To: U.S. Food and Drug Administration
From: Carl V Phillips, PhD
Chief Scientific Officer
The Consumer Advocates for Smoke-free Alternatives Association (CASAA)
25 November 2014
Comment Tracking Number: 1jy-8fp5-yhfe
Re: CASAA comments on Swedish Match MRTP application
(Docket No. FDA-2014-N-1051)
This comment on Docket No. FDA-2014-N-1051, Swedish Match’s (SM’s) Modified Risk Tobacco Product (MRTP) application is submitted on behalf of The Consumer Advocates for Smoke-free Alternatives Association (CASAA). CASAA is a public health and education NGO. It is a 501(c)4 nonprofit membership organization that serves as the leading representative of consumers who use or might in the future use smoke-free tobacco/nicotine products. CASAA is not an industry group and does not represent the interests of industry. CASAA did not confer with Swedish Match or other industry representatives when creating this comment.
First, we wish to note that we heartily endorse the acceptance of SM’s application. It would benefit the public, who FDA and the rest of our government are charged with operating on behalf of, particularly by improving the public’s overall health. It would reduce a persistent problem of the government grossly misrepresenting risks to the public about this category of products. We can see no apparent downside for consumers or society as a whole in FDA granting SM’s application. The only apparent downsides are for two special interest groups: those who wish to keep consumers smoking because they have a financial interest in cigarette sales, or those who are pursuing tobacco prohibition and know that those goals will be unattainable if consumers have accurate information about low-risk products.
There is little chance we could add any research material to SM’s encyclopedic application, and so we will not attempt to do so. Instead we will highlight some key summary points and address some public-interest and ethical issues that fall outside of what SM emphasized in their application.