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Can We Make Tobacco History
     in our Life Time?

  Gregory N. Connolly, D.M.D., M.P.H.
    Harvard School of Public Health
             November 29, 2012
Disclosure

I recently resigned my position at Harvard School of
Public Health to become a Senior Scientific Advisor to
a global consumer product manufacturer
   My decision was based on a growing realization
    that a free market that maximizes individual free
    choice with minimal government interference is
    best able to benefit society and reward those
    who contribute most.
   Just Ask the People What does Government
    Best?

   Selling Power Ball Tickets?

   Regulating the Market Place?

   Reducing Poverty?
Steve Jobs sold products: Style, High Tech and Utility
                    It’s the Product Stupid




Apple, 1984                                        Apple, 2012
“Our company’s strategic priority is to develop,
assess and commercialize products that can
reduce the health risks of smoking on an
individual and population basis. These are New
Growth Products or “Safer Cigarettes”. These
products have the potential to be the greatest
innovation in the industry.”
Our new growth products efforts are guided by the
following key objectives:

“Our first objective has been to develop a series of
products that provide adult smokers the taste,
sensory experience and smoking ritual
characteristics that are as close as possible to those
currently provided by conventional cigarettes.”
Trends in Per Capita Consumption of Various
      Tobacco Products – United States, 1880-2004 and
                 Linear Projection to 2035
                16    Cigarettes        Cigars       Pipe/Roll your own   Chewing   Snuff
                14


                12

                10
       POUNDS




                8

                6


                4

                2


                0
                     1880
                     1885
                     1890
                     1895
                     1900
                     1905
                     1910
                     1915
                     1920
                     1925
                     1930
                     1935
                     1940
                     1945
                     1950
                     1955
                     1960
                     1965
                     1970
                     1975
                     1980
                     1985
                     1990
                     1995
                     2000
                     2005
                     2010
                     2015
                     2020
                     2025
                     2030
                     2035
                                                            YEAR



Source: Giovino GA. Am J Prev Med 2007;33(6S):S318–S326.
Source: PM Investor Day, June 21, 2012
“We are very encouraged by the meeting (with the
Center for Tobacco Products with the Food and
Drug Administration) and although several details
still need to be discussed, we remain comfortable
with our current risk assessment approach.”
Trends in Per Capita Consumption of Various
      Tobacco Products – United States, 1880-2004 and
         Extremely Undesirable Projection to 2060

                16
                     Cigarettes        Cigars       Pipe/Roll your own   Chewing   Snuff
                14


                12

                10
       POUNDS




                8


                6

                4


                2

                0
                     1880
                     1885
                     1890
                     1895
                     1900
                     1905
                     1910
                     1915
                     1920
                     1925
                     1930
                     1935
                     1940
                     1945
                     1950
                     1955
                     1960
                     1965
                     1970
                     1975
                     1980
                     1985
                     1990
                     1995
                     2000
                     2005
                     2010
                     2015
                     2020
                     2025
                     2030
                     2035
                     2040
                     2045
                     2050
                     2055
                     2060
                                                            YEAR


Source: Giovino GA. Am J Prev Med 2007;33(6S):S318–S326.
“We are opting for one or two Greenfield facilities in Europe”


“…we envisage marketing our NGPs under our existing major
trademarks such as Marlboro.”

“…we expect the first factory to be ready in 2015 or 2016 final data
from clinical studies during the beginning of 2016 and a launch in
the first markets between 2016 and 2017.”

However we still must respect fundamental choice of individuals to
decide and let them choose and move the market to a safer one
   Until consumers accept an FDA approved
    Modified Risk Product like our NGPs we have
    as an interim Smokeless tobacco to let free
    choice move the market to a safer one

   Some scientist who receive “independent”
    grants from us see a 95% reduction. The
    Swedish experience shows it can happened



   We now have Verve!!
Smokeless Tobacco as an Approved
  FDA Modified Risk Product
   Data suggests Swedish Match has lower levels of lung
    cancer among males where use rates are high and
    smoking rates low
   Standards exist for lowering toxins in Swedish Snuss far
    lower than its concentrations in moist snuff
   Hard core inadvertent adult smokers who cannot quit
    should be given the choice for reducing harm
   Continuum of risk exists among tobacco products with
    cigarettes highest, Moist Snuff middle and Snuss lowest.
Our Response to Infant Poisoning                                                             45



“For instance, in 2007 the total number of
  reported pediatric exposures for cosmetics was
  172,541 compared with only 6,724 pediatric
  exposures for tobacco.”


   (Source: RJRT Submission on Impact of Dissolvable Tobacco Use
   on Public Health to TPSAC, Food and Drug Administration, September 2010)

   G.R. Krautter, & M.H. Abdelhameed, Clinical and Pharmacokinetic (PK) Characteristics of an
   Orally Ingested Tobacco Pellet (2007)
VERVE: Our “Much” Safer New Nicotine Chewing Gum


Verve is a nicotine chewing gum we are test marketing in Richmond
with very low levels of toxins thus greatly reducing the risk of
many smoking related diseases

Although the amount and type of nicotine is a trade secret , we
have provided our consumers with very strong warnings:

 “This product is addictive, can harm your baby if you are pregnant
and can increase your risk to heat disease, aggravate diabetes, etc.”

