Additionally, among rural high school male baseball players who had not used smokeless tobacco in the past 30-days, susceptibility to smokeless tobacco use was associated with perceiving a greater difference in lung cancer risk between cigarettes and smokeless tobacco (Table 2). Similar results were found for a group of urban and suburban California youth. Snus Smooth Mint Draft Guidance., 2012. Hecht SS, Stepanov I, Carmella SG.

Tob Regul Sci. 2008 Nov;10(11):1645-52.

Journal of Adolescent Health. 2.3.: Executive Summary, p. 43, 2.3-executive summary _Redacted.pdf.

Those participants who used smokeless tobacco, whether alone or in combination with other tobacco products, perceived a greater difference between cigarettes and smokeless. [51] Sung HY, Wang Y, Yao T, et al. Federal Register. https://doi.org/10.17226/13294. While the FDA indicates that “applicants may opt to use currently available models in the scientific literature to forecast the harm to public health from tobacco use,”. USSTC states is does not anticipate youth initiation rates for the candidate product to exceed rates currently observed for the ST category. This is something of great concern that USSTC didn’t take into account. In particular, there is reason to believe that potential consumers will misunderstand the concept of "switching completely."

PMID: 19106420. USSTC implies, without evidence, that the repeated exposure of an extended marketing campaign will lead to the desired harm reduction behavior among adult cigarette smokers but will not lead to expanded smokeless tobacco use among tobacco non-users and youth. Module 6: Summary of All Research Findings: 6.2.: Effect of Marketing on Consumer Understanding and Perceptions, Figure 6.2-7: General Harm Associated with the Candidate Product Pre-Post for Test and Control, p. 21, 6-2-risk-perceptions_Release in Full.pdf. Figure 1. [44] Altria Client Services LLC. Xtra Long Cut Wintergreen Modified Risk Tobacco Product Applications. [19] Song, AV, Morrell, HE, Cornell, JL, Ramos, ME., Biehl, M., Kropp, RY., Halpern-Felsher. USSTC has notified the U.S. Food and Drug Administration of the recall and is working with federal authorities on this matter.

(page 10). 2016 May, 58(5):5558-66. The language used in these claims must be tested thoroughly among the entire population for salience, credibility, readability, and accuracy of consumers' interpretations. 2007 Dec;9(12):1331-7. Importantly, USSTC’s proposed claims introduce language ("switching completely” and “reduces risk") that is unlikely to be familiar to adolescents and youth. The MRTPA indicates that they will “provide justification for our population of interest (i.e. 2015;15(1):258. In summary, the ALCS Cohort Model follows recommended approaches for model development but leaves out some important components and uses questionable input values and assumptions.

Smokers who report smoking but do not consider themselves smokers: a phenomenon in need of further attention.

If this unproven marketing campaign is approved and the result is greater smokeless tobacco use but without harm reduction, the only remedy USSTC suggest is “post market surveillance” (void of any details on how such surveillance would be conducted). 2003 Aug;5(4):561-9. Tob Regul Sci. Pouches Wintergreen (overseas military only). Adolescents’ Perceptions of Health Risks, Social Risks, and Benefits Differ across Tobacco Products. All rights reserved (About Us). JAMA Pediatr. Cigarette and Smokeless Tobacco Perception Differences of Rural Male Youth.

Roditis, M., Delucchi, K., Cash, D., & Halpern-Felsher, BL. As seen during the current “epidemic” of youth e-cigarette use, potential ex post facto solutions are severely limited. Evidence that smokeless tobacco use is a gateway for smoking initiation in young adult males.

[45] Caro JJ, Briggs AH, Siegert U, et al. Know the real cost of tobacco. Long Cut (overseas military only) U.S. Smokeless Tobacco Company - maker of popular brands such as Copenhagen, Husky and Skoal - has recalled multiple varieties of its products over concerns they could contain metal shards. Long Cut Berry Tobacco Blend Preventive Medicine. Perceived risks and benefits of smoking: Differences between adolescents with different smoking experiences and intentions. Fine Cut Wintergreen (overseas military only) In a study of male baseball athletes at rural high schools in California, cigarettes and smokeless tobacco were perceived to convey different probabilities of risk: participants generally viewed use of both cigarettes and smokeless tobacco as carrying a great risk of oral health problems and great risk of getting into "trouble" (facing discipline) from parents or at school, but smokeless tobacco was viewed, on average, as having less risk of systemic ailments. The FDA should not allow USSTC to make this modified risk claim without a more thorough analysis of the impact on non-smokers and the potential for an increased burden of tobacco-related diseases across all groups, but especially youth and young adults.

USSTC’s sales representatives will assist wholesalers and retailers in returning the product. 2.3.: Executive Summary, p. 42, 2.3-executive summary _Redacted.pdf, [11] USSTC MRTP Application for Copenhagen Snuff Fine Cut. [27] The opposite argument is more plausible: as adolescents have grown to perceive smokeless tobacco as a more palatable alternative to cigarettes in terms of health risks, smokeless tobacco use has grown more resistant to the public health gains achieved in reducing youth smoking. Roditis, M., Delucchi, K., Cash, D., & Halpern-Felsher, BL. USSTC MRTP Application for Copenhagen Snuff Fine Cut. 2009 Mar; 99(3):487-92. (p. 21-22), [49] Wang Y, Sung H, Yao T, et al.

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