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ACSH Statement for Senate Hearing on FDA Regulation of Tobacco
By Elizabeth M. Whelan, Sc.D., M.P.H., Gilbert Ross, M.D., Jeff Stier, Esq.
Elizabeth Whelan M.P.H., Sc.D.
Gilbert L. Ross, M.D.
Jeff Stier, Esq.
for
The American Council on Science and Health
“The Need for FDA Regulation of Tobacco Products”
Senate Committee on Health, Education, Labor and Pensions
February 27, 2007
Mr. Chairman:
The mission of the American Council on Science and Health (ACSH) is to promote sound science and to inform policy debates about public health, providing independent scientific evidence and analysis to clarify the scientific record in order to educate the public and assist policy-making. As such, we are writing on behalf of ACSH to lend our voice to others who have criticized S.625, a bill recently introduced in the Senate and referred to your Committee. We believe, as experts in the field of tobacco-related health effects and public health policy, that this bill would unnecessarily disregard a large and growing body of scientific evidence pertaining to the relative dangers posed by smoking and smokeless tobacco.
As you know, there has been a 50-year public health campaign against smoking cigarettes in the United States. Evidence has mounted, and indeed continues to mount, about the health risks associated with smoking cigarettes. And yet, despite widespread awareness of the general risks, cigarette smoking remains by far the greatest preventable cause of death in the United States, claiming more than 400,000 lives every year. While we can hardly say the public health campaign has failed – indeed, the ubiquitous acknowledgement of smoking’s risks can be considered a major accomplishment of public health consumer education – the campaign has long offered what should now be considered a false dichotomy to smokers: quit or die, instead of fostering awareness of harm-reducing alternatives to cigarettes for those who cannot quit nicotine altogether.
Indeed, after all these years, there is no reason to doubt that smokers know that cigarettes are unhealthful, yet they continue to smoke, in large part because of the difficulty of quitting. Unfortunately, quit rates with traditional methods are abysmal. This is where research published by ACSH might prove useful in this particular debate, and in the crafting of an improved, more beneficial version of S.625.
The conventional wisdom, perpetuated not only by cigarette companies but by otherwise reliable sources, including the U.S. Surgeon General, includes the fallacy that all tobacco products are equally harmful to public health. That is, smokeless tobacco, cigars, cigarettes, and pipe tobacco are, from a public health perspective, the same thing. Scientific studies have proven that they are not, and a rapidly-growing body of evidence confirms that they are not. Any effort to regulate tobacco products must explicitly acknowledge the differences in health risks between types of tobacco.
The fact is that modern smokeless tobacco products are considerably less harmful than cigarettes. No one should start using any form of tobacco if they can avoid it, of course, but for those who are already inveterate smokers and unable to quit nicotine altogether, smokeless tobacco at least provides a far, far safer (albeit not completely risk-free) way of receiving nicotine. Public policies that ignore this fact undermine public health, especially the health of those specifically designated to be in the protected, vulnerable group. Unfounded, unscientific pronouncements that lump all tobacco products and their risks together ultimately undermine the basic purpose of tobacco-regulatory policies. S.625 does not distinguish between harmful smoked tobacco and the demonstrably less harmful smokeless tobacco, to the detriment of millions of nicotine addicts. ACSH supports the announced goals of S.625 -- the reduction of smoking and smoking-related illnesses, clearer and streamlined regulation of tobacco, and the protection of children -- but we strongly disagree with the bill’s failure to appreciate the opportunity presented by the scientific evidence distinguishing smoking and smokeless tobacco.
Consider a limited but informative case in Sweden. ACSH recently reported on a study to gauge the efficacy of a program that encourages smokers to switch to smokeless tobacco products as an alternative both to smoking (which they know is harmful to them) and complete tobacco abstinence (which they have found extremely difficult). The results of the study are extremely positive. The program works. It works so well, in fact, that Sweden now has the lowest smoking-related mortality rates in the world. A similar program in the United States, where smoking is a bona fide public health disaster, could save thousands of lives and vast amounts of health-related expenditures. Harm reduction programs using smokeless as an option, even small programs, would seem to be a welcome opportunity to build on the successes and learn from the failures of our decades-old public health campaign against smoking. Smokeless tobacco is demonstrably less harmful than cigarettes, while making it much easier for some smokers to quit cigarettes. A transition from smoking to smokeless tobacco -- and for many, from smokeless to abstinence -- could produce great benefits for public health. It seems clear that it ought to at least be allowed a chance to work.
With even the U.S. Surgeon General failing in some public statements to rank the profoundly different health risks from different forms of tobacco -- differences that, if known to the general public, might save lives by means of harm reduction -- we must take care not to perpetuate the myth of smoking and smokeless tobacco equality. Part of what S.625 ought to do is to correct the public record regarding that myth, and until it does so, ACSH urges that the bill be modified or amended to allow lower-exposure products, such as smokeless tobacco, easy or at least equal access to the tobacco marketplace.
See also: ACSH's full report, Helping Smokers Quit: A Role for Smokeless Tobacco? 
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