Verve has child proof packaging to prevent poisoning !!!!!
   WE Designed Verve “Voluntarily” to Make It
    the Package Safe from Child Poisoning

   Let Me Show You
You Can be Part of the Solution!
You can help us! Together we can eliminate tobacco disease with
NGPs and “safer” SMOKELESS

Stop Fighting over Menthol and Give Freedom to the Black Smoker
to Decide

Provide funds to support research and attempts not to have
cigarettes sold to children or help tobacco users quit

Our power is too great not to accept this offer!
Multinationals Profits vs National GDPs
                             25,000



                                         $19,817                            $19,870
                             20,000
       Millions of Dollars




                             15,000


                                         32 of the
                                      lowest income                         4 TTTCs
                             10,000
                                         nations



                              5,000                                                                                   $3,890

                                                                                                                    Total Budget

                                 0
                                        Total GDP                             Profits                              WHO Budget
Total GDP is inclusive of 32 nations: Tuvalu, Montserrat, Nauru, Kiribati, Marshall Islands, Anguilla, Sao Tome and Principe, Palau, Cook Islands,
Micronesia (Federated States of), Tonga, Dominica, Comoros, Saint Kitts and Nevis, Samoa, Solomon Islands, United Republic of Tanzania: Zanzibar,
Saint Vincent and the Grenadines, Vanuatu, Grenada, Timor-Leste, Guinea-Bissau, Liberia, Micronesia, British Virgin Islands, Seychelles, Gambia, Somalia,
Antigua and Barbuda, Djibouti, Saint Lucia, and Turks and Caicos Islands.
For Countries Who Are Not
      Ready For Safer Cigarettes
   We are an international Company competing
    with the Japanese, British and now the
    CHINESE!!!!! Your best bet is America!!!
   We need to make a profit for our Shareholders
    State Pension Funds, Colleges, Health Insurance
    Companies. All of You will be affected.
    We sell the superior America Marlboro with
    more taste and pleasure and their Light!!!
   They’ll smoke anyways why not ours???
Female Smokers


“The number of Indian female smokers eclipsed those of
China by 2007, growing by 31% between 2006-2011.”

The kinds of innovations in place to cater to this growing
consumer base include super slims – longer, thinner
cigarettes… often with a charcoal filter for a smoother smoke,
and packaged in so-called “purse packs”…sometimes in
colors…coordinate with outfits or mood.”

Source: Euromonitor June 2012
Filter and Menthol Innovation
Role Filter Innovation

Much of the “added value” NPD activity centers around the filter, as it is here that
the flavour and any reduced chemical load or odour and enhanced product taste are
manifest.




   Source: Euromonitor June 2012
Marlboro Filter
Flavor Plus
Our Response to FDA
“
’Our company is” opposed to regulations
that are extreme in nature and are not
evidenced based. These include plain
packaging, health warnings covering most
of the pack, display bans and bans on the
use of all ingredients.”
Remarks from our CEO
Smokeless Tobacco Warning
        Labels in the US




-Must cover 30% of the two principle sides of package
-4 rotating warnings
Federal Tax Rates on Tobacco Products (2009)

                                     Previous Tax            SCHIP 2009 (New Tax)      Tax Increase       % Increase      % of the Tax on a Cigarette Pack

Cigarettes (20)                        $0.39/pack                 $1.01/pack            $0.62/pack           158%                        100%


Small Cigars (20)                      $0.04/pack                 $1.01/pack            $0.97/pack           2653%                       100%

RYO Tobacco (20)                       $0.04/pack                 $0.80/pack            $0.76/pack           2159%                      79.21%


Snuff (1.2 oz.)                         $0.04/tin                  $0.11/tin             $0.07/tin           158%                       10.89%

Chewing Tobacco (2.5 oz.)             $0.03/pouch                $0.08/pouch           $0.05/pouch           158%                        7.92%




      Source: United States Department of Treasury, Alcohol and Tobacco Tax and Trade Bureau. http://www.ttb.gov/main_pages/schip-summary.shtml -
      December 14, 2009
      Note: 20 RYO Cigarettes = 14.5g of Tobacco (0.51 oz)
Current Use of Flavored Smokeless by Users of Smokeless
Tobacco Products - 2010
Maryland Public High School Youth

   100%
     90%
     80%
                                            68.9%
     70%
                                                                                                                  61.1%
     60%
     50%
     40%
     30%
     20%
     10%
       0%

                                     High School                                                         Middle School

Source: Maryland Department of Health and Mental Hygiene, Youth Tobacco Survey – Fall 2010. Current smokeless tobacco use is any use of any smokeless tobacco
product during the 30 days prior to the survey.
32
“The Government has proven that the
 Enterprise [Tobacco Industry] knowingly
 and intentionally engaged in a scheme to
 defraud smokers and potential smokers,
 for purposes of financial gain, by making
 false and fraudulent statements,
 representations, and promises.”
       United States District Court For the District of Columbia. United States of
 America et al, v. Philip Morris USA Inc., et al. Final Opinion: August 17, 2006. Civil
 Action No. 99-2496 (GK).
   But What Do You Tell the Kids!!

