Date: Mon, Jun 11, 2001 3:36 PM

Subject: Cigarette & Smokeless Tobacco Reports

11 June, 2001

Office of the Secretary
Federal Trade Commission
Room 159
600 Pennsylvania, NW.,
Washington, DC 20580

Reference: Cigarette and Smokeless Tobacco Reports

Dear Office of the Secretary:

Many believe that the tobacco industry is a major obstacle to tobacco prevention. The Federal Trade Commission (FTC) should continue issuing its periodic reports on how much the cigarette companies and smokeless tobacco companies spend each year marketing and promoting their toxic products.

Your official publications help shed light on economic arguments used by the tobacco industry to divert public and policy maker's attention from the health issues. These reports also, provide policy makers and advocates with a clear context and analysis of emergent issues. For example, lacking these data it would be difficult to understand and explain distinctions between expenditures in advertising (newspapers, magazine, outdoor, transit expenditures, television and radio [before 1971]), and promotions that include point-of-sale, promotional allowances, sampling distribution, direct mail, public entertainment, endorsement, and testimonial expenditures. Again, without these reports, advocates, planners, health educators, and coalitions, etc. will be less effective in their roles. Thus, public disclosure about tobacco advertising greatly enhances the ability of citizens to identify misleading claims about manufacturing, sale, and marketing of tobacco products.

I think, believe, and feel that the FTC must go beyond their recent request for supplemental information about the nature of these reports to Congress. The statutory relevancy of the Comprehensive Smokeless Tobacco Health Education Act of 1986 (15 U.S.C. §§ 4401-4408) (Smokeless Tobacco Act". Section 8(b) of the Smokeless Tobacco Act should not be loss among the reporting requirements of P.L. 104-66, section 3003(a), 109 Stat.734. Moreover, outcome data or evaluation reports provided by the General Accounting Office (GAO), or another credible agency would further establish the true need for issuing future reports. Perhaps, it is time for the Commission to move beyond monitoring compliance with the Smokeless Tobacco Act and smokeless tobacco advertising and sales and really determine what type of appropriate action best serves the nation's public health.

Sincerely,

Jamaal Martin, MPH., RCP, MT
Instructor/Lecturer, Department of Internal Medicine