Comments on Preliminary Report - Swedish Match North America, 4/12/01 12:17PM   

Re:  Comments on The Preliminary Report of the President’s Commission on Improving Economic
Opportunity in Communities Dependent on Tobacco Production While Protecting Public Health  (“The Preliminary Report”)

 
    These comments on The Preliminary Report are submitted on behalf of Swedish Match North America Inc. (“SMNA”).  SMNA is a manufacturer of smokeless tobacco (loose leaf chewing tobacco, plug tobacco, and moist snuff), cigars, and pipe tobacco, as well as a distributor of lighters.  Its manufacturing facilities are in Owensboro, Kentucky (where its smokeless tobacco and pipe tobacco are produced) and Dothan, Alabama (where its cigar products are manufactured).  SMNA supports US tobacco growers, through its participation in the dark fire and dark air tobacco market in Kentucky and Tennessee and its involvement with the burley and flue cured growers in Virginia and North Carolina.  In addition, to maintain its close, traditional ties to the tobacco growing community, SMNA has a facility in Stoughton, Wisconsin, where it receives and stores type 54 style tobacco for its loose leaf chewing tobacco production.  In total, SMNA employs over 1000 workers in the United States.  Upon review of the Preliminary Report, SMNA urges the Tobacco Commission to consider the following:

Table 1, on page 15 of The Preliminary Report contains rates purporting to reflect “Male Youth Smokeless” use in a number of states, including a rate of 15.9% for “Other States’ Averages.”  There is no indication from what source these figures are derived or the basis upon which these rates of use were determined.  More importantly, these figures do not accurately reflect the findings of recent studies which demonstrate that illegal youth usage of smokeless tobacco is low and decreasing.   According to the 1999 National Household Survey on Drug Abuse (U.S. Health and Human Services (HHS), August 31, 2000), the percentage of young people age 12 to 17 using smokeless tobacco within the month proceeding the survey fell from 2.0% in 1997 to 1.2% in 1998 and has remained at this record low level for over a year.  Similarly, on December 14, 2000, HHS released the annual “Monitoring the Future” survey.  That survey reported substantial declines in youth usage to low single digit figures.  Specifically, the survey reports that since 1995, “use has fallen fairly steadily, dropping by 45 percent among 8th-graders, 42 percent among 10th-graders, and 38 percent so far among 12th-graders.”   Other recent federal government reports support low levels of youth usage among high school males.  See “Youth Tobacco Surveillance United States, 1998-1999”, Center for Disease Control and Prevention, MMWR, October 13, 2000 (reporting use at a 2.5% level).  In light of these reports, SMNA remains hopeful that the Tobacco Commission’s final report will accurately reflect the low and dramatically decreasing illegal youth usage of smokeless tobacco products.

On page 14 of The Preliminary Report, the Commission refers to smokeless tobacco as “spit tobacco.”  The use of this term is entirely improper, inappropriate and inaccurate.  The United States Congress, the United States Federal Trade Commission, other federal government agencies, and the state governments (in connection with legislation such as the Comprehensive Smokeless Tobacco Health Education Act of 1986 (CSTHEA), reports to Congress under CSTHEA, the federal excise tax laws and regulations, and state laws regulating these products) correctly refer to these products as “smokeless tobacco.”  Accordingly, any reference to “spit tobacco” should be eliminated from the final report as a demonstration that the Commission’s intentions are to be objective and constructive.

With respect to the health risks that some have associated with the use of smokeless tobacco and that are addressed at page 14 of The Preliminary Report, for the sake of completeness and accuracy, the Commission should include reference to the findings of the more current scientific literature regarding the use of smokeless tobacco and health.  A number of recent studies report findings of no link between smokeless tobacco use and the disease being studied.  See e.g.,  Lewin, et al.,1998 (failing to demonstrate link between smokeless use and oral cancer); Schilt, et al.,1998 (similar conclusion); Benowitz, Journal of American College of Cardiology, November 1999 (smokeless tobacco not a significant risk factor for cardiovascular disease). 

Finally, The Preliminary Report fails to take into account the interests of all tobacco farmers, including the dark fire, dark air, and Wisconsin growers with whom SMNA has a long standing working relationship.  In preparing its final report, the Commission must recognize the impact its regulatory recommendations will have upon these growers.

I am hopeful that the Commission will carefully consider these comments as it prepares it final reports.


            Sincerely,


            Gerard J. Roerty, Jr.,   
            Vice President