Letter to the Commission Members of the President's Commission on Economic Opportunity in Communities Dependent on Tobacco Production While Protecting Public Health - Paul L. Perito, 3/14/01 4:53PM  

President’s Commission on Improving
  Economic Opportunity In Communities
  Dependent on Tobacco Production While
  Protecting Public Health
2101 L Street, N.W., Suite 303B
Washington, D.C. 20037

     Star Scientific, Inc. has reviewed the Commission’s Preliminary report, Tobacco Communities at a Crossroad, published on January 21, 2001. We wish to commend the Commission for its efforts and visionary work.

     The search for meaningful solutions that will reduce this nation’s leading preventable cause of death and disease demands that we take on challenges that are often difficult, and at times, seemingly insurmountable. The Commission’s critical examination of options that can protect U.S. tobacco growing communities and, in a parallel vein, be consistent with a range of reasonable public health interests, represents the kind of challenge that only a panel with creative vision would embrace. Change does not, and will not, come easily but, unless we recognize the challenging realities that we face in our efforts to reduce smoked tobacco’ s devastating toll, we will never meet our goals and expectations. At the same time, the cessation of smoked tobacco must be the initial and ultimate goal. Unfortunately, the U.S. farmer has been relegated for too long to a non-participatory role in this entire dynamic. Star Scientific has attempted to reverse that trend through its StarCure™ participating farmers’ program.  It has been our experience, in working with a multi-state group of public health oriented committees and concerned StarCure™ participating farmers, that they intend to be part of the "solution" to this seemingly intractable social, ethical, governmental, public health and farming quagmire.

     As you know, Star Scientific voluntarily testified before your Commission in Louisville, KY late last year. We understand that several major tobacco companies chose not to testify. This is indeed unfortunate since a complete record of all views appears to be essential to your mission. We testified because we believe that the future of tobacco production and manufacturing must significantly change, but that the American farmer needs to be an active participant in that changing dynamic. Star Scientific’s business was founded on the belief that, given the reality of the devastating toll taken by the daily worldwide use of smoked tobacco, i.e., over 1.2 billion people, the only reasonable response is an effort to reduce the toxicity of the manufacturing of tobacco-containing products to the maximum extent allowable, given available technologies. Simultaneously, it is vital that there be a rational and integrated public health-oriented "national agenda". However, we need to make certain that the American tobacco farmers participate in forging that "agenda" while also recognizing that public health interests should continue to play a paramount role in such a "national agenda".

     Star Scientific believes that its novel, proprietary curing technology can play a meaningful role in assisting American farmers to regain their pre-eminence in the worldwide tobacco market. For too long considerations based on price alone, and not the public health, have driven market decisions. Star believes accountability and tobacco farming productivity can go hand in hand, if they ultimately factor rational public health considerations into the mix. To achieve such a rational "national agenda", both vision and courage are needed. A necessary adjunct, however, is meaningful regulation of all aspects of the manufacturing, production and marketing of tobacco containing products. For that very reason, Star Scientific was the first technology-oriented tobacco company (with a toxicity reduction mission) to call for comprehensive FDA regulation, almost three years ago. Fortunately, the Commission’s work parallels what we perceive to be our effort to serve as a catalyst for long-overdue, positive change in an industry that unfortunately has been resistant to innovations, like adopting the most reliable and consistent method to cure tobacco leaf, that delivers the lowest possible carcinogenic TSNA levels, i.e., the StarCure™ method. Star Scientific’s unique farm StarCure™ program provides an added benefit to the U.S. farmer since it takes skill, responsible fertilizing practices and technological "know how"to consistently achieve the lowest possible carcinogenic TSNA levels. The ability to produce very low-TSNA StarCure™ tobacco should provide American tobacco farmers with the opportunity to distinguish their U.S. cured leaf from foreign competitors’leaf production, particularly if low-TSNA leaf becomes an internationally mandated standard.

	Tobacco producers and their communities should be given appropriate opportunities to explore viable approaches to reduce their total dependence on tobacco cultivation in such a manner as to allow them to survive, and hopefully thrive, in the coming years. These options should include, among others, consideration of a buyout, retention of some form of a tobacco program, economic development assistance, assistance designed to enhance farming methods and to issue quality controls to produce a more responsible product, i.e., the StarCure™ approach, which will better allow farmers to compete in the worldwide market and simultaneously be able to consistently produce tobacco leaf with the lowest levels of carcinogenic TSNA possible.
	The Food and Drug Administration should have authority to regulate the manufacture, sale and distribution, labeling and marketing of all tobacco containing products. Effective comprehensive tobacco control efforts should be implemented (as outlined in the Surgeon General’s 2000 Report) and be consistent with the findings and recommendations of the Institute of Medicine’s recent Report, Clearing the Smoke, relating to the encouragement of "potential reduced exposure products (PREP)". We must all attempt to prevent persons from taking up the use of tobacco products and provide effective ways of quitting as the primary focus of a national program. At the same time, companies committed to a public health-oriented agenda, like Star Scientific, should be encouraged to innovate in producing other forms of non-combustible tobacco products, with significantly reduced toxic delivery, to long-time adult tobacco users who cannot quit, or choose not to quit. We must recognize that it is possible to manufacture tobacco products that deliver less toxins.
	As the Report recommends, there needs to be a rational, integrated regulatory system in place to coordinate the production, manufacture and sale of tobacco with a focus on public health considerations (i.e., the USDA, EPA and FDA).
	New technologies (like the StarCure™ process) that will further improve the safety of tobacco leaf or that will identify alternative uses for tobacco need to be developed, implemented and encouraged. These technological applications should be evaluated and overseen by agencies such as the USDA, EPA and FDA on a meaningful basis. If we raise the bar too high on innovative potentially reduced exposure products (PREP), then companies like Star Scientific will have little incentive to devote scarce financial and human resources to the research and development of products that lower toxic exposure for the users of tobacco products.