August 8, 2014
Submitted to FDA:
Docket No. FDA-2014-N-0189
August 8, 2014
FDA and OMB should put the public health first, as the law directs them to.
Stanton A. Glantz, PhD
Professor and Director
The tracking number is 1jy-8dof-xl8c.
Thanks to Joel Dunnington for sending this around.
August 8, 2014
FDA Should Prohibit Flavors in all Tobacco Products including Electronic Cigarettes
Docket No. FDA-2014-N-0189
Emily Anne McDonald, PhD
Lauren K. Lempert, JD
Ganna Kostygina, PhD MPH
Pamela M. Ling, MPH, MD
Center for Tobacco Control Research and Education
University of California San Francisco
August 6, 2014
Although flavored cigarettes were banned under the 2009 Family Smoking Prevention Tobacco Control Act (TCA)[1], flavored tobacco products, including electronic cigarettes (e-cigarettes), continue to be widely available.
August 6, 2014
August 6, 2014
Recent Research, some conducted by the FDA, Reinforces Need for Regulation of ALL Tobacco Products to Protect Health
Docket No. FDA-2014-N-0189
LM Dutra, ScD1; RA SA Glantz, PhD1
1 Center for Tobacco Control Research and Education
University of California San Francisco
August 1, 2014
Two recent supplements to peer-reviewed journals have provided additional support for the need for the FDA to regulate all tobacco products, including e-cigarettes. The August 2014 supplement in the American Journal of Preventive Medicine that was entirely devoted to publishing research conducted by or with FDA scientists, revealed high levels of use of both conventional and nonconventional tobacco products among youth in the U.S., including e-cigarettes and cigars. Likewise, the July 2014 Tobacco Control supplement showed high levels of exposure to e-cigarettes in the media. This recent evidence supports the need for the FDA to provide improved warning labels for all tobacco products; regulate all types of cigars as addictive products that endanger the health of youth; and regulate the advertising, product design, and sales of all tobacco products, including e-cigarettes.
Samples for supplements
August 6, 2014
Today a group of leading economists released a report that is sharply critical of the way that the FDA (and, by implication, the OMB) does cost-benefit analysis of tobacco regulations, in particular saying that the consumer surplus discount the FDA/OMB applies to health benefits of regulation is simply wrong. It is espcially significant that one of the authors of the analysis if Jonathan Gruber, whose work the FDA cites to justify applying the consumer surplus discount discount. The economists also take FDA to task for grossly understimating the benefits of reducing tobacco use.
Like the paper Anna Song, Paul Brown and I published a few months ago on the strong evidence that consumer surplus simply does not make sense when dealing with an addictive substance like tobacco, the economists framed their analysis as a critique of the FDA's warning label rule. As we pointed out in the public comment we submitted on the deeming rule based on this paper, all the same issues apply, however, to the deeming rule.