   Read What the FDA Scientific Advisory
    Committee has to Say about US

   We Would Like to Thank our Non Voting
    Members for their Collegial Scientific Input into
    Our Menthol Report!!!
A Jeffersonian View of a Citizens Role in
                   Governance




                    A




My typical day at work on tobacco control
31




   Over the past few years, the cigarette
    industry has acquired the smokeless
    tobacco industry dramatically changing the
    incentives for product design and use;
    Combined use? Maintenance of smoking?
    Initiation?
Smokeless Tobacco is a Very
    Serious Public Health Problem
Smokeless Tobacco Causes
 Periodontal disease
 Oral Mucosal lesions
 Oral and pancreatic cancer
 Low birth weight
 CHD
 Addiction
 Extremely high levels of heavy metals may contribute
  to unknown systemic diseases
34
              Industry Intent on Use
   “RJRT designed Camel dissolvable tobacco products to
    complement its current product offerings for adult
    tobacco consumers who may have an interest in using,
    or switching to, new smokeless tobacco product.
(Source: RJRT Submission on Impact of Dissolvable Tobacco Use on Public Health to TPSAC, Food and Drug
   Administration, September 2010)

   RJR: Oral tobacco is an expansion of choice


   PM USA: Oral tobacco is an adjacency product
Snus Free Nicotine (mg/g)
6.00


5.00


4.00


3.00


2.00


1.00


0.00
       Taboka    Camel      Camel    Camel   Marlboro   Marlboro   Marlboro   Marlboro   Marlboro
                  Snus      Snus     Snus     Snus       Snus       Snus       Snus       Moist
                 Original   (OH)    (WVa)     Spice       Rich       Mild       Mint      Snuff
                (TX/OR)
35

          Use of Snus -Sweden-
   Has not reduced current occasional smoking
   Among adolescents reporting current use of oral snuff,
    71% also smoked (same as US)
   20% of male current smokers also used moist snuff
   Overall rate of cigarettes in Sweden is 25%
         higher than Canada, US or Australia
         has fallen by less over the last decade




Swedish Tobacco Control 2006. Progress & Challenges- both are greater than ever. Swedish Network for
    Tobacco Prevention
WHO IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Vol.89:Smokeless
    Tobacco and Some Tobacco-specific N-Nitrosamines. 2007. IARC Monographs Vol. 89. ISBN 978
    92 832 1289 8
36

              Oral Tobacco -Norway-
   Males 16-24
   Prevalence of daily or occasional snuff use
      1985: 9%
      2004/5: 33%
   Prevalence of daily smoking
        1983: 28%
        2001: 32%
   Increase in snuff not accompanied by less smoking

    WHO IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Vol.89:Smokeless Tobacco and
    Some Tobacco-specific N-Nitrosamines. 2007. IARC Monographs Vol. 89. ISBN 978 92 832 1289
37
        Percentage of US High School Students, by Sex, Who Reported
                 Current Smokeless Tobacco Use,* 1995-2009
              25                                Total         Male          Female

                      19.7
              20
                                 15.8
                                                         14.8                                    15
                                             14.2                                  13.6
              15                                                                          13.4
    Percent




                      11.4                                            11
                                  9.3                                                            8.9
              10                              7.8         8.2                       8     7.9
                                                                      6.7

               5
                      2.4                                 1.9         2.2          2.2    2.3    2.2
                                  1.5         1.3

               0
                     1995        1997        1999        2001        2003          2005   2007   2009
                                                        Year
Source: National Youth Risk Behavior Surveillance Surveys, 1995 – 2009
* Used chewing tobacco, snuff, or dip on  1 of the 30 days preceding the survey
Percentages of Cigarette Use among Past Month
                                                38
   Smokeless Tobacco Users, by Age Group:
           2002 to 2009 –USA-




  Source: SAMSHA, 2002-2009
  NSDUHs
40
    Dissolvables Health Effects


•Infant Child poisoning
•Youth Initiation
•CHD (Heavy Metal, Nicotine)
•Cancer (TSNAs, Heavy Metals, PAHs)
Using the “Smokeless” Argument to Invent
   New Nicotine Drug Delivery System




                    (.6 – 3.3 mg/unit)
Lethal Nicotine Poisoning                                            43


                    Dosages
                                         Toxicology
Estimated lethal pediatric dose of nicotine is 1.0 mg - 1.4 mg / kg body
weight
Average body weight of an infant one year old is 22.7 pounds, or 10.3 kg.*
Lethal dose for an infant one year old, of average body weight, is 10.3 – 14.4
mg.

Novel Dissolvable Tobacco Product                     Estimated Lethal Dose
Camel Orbs (1 mg nicotine per pellet)*                    10 – 15 pellets
Camel Sticks (3.1 mg nicotine per                           3 - 5 sticks
stick)*
Camel Strips (0.6 mg nicotine per                         17 – 24 strips
strip)*
*conservatively   high estimate
*   Per manufacturer’s promotional literature
FDA Tobacco Product Authority


-Standard setting for existing or substantially equivalent
tobacco products. Burden is on FDA to make a finding
with likely legal challenge (menthol)

-New tobacco products introduced after 2/15/2007 with
no substantially equivalent predicate tobacco product;
burden on industry to demonstrate

