omaha Municipal Code pertaining to the sale of
tobacco products. Once this has been accomplished, it will become evident that, as currently structured, the proposed ordinance will endanger the physical health of citizens and damage the economic health of the city.
Section 12-135(a), Findings and Intent, fails to acknowledge the scientific evidence that cigarettes are by far the most hazardous type of
tobacco product. Cigarettes are burned and inhaled, which makes them far more harmful than tobacco and nicotine products that do not produce lung-damaging, carcinogenic smoke.
A 2007 report by the Royal College of Physicians noted that a large percentage of smokers may never be able to give up all use of nicotine.(1) The practice of substituting a low-risk nicotine product for smoking is called Tobacco Harm Reduction (THR). Such low risk products include smokeless tobacco products, electronic cigarettes, and long-term use of Nicotine Replacement Therapy (NRT) products.(2) Rather than treat all tobacco products as equally dangerous, politicians and health care advocates should embrace THR. For those who are unable or unwilling to completely quit tobacco and/or nicotine use, switching to a smokeless alternative can achieve substantial health benefits, with many such products carrying less than 1 to 2% of the risk posed by smoking.
During the past several decades, millions of Swedish smokers switched to snus, a type of spit-free moist snuff. As a result, adult daily smoking (age 15 and older) has dropped to 12% for men and 17% for women, which represent reductions of 44% and 29%, respectively, between 1995 and 2008.(3) Not coincidentally, Sweden has the lowest lung cancer mortality rate in the European Union.(4)
In a 2010 FDA workshop, Dr. Neal Benowitz reviewed the scientific evidence on the health benefits of switching to smokeless tobacco (ST) products as proof that NRT would be safe for long-term use. His presentation noted, The lack of increase in common cancers in lifelong ST users indicates that nicotine is not a general cancer promoter, and studies indicate minimal if any increased CV risks (i.e., heart attacks and strokes) with ST.(5)
The Omaha City Council needs to revise the description of health risks and economic impacts in Section 12-135(b), Findings and Intent, to reflect the fact that there are no increased costs to the City or to Omahas private employers related to the use of smoke-free alternatives. Furthermore, the proposed ordinance may actually result in unintended consequences: reducing the Citys revenue and increasing the health risks of its citizens.
Higher prices on all tobacco products may result in closure of Omahas tobacco specialty stores, e-cigarette vendors, and other small businesses as consumers seek lower prices outside the city. It may also result in continued smoking among those who might have switched to a lower-risk product if those products had remained conveniently available and affordable on a local level.
CASAA urges the Omaha City Council to revise the proposed ordinance so as to achieve the stated purpose of just, proper, and equitable distribution of tax burdens within the city. If this cannot be accomplished, the ordinance should be tabled altogether because, as structured, it stands to do more harm than good.
CASAA is a non-profit organization that works to ensure the availability of low-risk alternatives to smoking and to provide the public with truthful information about such alternatives. Please feel free to contact us if you require any additional scientific information on relative risks of various tobacco and nicotine products.
Sincerely,
Elaine Keller, President
ekeller@casaa.org
The Consumer Advocates for Smoke-free Alternatives Association
CASAA - The Consumer Advocates for Smoke-free Alternatives Association
(202) 241-9117
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1. Royal College of Physicians. Harm reduction in nicotine addiction: helping people who cant quit. A report by the Tobacco Advisory Group of the Royal College of Physicians. London: RCP, 2007.
http://www.tobaccoprogram.org/pdf/4fc74817-64c5-4105-951e-38239b09c5db.pdf
2. Rodu B. The scientific foundation for tobacco harm reduction, 2006-2011. Harm Reduct J. 2011 Jul 29;8:19.
The scientific foundation for tobacco harm reduction, 2006-2011
3. OECD/European Union (2010), Tobacco Consumption among Adults, in Health at a Glance: Europe 2010, OECD Publishing.
Tobacco Consumption among Adults - Health at a Glance: Europe 2010 - OECD iLibrary
4. OECD/European Union (2010), Mortality from Cancer, in Health at a Glance: Europe 2010, OECD Publishing.
Mortality from Cancer - Health at a Glance: Europe 2010 - OECD iLibrary
5. Benowitz N. Smokeless Tobacco and Disease: Evidence Related to Long-term Safety of Nicotine.
http://www.fda.gov/downloads/Drugs/NewsEvents/UCM232147.pdf
