Why the FDA should deny RJ Reynolds' citizen's petition to change the warning on smokeless tobacco products

Two colleagues, Ganna Kostygina and Pamela M. Ling, and I have submitted a public comment to the FDA in opposition to RJ Reynolds' citizen's petition for the FDA to change the warning labels on smokeless tobacco products.  

Our bottom line is:

"Altering the text of the warning label to unequivocally state that smokeless tobacco presents substantially lower risks to health than cigarettes neglects the effects of dual tobacco use and the effects of smokeless tobacco use on smoking cessation, and so is fundamentally misleading consumers to underestimate the true risks associated with smokeless tobacco use.

 "For these reasons, the Citizen’s Petition should be denied.

 "In addition, as the FDA deliberates the content of any new smokeless warning labels, it should see that any such new warnings include the information that smokeless tobacco can discourage smokers from quitting tobacco and address the dangers of dual use.  To minimize the possibility of dual use, the FDA should prohibit the promotion of smoked and smokeless products as line extensions of the same brand name, and prohibit the explicit promotion of dual use."

The full comment is available here.