Mon, Jun 11, 2001 8:54 AM
Subject: Cigarette And Smokeless Tobacco Reports
Department of Cancer Prevention, Epidemiology, and Biostatistics
June 11, 2001
Dear Mr. Ostheimer:
I am writing in response to your request for public comment on the cigarette and smokeless tobacco (C/ST) reports issued by the Federal Trade Commission (FTC). I am the Director of the Tobacco Control Research Program of the Roswell Park Cancer Institute (Buffalo, New York) and a former Chief of the Epidemiology Branch at the U.S. Centers for Disease Control and Prevention's Office on Smoking and Health. I was also a committee member and contributing author of the recent Institute of Medicine report entitled, "Clearing the Smoke. Assessing the Science Base for Tobacco Harm Reduction."
I believe very strongly that the C/ST reports should be maintained and expanded. These reports provide valuable information on tobacco advertising and promotion activities that allow scientists and practitioners of tobacco prevention and control to assess trends in industry marketing practices. We learn, from the reports, to what extent and how the industry markets its products. The most recent estimate, of $8.4 billion is staggering, especially when considered in light of what is spent to counter the industry's promotional activities. I will respond to each question below:
1. The C/ST reports are used by researchers, both within government and in the private sector, and by policy makers to attempt to understand and counter the industry's marketing activities.
2. I do not know how much the costs are, but I believe strongly that the costs should be interpreted in light of the damage done to consumers by the misperceptions engendered by industry advertising and promotions. Further, any costs are likely to be passed on to consumers, which will result in lower consumption of the products.
3. Absolutely - this information is vitally important. It gives us the only relevant information on the amounts and types of advertising and promotional activities conducted by the industry. It also gives us information on the types of products being sold (e.g., mentholated cigarettes and filtered cigarettes).
4. All of the data in the reports are useful. The marketing expenditure data, percent of cigarettes sold by tar level, mentholation type, presence of a filter, and whether the brand contains a warning label come immediately to mind,
5. Yes. As pointed out in the Institute of Medicine report, "Clearing the Smoke. Assessing the Science Base for Tobacco Harm Reduction, " additional information on marketing by brand would be of tremendous help in sorting out factors that can influence use of specific products. Furthermore, state-specific or at minimum, region-specific activities should be reported. When I was at the CDC, we published a report indicating the Camel cigarettes were preferred more often by adolescent smokers in the West than by adolescent smokers in other areas of the country. In an attempt to better understand reasons for this finding I asked the FTC if we could see advertising data by region and by brand, but the FTC could not provide this information. Such information would have been extremely helpful. I would also recommend that the FTC add information on whether advertising was for potential reduced-exposure products," as these will become more important over time as attempts to produce reduced-risk products are implemented.
6. Annually - anything less frequent would diminish the benefits of these reports for tobacco prevention and control activities.
7. Please consider that more than 400,000 Americans die annually from the products you are monitoring and that about 8 million Americans are alive with diseases or conditions caused by these products. These reports help us to fight the scourge of tobacco in the United States and should be continued and expanded.
Please feel free to call (716-845-4402) or e-mail
Gary A. Giovino, Ph.D.