-Modified risk tobacco products that make a claim the
burden is on industry to show risk reduction
SLT: Population Impact
   Initiation: Graduation strategy to promote youth
    addiction and only male adolescents have shown
    a significant increase in use paritcularly flavored
    products
   Maintenance: Industry is actively promoting
    Snuss as a way to arrest the decline in cigarette
    sales through dual use
   There is science to support Swedisn Toxin level
    reduce risk
US Tobacco’s Dose-Controlled
                             “Graduation Strategy”
                                         COPENHAGEN



                                  SKOAL              SKOAL/KEY
                               WINTERGREEN            NATURAL
     GRADUATION PROCESS




                                                                       GRADUATION PROCESS
                             SKOAL    SKOAL    SKOAL    SKOAL
                            LONG CUT LONG CUT LONG CUT LONG CUT
                          WINTERGREEN  MINT     MINT   NATURAL

                             HAPPY DAYS MINT   HAPPY DAYS HAPPY DAYS
                                LONG CUT         SWEET     NATURAL
                                                LONG CUT   LONG CUT


                             SKOAL     SKOAL      SKOAL     SKOAL
                            BANDITS   BANDITS    BANDITS   BANDITS
                          WINTERGREEN   MINT      SWEET    NATURAL


Source: Marsee vs. UST. UST Document No. 12017104. Court Exhibit No. 100.
Dual Users are a Big Driver of
           Current MST Growth
   “Based on our research, we believe the bulk of
    smoker migration into MST is coming from dual
    users (consumers that dip and smoke). We
    estimate that about 30% of dippers also smoke.
    The proliferation of smoking bans has
    effectively increased the number of dipping
    occasions.
    Source: UBS Research, 2007, Nat’l Tobacco Incidence Study [UST]
TSNAs: Snus vs. Moist Snuff (ng/g)

18000
16000
14000
12000
10000
 8000
 6000
 4000
 2000
    0
        Taboka PM Camel Snus Marlboro  Marlboro  Marlboro   Marlboro   Marlboro   Marlboro   Marlboro    Marlboro
                    (Texas) SNUS Rich SNUS Mild SNUS Spice SNUS Mint   Fine Cut   Long Cut   Fine Cut    Long Cut
                                                                       Original    Original Wintergreen Wintergreen

 Mg/g
Olalekan Ayo-Yusuf, B.D.S., M.Sc., D.H.S.M   .
Facebook

    Does Baking Soda Give You a Buzz?
    “Baking Soda is basic and it opens up the pores in ur lip and
    gum allowing for more nicotine if u want a buzz tha’s an easy
    way.”

    Does one cut the webbing in their foot so you can
          still get the satisfaction during school?

   “All u gotta do is cut urself between your big and second toe,
    then pack it like u would ur lip, throw a sock on and u have
    descreet enjoyable dippin.”
The Bottom Line for Health or
Public Health Professionals

“To recommend use of a cancer causing, addictive product in lieu
of smoking while safe approved cessation medications exist raises
professional, ethical and liability questions and may violate the
oath to do no harm.”
Snus & NRT Annual Dollar Sales
                                      (2003-2007)
                    2003               2004               2005              2006               2007

   FDA-        $437,482,997       $444,561,898       $477,086,467      $496,640,220       $501,806,178
 Approved
   NRT
    Snus                    $0           $15,239           $14,300            $34,349            $32,773



Source: AC Nielsen ScanTrak, including sales in US food stores with at least $2 million in annual sales, US
   drug stores with at least $1 million in annual sales and all US mass merchandisers, with the exception of
                                                     WalMart.
FDA Authority

•Directive-Controls behavior of
manufacturing

•Gatekeepers-Defines debate, agenda while
keeping he gate closed

•Conceptual-Ability to shape concepts and
standards
FSTCPA Challenge
          Freezing Innovations?
   No new products should be allowed into the
    market unless they reduce public health impact .
    Exempt are Substantially Equivalent products
    with a predicate (like) product in market as of
    2/15/07.

   The key to is success is an FDA restrictive not
    permissive definition of substantially equivalent
    that can survive a legal challenge
Camel 1917   Camels 2010
Submissions to the FDA for Substantially Equivalent (SE),           33
New and Modified Risk Products (MRTPs)
(up to April 2011) (A Clear Definition of Dissolvables is Needed)
          Application                  4/11


         SUBSTANTIALLY
         EQUIVALENT
                                       3,661

         NEW
                                       0
         Products

         MRTP Products
                                       16




  Source: Food and Drug Administration, June 2011
Substantially Equivalent to What?
              -Section 905(j)




Predicate Product   or         Predicate Product
The Family Smoking Prevention and
               Tobacco Control Act


The states gave the federal government authority due to
the lack of state resources of expertise to regulate
tobacco products

Highly centralized, non-transparent rule making body

A body that must maintain strict neutrality as would a
court of law while subject to political realities of an
administrative agency

CAN WE WAIT FOUR MORE YEARS ????
Local Tobacco Control Must
      Remain as Locus of Tobacco
         Reduction in America
-The environment has changed and we must use our local authority
wisely and courageously and to set moral limits on the tobacco
market. Demand Federal and FDA accountability and involve our
federally elected officials to do so!

