September 17, 2018
Lauren Lempert listened in to the presentations and scientific discussion of the RJR application to market Camel Snus as a modified (i.e., reduced) risk tobacco product on September 14, 2018. After that session, she and I prepared this public comment, which we submitted to the FDA Camel Snus MRTP docket. The tracking number is 1k2-95hg-nfon and a PDF of the comment is available here.
COMMENT PREPARED AFTER THE TPSAC MEETIING ON CAMEL SNUS
RJR failed to demonstrate that Camel Snus, as actually used by consumers, will significantly reduce harm to individuals or benefit population health. FDA should not issue an MRTP order allowing RJR to market Camel Snus with modified risk claims
Lauren K. Lempert, JD MPH; Stanton A. Glantz, PhD
UCSF TCORS
Docket FDA-2017-N-4678-0001
September 17, 2018
September 14, 2018
Stella Bialous and I just published “Heated tobacco products: another tobacco industry global strategy to slow progress in tobacco control” in Tobacco Control discussing how the latest round of heated tobacco products fits into and supports the tobacco companies’ political efforts to avoid meaningful regulation and protect their ability to sell all their products – including conventional cigarettes.
We see these products as a reaction to the effective reductions in tobacco use that are being implemented around the world, including those stimulated by the FCTC:
September 14, 2018
Lucy Popova, Lauren Lempert, and I recently published “Light and mild redux: heated tobacco products’ reduced exposure claims are likely to be misunderstood as reduced risk claims” in Tobacco Control. This paper is another in the series of papers we have written based on a careful reading of the data that Philip Morris International submitted to the FDA to support its application to market IQOS in the US as a less dangerous product. We found that the information that PMI provided actually indicates that people are likely to misunderstand reduced exposure (i.e., users are exposed to less bad stuff by an IQOS than a conventional cigarette) as a reduced risk (i.e., IQOS is not as dangerous as a cigarette) claim.
This is important because even if FDA allows reduced exposure claims, they will be complicit in allowing PMI to mislead the public. Without evidence of reduced risk, claims of lower exposure are inherently misleading because they will be interpreted as reduced risk claims even if they do not explicitly make reduced risk claims.
And, of course, the same things hold for how PMI is marketing IQOS all over the world.
Here is the abstract:
September 12, 2018
September 9, 2018
The Canadian Ministry of Health has invited public comment on marketing statements that it proposes to allow e-cigarette companies to make to seel their wares.
The big problem is that these claims ignore everything we have learned about the dangers and use patterns of e-cigarettes in the last year or so.
Here is the comment I sent in. You can download a PDF of it here.
September 11, 2018
Mathew Cook
Manager, Regulations Division
Tobacco Products Regulatory Office
Tobacco Control Directorate
RE: Authorized statements regarding e-cigarettes
Dear Mr. Cook,
It has come to my attention that you are seeking comments on the List of Statements for Use in the Promotion of Vaping Products. I am pleased to offer some comments on these statements.