CAGW Submits Comments for Tobacco Products Scientific Advisory Committee Open Session
Agency Comments
June 17, 2024
Serina Hunter-Thomas Office of Science Center for Tobacco Products Food and Drug Administration Document Control Center, Building 71, Room G335 10903 New Hampshire Avenue Silver Spring, MD 20993-0002 TPSAC@fda.hhs.gov
Re: Tobacco Products Scientific Advisory Committee (TPSAC) Open Session to discuss the renewal of a risk modification order submitted by Swedish Match USA, Inc. for eight snus smokeless tobacco products.
Dear Advisory Committee Members,
Citizens Against Government Waste (CAGW) is a private, nonpartisan, nonprofit organization representing more than one million members and supporters nationwide. CAGW's mission is to eliminate waste, mismanagement, and inefficiency in government. Founded in 1984 by the late industrialist J. Peter Grace and syndicated columnist Jack Anderson, CAGW was created to follow up on the report of the President's Private Sector Survey on Cost Control, also known as the Grace Commission. CAGW appreciates the opportunity to provide comments regarding the renewal of a risk modification order submitted by Swedish Match USA, Inc. for eight snus smokeless tobacco products to be submitted to the meeting record for your June 26, 2024, meeting.
Efforts to reduce burn tobacco product use include less harmful alternatives to cigarettes. Snus, an oral tobacco product that is placed in the mouth between the lip and gums, but not spitted out, is among the products that help transition smokers to less harmful products.
Although the product still contains nicotine, and may still be addictive, a November 27, 2019, study in the Harm Reduction Journal found that, “The most recent Eurobarometer data from 2017 reported that Sweden had the lowest prevalence of daily cigarette use in the European Union at 5% whilst daily ‘oral tobacco’ use was reported to be 20%. European data published by the World Health Organization in 2018 indicated that Sweden had the lowest rate of tobacco-related mortality and the lowest incidence of male lung cancer. Overall, prevalence statistics and epidemiological data indicate that the use of snus confers a significant harm reduction benefit which is reflected in the comparatively low levels of tobacco-related disease in Sweden when compared with the rest of Europe.” The report also noted a decline in daily cigarette smokers in both Sweden and Norway, as adoption of snus among men in particular increased.
The Food and Drug Administration (FDA) first granted authorization for Swedish Match’s eight premarket tobacco applications for snus smokeless tobacco products on November 10, 2015. On October 22, 2019, the FDA issued a modified risk tobacco authorization to Swedish Match for the eight products currently under consideration for renewal, allowing these products to be advertised as lower risk for certain health effects compared to smoking cigarettes. Since that time, no reported issues relating to the use of these products has come up, and youth use of the products remain consistently low according to post-market surveillance by the FDA and the Centers for Disease Control, which found that smokeless tobacco products, including chewing tobacco, snuff, dip, or snus, were used by only 1.5 percent of teen tobacco users.
CAGW has long been engaged in promoting the benefits of tobacco harm reduction products. We ask that the advisory committee members review the scientific evidence that shows these products to be of lower risk than combustible tobacco products like cigarettes and cigars and approve the renewal of the risk modification order for the eight products offered by Swedish Match. Again, I appreciate the opportunity to offer the views of CAGW.
June 17, 2024
Serina Hunter-Thomas
Office of Science
Center for Tobacco Products
Food and Drug Administration
Document Control Center, Building 71, Room G335
10903 New Hampshire Avenue
Silver Spring, MD 20993-0002
TPSAC@fda.hhs.gov
Re: Tobacco Products Scientific Advisory Committee (TPSAC) Open Session to discuss the renewal of a risk modification order submitted by Swedish Match USA, Inc. for eight snus smokeless tobacco products.
Dear Advisory Committee Members,
Citizens Against Government Waste (CAGW) is a private, nonpartisan, nonprofit organization representing more than one million members and supporters nationwide. CAGW's mission is to eliminate waste, mismanagement, and inefficiency in government. Founded in 1984 by the late industrialist J. Peter Grace and syndicated columnist Jack Anderson, CAGW was created to follow up on the report of the President's Private Sector Survey on Cost Control, also known as the Grace Commission. CAGW appreciates the opportunity to provide comments regarding the renewal of a risk modification order submitted by Swedish Match USA, Inc. for eight snus smokeless tobacco products to be submitted to the meeting record for your June 26, 2024, meeting.
Efforts to reduce burn tobacco product use include less harmful alternatives to cigarettes. Snus, an oral tobacco product that is placed in the mouth between the lip and gums, but not spitted out, is among the products that help transition smokers to less harmful products.
Although the product still contains nicotine, and may still be addictive, a November 27, 2019, study in the Harm Reduction Journal found that, “The most recent Eurobarometer data from 2017 reported that Sweden had the lowest prevalence of daily cigarette use in the European Union at 5% whilst daily ‘oral tobacco’ use was reported to be 20%. European data published by the World Health Organization in 2018 indicated that Sweden had the lowest rate of tobacco-related mortality and the lowest incidence of male lung cancer. Overall, prevalence statistics and epidemiological data indicate that the use of snus confers a significant harm reduction benefit which is reflected in the comparatively low levels of tobacco-related disease in Sweden when compared with the rest of Europe.” The report also noted a decline in daily cigarette smokers in both Sweden and Norway, as adoption of snus among men in particular increased.
The Food and Drug Administration (FDA) first granted authorization for Swedish Match’s eight premarket tobacco applications for snus smokeless tobacco products on November 10, 2015. On October 22, 2019, the FDA issued a modified risk tobacco authorization to Swedish Match for the eight products currently under consideration for renewal, allowing these products to be advertised as lower risk for certain health effects compared to smoking cigarettes. Since that time, no reported issues relating to the use of these products has come up, and youth use of the products remain consistently low according to post-market surveillance by the FDA and the Centers for Disease Control, which found that smokeless tobacco products, including chewing tobacco, snuff, dip, or snus, were used by only 1.5 percent of teen tobacco users.
CAGW has long been engaged in promoting the benefits of tobacco harm reduction products. We ask that the advisory committee members review the scientific evidence that shows these products to be of lower risk than combustible tobacco products like cigarettes and cigars and approve the renewal of the risk modification order for the eight products offered by Swedish Match. Again, I appreciate the opportunity to offer the views of CAGW.
Sincerely,
Tom Schatz
President, CAGW
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