--Stick to our strengths! Level the playing field between cigarettes and
SLT: Taxes, Prohibiting public use of all tobacco products, local
public education, well funded program

Avoid issues of federal preemption in the FSTCPA and issues of
restricting speech
Like SHS We Need a New
     Effective Local Interventions
   Licensing of Retail Outlets (Constitutional)
   Limit the Number of Licenses as with Alcohol
   Limit Location (schools), Density as Retailers
    Close, Age of Entry(adults only) and Products
    Sold
    Products: No Flavored Products, Require Child
    Proof Packaging (2015), 18 years after
    enactment (2030) allow sale of non initiating
    prodcuts
“A Tiny Ripple of Hope”
   “Each Time a Man Stands up for and Ideal
     or acts to improve the lot of others or strike
    out at injustice, he sends forth a tiny ripple
    of hope, and crossing each other from
    a different centers of energy builds
    a current that can sweep down
    the mightiest”
Robert Kennedy 1986 South Africa
"They can crush a few flowers, but they cannot hold back the springtime."


Sister Pat Farrell, Leadership Conference of Women Religious August 2012

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Can we make tobacco history in our life time dr. greg connolly

  • 1. Can We Make Tobacco History in our Life Time? Gregory N. Connolly, D.M.D., M.P.H. Harvard School of Public Health November 29, 2012
  • 2. Disclosure I recently resigned my position at Harvard School of Public Health to become a Senior Scientific Advisor to a global consumer product manufacturer
  • 3. My decision was based on a growing realization that a free market that maximizes individual free choice with minimal government interference is best able to benefit society and reward those who contribute most.
  • 4. Just Ask the People What does Government Best?  Selling Power Ball Tickets?  Regulating the Market Place?  Reducing Poverty?
  • 5. Steve Jobs sold products: Style, High Tech and Utility It’s the Product Stupid Apple, 1984 Apple, 2012
  • 6. “Our company’s strategic priority is to develop, assess and commercialize products that can reduce the health risks of smoking on an individual and population basis. These are New Growth Products or “Safer Cigarettes”. These products have the potential to be the greatest innovation in the industry.”
  • 7. Our new growth products efforts are guided by the following key objectives: “Our first objective has been to develop a series of products that provide adult smokers the taste, sensory experience and smoking ritual characteristics that are as close as possible to those currently provided by conventional cigarettes.”
  • 8. Trends in Per Capita Consumption of Various Tobacco Products – United States, 1880-2004 and Linear Projection to 2035 16 Cigarettes Cigars Pipe/Roll your own Chewing Snuff 14 12 10 POUNDS 8 6 4 2 0 1880 1885 1890 1895 1900 1905 1910 1915 1920 1925 1930 1935 1940 1945 1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 YEAR Source: Giovino GA. Am J Prev Med 2007;33(6S):S318–S326.
  • 9. Source: PM Investor Day, June 21, 2012
  • 10. “We are very encouraged by the meeting (with the Center for Tobacco Products with the Food and Drug Administration) and although several details still need to be discussed, we remain comfortable with our current risk assessment approach.”
  • 11. Trends in Per Capita Consumption of Various Tobacco Products – United States, 1880-2004 and Extremely Undesirable Projection to 2060 16 Cigarettes Cigars Pipe/Roll your own Chewing Snuff 14 12 10 POUNDS 8 6 4 2 0 1880 1885 1890 1895 1900 1905 1910 1915 1920 1925 1930 1935 1940 1945 1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 YEAR Source: Giovino GA. Am J Prev Med 2007;33(6S):S318–S326.
  • 12. “We are opting for one or two Greenfield facilities in Europe” “…we envisage marketing our NGPs under our existing major trademarks such as Marlboro.” “…we expect the first factory to be ready in 2015 or 2016 final data from clinical studies during the beginning of 2016 and a launch in the first markets between 2016 and 2017.” However we still must respect fundamental choice of individuals to decide and let them choose and move the market to a safer one
  • 13. Until consumers accept an FDA approved Modified Risk Product like our NGPs we have as an interim Smokeless tobacco to let free choice move the market to a safer one  Some scientist who receive “independent” grants from us see a 95% reduction. The Swedish experience shows it can happened  We now have Verve!!
  • 14. Smokeless Tobacco as an Approved FDA Modified Risk Product  Data suggests Swedish Match has lower levels of lung cancer among males where use rates are high and smoking rates low  Standards exist for lowering toxins in Swedish Snuss far lower than its concentrations in moist snuff  Hard core inadvertent adult smokers who cannot quit should be given the choice for reducing harm  Continuum of risk exists among tobacco products with cigarettes highest, Moist Snuff middle and Snuss lowest.
  • 15.
  • 16.
