|Oregon Department of Human Services
Health Promotion and Chronic Disease Prevention Program
Tobacco Prevention and Education
800 N.E. Oregon, #21
Portland, OR 97232
July 20, 2000
RE: 16 CFR Part 307
Comments on the Smokeless Tobacco Warning Label Regulations
Approximately 86,000 Oregonians use smokeless tobacco. The health hazards of smokeless tobacco are well-documented. Prevention of those illnesses is a priority for the Tobacco Prevention Program in Oregon, particularly in Eastern Oregon where use is more prevalent than in other parts of Oregon.
In addition to education and community awareness, a powerful tool to prevent people from using smokeless tobacco is the package warning label.
Canada requires larger warning labels on smokeless tobacco products, in larger type and in greater contrast to the background than we require in the US. A comparison of the US warnings to the Canadian warnings done by the Massachusetts Tobacco Control Program, shows several clear findings:
Because greater recall correlates to greater awareness of the message, it is clear that a significant benefit could be derived from more stringent warning labels in the United States.
Therefore, it is our recommendation that the FTC do the following:
Thank you for your consideration of our recommendations.
Very truly yours,