On Halloween, Dr. John Armstrong, Florida Surgeon General and Secretary of Health, launched an attack on flavored tobacco, ostensibly to protect children (I expressed concern three years ago about the crusade against tobacco flavors, here and here). As I note in the attached letter, “the availability of flavored tobacco products is important for tobacco harm reduction among adults who smoke…” because “…these individuals [should] have access to appealing, vastly safer smoke-free alternatives to cigarettes.” Furthermore, contrary to Dr. Armstrong’s claim, there is no evidence that tobacco flavoring is aimed at targeting youth. The full text of my letter follows:
November 12, 2012
John H. Armstrong, MD, FACS
Surgeon General and Secretary of Health
State of Florida
Dear Dr. Armstrong,
I am a professor of medicine and hold an endowed chair in tobacco harm reduction research at the University of Louisville. I read with interest an article in the St. Pete Patch entitled “Candy Flavored Tobacco: Trick or Treat” (here), which provided the following quote from you:
“Youth have always been a target for the tobacco industry, and our Department will not sit by and watch. Companies perceive youth as an easy target, and develop products like flavored tobacco and marketing campaigns aimed at them.”
The 1998 Master Settlement Agreement (MSA) between the four largest American tobacco manufacturers and the attorneys general of 46 states (here) expressly prohibited the egregious actions you describe occurring in Florida. Section IIIa of this agreement, titled “Prohibition on Youth Targeting”, specifies that “No participating Manufacturer may take any action, directly or indirectly, to target Youth within any Settling State in the advertising, promotion or marketing of Tobacco Products…”
As you know, the state of Florida was not a party to the MSA. Instead, Florida entered into an individual agreement with tobacco manufacturers (here) that appears not to have youth targeting and marketing prohibitions. However, I believe that tobacco manufacturers have a moral obligation to follow the spirit of the MSA in Florida.
I reviewed the Tobacco Free Florida website on candy-flavored tobacco (here), which claims that flavors include “berry, vanilla, chocolate and green apple, orange, cherry and coffee” and that tobacco products are presented in “colorful and playful packaging.” I do not believe that this constitutes evidence that manufacturers are “directly or indirectly” targeting youth.
The availability of flavored tobacco products is important for tobacco harm reduction among adults who smoke. From a public health standpoint, it is important that these individuals have access to appealing, vastly safer smoke-free alternatives to cigarettes. The flavors highlighted by Tobacco Free Florida have no special appeal to youth, so there is no reason they should not be used in adult tobacco products. Banning tobacco flavoring is no more logical than banning flavored beer, wine and mixed drinks on the grounds that those products appeal to youth.
As a state official, you have made specific allegations that tobacco manufacturers are targeting youth and have “marketing campaigns aimed at them.” The mere use of flavoring in tobacco products does not warrant such a claim.
I share your interest in preventing initiation of tobacco use by youth, and would appreciate your sharing with me any specific evidence of unlawful tobacco marketing to this protected class.
Endowed Chair, Tobacco Harm Reduction Research
School of Medicine
University of Louisville