  • 17. Our Response to Infant Poisoning 45 “For instance, in 2007 the total number of reported pediatric exposures for cosmetics was 172,541 compared with only 6,724 pediatric exposures for tobacco.” (Source: RJRT Submission on Impact of Dissolvable Tobacco Use on Public Health to TPSAC, Food and Drug Administration, September 2010) G.R. Krautter, & M.H. Abdelhameed, Clinical and Pharmacokinetic (PK) Characteristics of an Orally Ingested Tobacco Pellet (2007)
  • 18.
  • 19. VERVE: Our “Much” Safer New Nicotine Chewing Gum Verve is a nicotine chewing gum we are test marketing in Richmond with very low levels of toxins thus greatly reducing the risk of many smoking related diseases Although the amount and type of nicotine is a trade secret , we have provided our consumers with very strong warnings: “This product is addictive, can harm your baby if you are pregnant and can increase your risk to heat disease, aggravate diabetes, etc.” Verve has child proof packaging to prevent poisoning !!!!!
  • 20. WE Designed Verve “Voluntarily” to Make It the Package Safe from Child Poisoning  Let Me Show You
  • 21.
  • 22. You Can be Part of the Solution! You can help us! Together we can eliminate tobacco disease with NGPs and “safer” SMOKELESS Stop Fighting over Menthol and Give Freedom to the Black Smoker to Decide Provide funds to support research and attempts not to have cigarettes sold to children or help tobacco users quit Our power is too great not to accept this offer!
  • 23. Multinationals Profits vs National GDPs 25,000 $19,817 $19,870 20,000 Millions of Dollars 15,000 32 of the lowest income 4 TTTCs 10,000 nations 5,000 $3,890 Total Budget 0 Total GDP Profits WHO Budget Total GDP is inclusive of 32 nations: Tuvalu, Montserrat, Nauru, Kiribati, Marshall Islands, Anguilla, Sao Tome and Principe, Palau, Cook Islands, Micronesia (Federated States of), Tonga, Dominica, Comoros, Saint Kitts and Nevis, Samoa, Solomon Islands, United Republic of Tanzania: Zanzibar, Saint Vincent and the Grenadines, Vanuatu, Grenada, Timor-Leste, Guinea-Bissau, Liberia, Micronesia, British Virgin Islands, Seychelles, Gambia, Somalia, Antigua and Barbuda, Djibouti, Saint Lucia, and Turks and Caicos Islands.
  • 24. For Countries Who Are Not Ready For Safer Cigarettes  We are an international Company competing with the Japanese, British and now the CHINESE!!!!! Your best bet is America!!!  We need to make a profit for our Shareholders State Pension Funds, Colleges, Health Insurance Companies. All of You will be affected.  We sell the superior America Marlboro with more taste and pleasure and their Light!!!  They’ll smoke anyways why not ours???
  • 25. Female Smokers “The number of Indian female smokers eclipsed those of China by 2007, growing by 31% between 2006-2011.” The kinds of innovations in place to cater to this growing consumer base include super slims – longer, thinner cigarettes… often with a charcoal filter for a smoother smoke, and packaged in so-called “purse packs”…sometimes in colors…coordinate with outfits or mood.” Source: Euromonitor June 2012
  • 26. Filter and Menthol Innovation Role Filter Innovation Much of the “added value” NPD activity centers around the filter, as it is here that the flavour and any reduced chemical load or odour and enhanced product taste are manifest. Source: Euromonitor June 2012
  • 28.
  • 29. Our Response to FDA “ ’Our company is” opposed to regulations that are extreme in nature and are not evidenced based. These include plain packaging, health warnings covering most of the pack, display bans and bans on the use of all ingredients.” Remarks from our CEO
  • 30.
  • 31.
  • 32. Smokeless Tobacco Warning Labels in the US -Must cover 30% of the two principle sides of package -4 rotating warnings
  • 33. Federal Tax Rates on Tobacco Products (2009) Previous Tax SCHIP 2009 (New Tax) Tax Increase % Increase % of the Tax on a Cigarette Pack Cigarettes (20) $0.39/pack $1.01/pack $0.62/pack 158% 100% Small Cigars (20) $0.04/pack $1.01/pack $0.97/pack 2653% 100% RYO Tobacco (20) $0.04/pack $0.80/pack $0.76/pack 2159% 79.21% Snuff (1.2 oz.) $0.04/tin $0.11/tin $0.07/tin 158% 10.89% Chewing Tobacco (2.5 oz.) $0.03/pouch $0.08/pouch $0.05/pouch 158% 7.92% Source: United States Department of Treasury, Alcohol and Tobacco Tax and Trade Bureau. http://www.ttb.gov/main_pages/schip-summary.shtml - December 14, 2009 Note: 20 RYO Cigarettes = 14.5g of Tobacco (0.51 oz)
  • 34. Current Use of Flavored Smokeless by Users of Smokeless Tobacco Products - 2010 Maryland Public High School Youth 100% 90% 80% 68.9% 70% 61.1% 60% 50% 40% 30% 20% 10% 0% High School Middle School Source: Maryland Department of Health and Mental Hygiene, Youth Tobacco Survey – Fall 2010. Current smokeless tobacco use is any use of any smokeless tobacco product during the 30 days prior to the survey.
  • 35. 32 “The Government has proven that the Enterprise [Tobacco Industry] knowingly and intentionally engaged in a scheme to defraud smokers and potential smokers, for purposes of financial gain, by making false and fraudulent statements, representations, and promises.” United States District Court For the District of Columbia. United States of America et al, v. Philip Morris USA Inc., et al. Final Opinion: August 17, 2006. Civil Action No. 99-2496 (GK).
