Thu, Jul 20, 2000 4:35 PM
Subject: smokeless tobacco product labeling
Secretary, Federal Trade Commission
Re: 16 CFR Part 307
This letter is in response to your Request for Comments Concerning Regulations Implementing the Comprehensive Smokeless Tobacco Health Education Act of 1986.
Smokeless tobacco is a growing problem in Oklahoma. In Pittsburg County, 36% of our high school students are currently using spit tobacco compared with 13% statewide and 7% nationwide. These results are from the OYTS conducted in spring of 1999. Users of these tobacco products are not receiving sufficient warnings or information about the health risks associated with smokeless tobacco use.
Labels on smokeless tobacco products should be much more prominent and cover at least 50% of the package's main and side panels and even require a package insert. Larger print for warnings would help and appropriate contrasting colors and format should be used to ensure increased visibility.
Rotating the warnings would also be beneficial to maintain effectiveness. Health messages should give the consumer important and graphic information about the addictive properties of smokeless tobacco, the immediate and long-term, disease specific health effects of smokeless tobacco use, and all ingredients, or at the very least, the hazardous ones, included in the product.
The warning labels should correspond to the grave dangers of smokeless tobacco. The FTC has long advocated stronger labeling and should be allowed to pursue these stronger labeling requirements to adequately protect current users of smokeless tobacco and potential users, mostly minors.
At a local level, we are seeing too many young people using smokeless tobacco. The tobacco industry has targeted youth with these products by making them in favorable flavors for youth and even putting the tobacco in small packets for easier and cleaner use when placed in the mouth. In Pittsburg County, youth perceive smokeless tobacco users in a positive light as associated with rodeos and cowboys.
I appreciate your time and your consideration.