|Received:||9/11/2008 1:13:05 PM|
|Organization:||Duke University and QuitSmart, Inc.|
|Agency:||Federal Trade Commission|
|Rule:||Proposal to Rescind FTC Approval of the Current Cigarette Test Method|
Comments:The FTC should not rescind its guidance that permits statements about tar and nicotine yields when such statements are based on a single test method -- the Cambridge Filter Method.This information is useful in two treatments that help smokers quit: Nicotine Fading or Brand Switching, and Pre-Quit Use of the Nicotine patch paired with the smoking for 2 weeks of an ultra-low nicotine brand of cigarettes (< 2 mg nicotine). Brand Switching: Several studies have found that when a smoker is switched from a cigarette brand with an average nicotine rating (0.8–1.0 mg) to a low-rated brand (< 0.1–0.2 mg), blood nicotine level (measured by its metabolite cotinine) drops an average of 30–49% (Benowitz, et al. 1986; McGovern and Lando, 1991; Westman, Tomlin, and Shipley, 1999; Zacny and Stitzer, 1988). While less than the putative reductions of 80–90% implied by the machine-rated nicotine yields published by the Federal Trade Commission (FTC), the obtained reductions are nonetheless clinically meaningful. The cited studies also found reductions in carbon monoxide levels of 24–36%. Pre-Quit use of the Nicotine Patch: Studies have not found any danger from smoking while wearing a patch. Australia has decided it is safe and has approved pre-quit use of the patch. England has removed its warning against smoking while wearing a patch, and fourteen countries have approved use of various forms of NRT while the user continues to smoke. When using a patch before the quit date we recommend switching from the smoker's usual brand of cigarettes to an ultra-low nicotine brand. This keeps pre-quit patch use very safe because the smoker is unlikely to get more nicotine than from smoking their usual brand of cigarettes. For these two treatments to continue and be subjected to further research, we need access to reliable nicotine ratings of different cigarettes brands. II don't believe the Commission's proposal would have any effect on consumers' purchases of cigarettes or on their smoking behavior.