  • 36. But What Do You Tell the Kids!!  Read What the FDA Scientific Advisory Committee has to Say about US  We Would Like to Thank our Non Voting Members for their Collegial Scientific Input into Our Menthol Report!!!
  • 37. A Jeffersonian View of a Citizens Role in Governance A My typical day at work on tobacco control
  • 38. 31  Over the past few years, the cigarette industry has acquired the smokeless tobacco industry dramatically changing the incentives for product design and use; Combined use? Maintenance of smoking? Initiation?
  • 39. Smokeless Tobacco is a Very Serious Public Health Problem Smokeless Tobacco Causes  Periodontal disease  Oral Mucosal lesions  Oral and pancreatic cancer  Low birth weight  CHD  Addiction  Extremely high levels of heavy metals may contribute to unknown systemic diseases
  • 40. 34 Industry Intent on Use  “RJRT designed Camel dissolvable tobacco products to complement its current product offerings for adult tobacco consumers who may have an interest in using, or switching to, new smokeless tobacco product. (Source: RJRT Submission on Impact of Dissolvable Tobacco Use on Public Health to TPSAC, Food and Drug Administration, September 2010)  RJR: Oral tobacco is an expansion of choice  PM USA: Oral tobacco is an adjacency product
  • 41. Snus Free Nicotine (mg/g) 6.00 5.00 4.00 3.00 2.00 1.00 0.00 Taboka Camel Camel Camel Marlboro Marlboro Marlboro Marlboro Marlboro Snus Snus Snus Snus Snus Snus Snus Moist Original (OH) (WVa) Spice Rich Mild Mint Snuff (TX/OR)
  • 42. 35 Use of Snus -Sweden-  Has not reduced current occasional smoking  Among adolescents reporting current use of oral snuff, 71% also smoked (same as US)  20% of male current smokers also used moist snuff  Overall rate of cigarettes in Sweden is 25%  higher than Canada, US or Australia  has fallen by less over the last decade Swedish Tobacco Control 2006. Progress & Challenges- both are greater than ever. Swedish Network for Tobacco Prevention WHO IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Vol.89:Smokeless Tobacco and Some Tobacco-specific N-Nitrosamines. 2007. IARC Monographs Vol. 89. ISBN 978 92 832 1289 8
  • 43. 36 Oral Tobacco -Norway-  Males 16-24  Prevalence of daily or occasional snuff use  1985: 9%  2004/5: 33%  Prevalence of daily smoking  1983: 28%  2001: 32%  Increase in snuff not accompanied by less smoking WHO IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Vol.89:Smokeless Tobacco and Some Tobacco-specific N-Nitrosamines. 2007. IARC Monographs Vol. 89. ISBN 978 92 832 1289
  • 44. 37 Percentage of US High School Students, by Sex, Who Reported Current Smokeless Tobacco Use,* 1995-2009 25 Total Male Female 19.7 20 15.8 14.8 15 14.2 13.6 15 13.4 Percent 11.4 11 9.3 8.9 10 7.8 8.2 8 7.9 6.7 5 2.4 1.9 2.2 2.2 2.3 2.2 1.5 1.3 0 1995 1997 1999 2001 2003 2005 2007 2009 Year Source: National Youth Risk Behavior Surveillance Surveys, 1995 – 2009 * Used chewing tobacco, snuff, or dip on  1 of the 30 days preceding the survey
  • 45. Percentages of Cigarette Use among Past Month 38 Smokeless Tobacco Users, by Age Group: 2002 to 2009 –USA- Source: SAMSHA, 2002-2009 NSDUHs
  • 46. 40 Dissolvables Health Effects •Infant Child poisoning •Youth Initiation •CHD (Heavy Metal, Nicotine) •Cancer (TSNAs, Heavy Metals, PAHs)
  • 47. Using the “Smokeless” Argument to Invent New Nicotine Drug Delivery System (.6 – 3.3 mg/unit)
  • 48. Lethal Nicotine Poisoning 43 Dosages Toxicology Estimated lethal pediatric dose of nicotine is 1.0 mg - 1.4 mg / kg body weight Average body weight of an infant one year old is 22.7 pounds, or 10.3 kg.* Lethal dose for an infant one year old, of average body weight, is 10.3 – 14.4 mg. Novel Dissolvable Tobacco Product Estimated Lethal Dose Camel Orbs (1 mg nicotine per pellet)* 10 – 15 pellets Camel Sticks (3.1 mg nicotine per 3 - 5 sticks stick)* Camel Strips (0.6 mg nicotine per 17 – 24 strips strip)* *conservatively high estimate * Per manufacturer’s promotional literature
  • 49. FDA Tobacco Product Authority -Standard setting for existing or substantially equivalent tobacco products. Burden is on FDA to make a finding with likely legal challenge (menthol) -New tobacco products introduced after 2/15/2007 with no substantially equivalent predicate tobacco product; burden on industry to demonstrate -Modified risk tobacco products that make a claim the burden is on industry to show risk reduction
  • 50. SLT: Population Impact  Initiation: Graduation strategy to promote youth addiction and only male adolescents have shown a significant increase in use paritcularly flavored products  Maintenance: Industry is actively promoting Snuss as a way to arrest the decline in cigarette sales through dual use  There is science to support Swedisn Toxin level reduce risk
