November 21, 2013

Stanton A. Glantz, PhD

Glantz/Lempert comment on FDA menthol rule: Just ban it

Lauren Lempert and I just submitted a public comment on the FDA's Advanced Notice of Potential Rulemaking for menthol.

Our key points:

  • The FDA should simply ban menthol rather than menthol as a characterizing flavor.
  • There would be large and rapid health benefits because of people quitting smoking and fewer kids starting
  • It would be easier to enforce
  • Smuggling, to the extent that it exists, would be less of a problem
  • While the effects on smoking initiation and cessation are more important, the industry's own research, properly interpreted, shows increased toxicity of cigarette smoke when menthol is added
  • The FDA cannot take industry scientific submissions at face value

You can read the whole submission here.



As a public health professional with 14 years of experience with tobacco control and tobacco related health disparities (especially among Asian American communities) and given that tremendous research and professional viewpoint of the scientific community, I strongly believe that time has come for FDA to weather the storm and controversy (surrounding menthol ingredients in cigarettes) and take ad hoc action to ban Menthol categorically and not be hung up with partial action regarding characteristics such as menthol analogs and constituents that will undoubtedly be subject to manipulation by tobacco industry in future:
First, there is evidence regarding disparities in menthol use among certain ethnicities/minorities. Given my own research with Asian American youth in Ohio, we have time and again found; (a) perception of less risk due to menthol (because first it is associated with healthy products and second those who smoke menthol cigarettes feel a soothing effect which makes the smoker feel it is not toxic as they have heard); (b) that smokers smoking such cigarettes inhale deeply to get more kick and hence the heightened impact on the lung; (c) sadly enough it is the preferred brand among Asian youths/adolescents (which is strongly associated with the risk perception); (d) glamor value (display of smoking and sporting menthol cigarette is like a status); and (e) a gateway to other regular cigarettes (many young experimenters start with menthol first (because of the perceived less risk or no risk at all).
Second, we have witnessed the manipulative powers of the tobacco industries even when tough regulations/enforcements are in place. We also have seen they have even spend millions of dollars to fuzz science and denigrate valid research. Most alarming though is the fact that they spend billions on finding ways to circumvent the laws and regulations.
Third, through lobbyists and campaign finance, sadly so, they have the buy-in of many legislators and policy makers.
The most risk free approach and the right approach for FDA, keeping in mind thousands of young initiators who use menthol cigarettes as the gateway to regular cigarettes and find them entrapped in a lifelong addiction and associated morbidity and mortality, is to totally ban menthol and be done with it once and for all. If FDA does not take this historic step now, this would be a missed opportunity once and for all and expose itself to a Pandora's Box and force FDA to fight one of the most powerful enemy with the most sophisticated arsenal (resources!).
One last thing, to think that the tobacco industry could be trusted or they have changed their tune and have come a long way and willing to work with us could be likened to "trusting the cat to watch the milk." Which industry in a capitalistic society would like to see their profits go down the drain. If they were for public health or for the health of the people, why would not they transfer the resources to non-sin industries.
As a citizen, as a member of the Asian community, as a tobacco control professional, and as someone who has seen many friends and relatives become victims of smoking and tobacco use, I urge FDA to seriously take action with a total ban on menthol and be done with it. Dragging out feet on this now would lead to an outcome that would haunt generations. Thank you.
Surendra B. Adhikari, PhD
Research Administrator & Health Disparities Lead
Ohio Department of Mental Health and Addiction Agency
Columbus, Ohio
PS: These are personal and professional views and do not necessarily reflect those of the agency I am affiliated with.

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