Why U.S. Smokeless Tobacco Company Is Asking the FTC for Advertising Guidance Regarding Cross-Category Comparative Risk Statements
U.S. Smokeless Tobacco Company, a subsidiary of UST, on February 5, 2002, asked the Federal Trade Commission (FTC) for an advisory opinion regarding the acceptability of communicating in advertising to adult smokers that smokeless tobacco products are considered to be a significantly reduced risk alternative as compared to cigarette smoking. Under federal law, the FTC has jurisdiction over tobacco product advertising.
Until recently, public health strategies regarding tobacco use have focused primarily on prevention and cessation. However, there is considerable agreement among researchers that use of smokeless tobacco involves significantly less risk of adverse health effects than cigarette smoking, and there is growing support in the public health community that cigarette smokers who do not quit or use medicinal nicotine should be encouraged to switch to smokeless tobacco. Such a harm reduction strategy is being debated in the public health community as representing a pragmatic component of a comprehensive public health policy on cigarette smoking.
We believe that cross-category (that is, smokeless tobacco advertisements directed at adult smokers) comparative risk statements in advertising, if substantiated and properly qualified, will help to educate current adult cigarette smokers and assist them in making informed choices about the tobacco products they use. We further believe that the current regulatory environment for some tobacco advertising is unclear, especially in light of advertising for new "modified" cigarettes and efforts by tobacco control advocates to engage the Food and Drug Administration in regulatory activity.
To better inform the decision-making process and public understanding, we encourage the FTC to arrange a workshop or seminar to facilitate discussion of tobacco harm reduction strategies and the appropriateness of cross-category comparative risk statements in advertising for tobacco products. Participating in the workshop should be medical and public health researchers, public interest and advocacy groups, tobacco manufacturers, and representatives from federal and state agencies.
The complete text of our request to the FTC for an advisory opinion. 