  • 51. US Tobacco’s Dose-Controlled “Graduation Strategy” COPENHAGEN SKOAL SKOAL/KEY WINTERGREEN NATURAL GRADUATION PROCESS GRADUATION PROCESS SKOAL SKOAL SKOAL SKOAL LONG CUT LONG CUT LONG CUT LONG CUT WINTERGREEN MINT MINT NATURAL HAPPY DAYS MINT HAPPY DAYS HAPPY DAYS LONG CUT SWEET NATURAL LONG CUT LONG CUT SKOAL SKOAL SKOAL SKOAL BANDITS BANDITS BANDITS BANDITS WINTERGREEN MINT SWEET NATURAL Source: Marsee vs. UST. UST Document No. 12017104. Court Exhibit No. 100.
  • 52.
  • 53. Dual Users are a Big Driver of Current MST Growth  “Based on our research, we believe the bulk of smoker migration into MST is coming from dual users (consumers that dip and smoke). We estimate that about 30% of dippers also smoke. The proliferation of smoking bans has effectively increased the number of dipping occasions. Source: UBS Research, 2007, Nat’l Tobacco Incidence Study [UST]
  • 54. TSNAs: Snus vs. Moist Snuff (ng/g) 18000 16000 14000 12000 10000 8000 6000 4000 2000 0 Taboka PM Camel Snus Marlboro Marlboro Marlboro Marlboro Marlboro Marlboro Marlboro Marlboro (Texas) SNUS Rich SNUS Mild SNUS Spice SNUS Mint Fine Cut Long Cut Fine Cut Long Cut Original Original Wintergreen Wintergreen Mg/g
  • 55. Olalekan Ayo-Yusuf, B.D.S., M.Sc., D.H.S.M .
  • 56.
  • 57. Facebook Does Baking Soda Give You a Buzz?  “Baking Soda is basic and it opens up the pores in ur lip and gum allowing for more nicotine if u want a buzz tha’s an easy way.” Does one cut the webbing in their foot so you can still get the satisfaction during school?  “All u gotta do is cut urself between your big and second toe, then pack it like u would ur lip, throw a sock on and u have descreet enjoyable dippin.”
  • 58. The Bottom Line for Health or Public Health Professionals “To recommend use of a cancer causing, addictive product in lieu of smoking while safe approved cessation medications exist raises professional, ethical and liability questions and may violate the oath to do no harm.”
  • 59. Snus & NRT Annual Dollar Sales (2003-2007) 2003 2004 2005 2006 2007 FDA- $437,482,997 $444,561,898 $477,086,467 $496,640,220 $501,806,178 Approved NRT Snus $0 $15,239 $14,300 $34,349 $32,773 Source: AC Nielsen ScanTrak, including sales in US food stores with at least $2 million in annual sales, US drug stores with at least $1 million in annual sales and all US mass merchandisers, with the exception of WalMart.
  • 60. FDA Authority •Directive-Controls behavior of manufacturing •Gatekeepers-Defines debate, agenda while keeping he gate closed •Conceptual-Ability to shape concepts and standards
  • 61. FSTCPA Challenge Freezing Innovations?  No new products should be allowed into the market unless they reduce public health impact . Exempt are Substantially Equivalent products with a predicate (like) product in market as of 2/15/07.  The key to is success is an FDA restrictive not permissive definition of substantially equivalent that can survive a legal challenge
  • 62. Camel 1917 Camels 2010
  • 63.
  • 64. Submissions to the FDA for Substantially Equivalent (SE), 33 New and Modified Risk Products (MRTPs) (up to April 2011) (A Clear Definition of Dissolvables is Needed) Application 4/11 SUBSTANTIALLY EQUIVALENT 3,661 NEW 0 Products MRTP Products 16 Source: Food and Drug Administration, June 2011
  • 65. Substantially Equivalent to What? -Section 905(j) Predicate Product or Predicate Product
  • 66. The Family Smoking Prevention and Tobacco Control Act The states gave the federal government authority due to the lack of state resources of expertise to regulate tobacco products Highly centralized, non-transparent rule making body A body that must maintain strict neutrality as would a court of law while subject to political realities of an administrative agency CAN WE WAIT FOUR MORE YEARS ????
  • 67.
  • 68. Local Tobacco Control Must Remain as Locus of Tobacco Reduction in America -The environment has changed and we must use our local authority wisely and courageously and to set moral limits on the tobacco market. Demand Federal and FDA accountability and involve our federally elected officials to do so! --Stick to our strengths! Level the playing field between cigarettes and SLT: Taxes, Prohibiting public use of all tobacco products, local public education, well funded program Avoid issues of federal preemption in the FSTCPA and issues of restricting speech
  • 69.
  • 70. Like SHS We Need a New Effective Local Interventions  Licensing of Retail Outlets (Constitutional)  Limit the Number of Licenses as with Alcohol  Limit Location (schools), Density as Retailers Close, Age of Entry(adults only) and Products Sold  Products: No Flavored Products, Require Child Proof Packaging (2015), 18 years after enactment (2030) allow sale of non initiating prodcuts
  • 71.
  • 72. “A Tiny Ripple of Hope” “Each Time a Man Stands up for and Ideal or acts to improve the lot of others or strike out at injustice, he sends forth a tiny ripple of hope, and crossing each other from a different centers of energy builds a current that can sweep down the mightiest” Robert Kennedy 1986 South Africa
  • 73. "They can crush a few flowers, but they cannot hold back the springtime." Sister Pat Farrell, Leadership Conference of Women Religious August 2012