FDA Flavors Comment

Download the original comment here.

June 19, 2018

Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852

To Whom It May Concern:

RE: Johns Hopkins Bloomberg School of Public Health Response to the United States
(U.S.) Department of Health and Human Services, Food and Drug Administration,
Docket No. FDA-2017-N-6565

The Institute for Global Tobacco Control (IGTC) at the Johns Hopkins Bloomberg School of Public Health appreciates the opportunity to provide comments in response to the Food and Drug Administration (FDA) public docket published in the Federal Register on March 21, 2018, requesting public comments on the role that flavors play in tobacco products. The public docket is seeking comments, data, research results, or other information about the role of flavors and how flavors attract youth to initiate tobacco product use, and about whether and how certain flavors may help adult cigarette smokers reduce cigarette use.

Research conducted at IGTC indicates that globally, flavored tobacco product availability, including menthol, is increasing. Efforts to ban all flavored cigarettes, including menthol, have been gaining momentum. Canadian provinces have already implemented bans on menthol tobacco products, and Canada will implement its own ban on menthol by the end of 2018, complementing an existing ban on all other flavored
cigarettes. Domestically, Chicago has implemented a partial menthol cigarette ban targeted around high schools. More recently, San Francisco voters approved a comprehensive flavored tobacco product ban. Our data show that tobacco manufacturers will use persuasive marketing and packaging to circumvent or exploit loopholes in policy requirements.

Thank you for this opportunity to share comments, published and unpublished research regarding flavored cigarettes and efforts to regulate these products globally. IGTC is Institute for Global Tobacco Control providing the following comments with the aim of informing the FDA on evidence-based measures to reduce cigarette use broadly, and among children specifically.

Sincerely,
Joshua M. Sharfstein, MD
Vice Dean for Public Health Practice and Community Engagement
Professor of the Practice
Department of Health Policy and Management
Johns Hopkins Bloomberg School of Public Health

Joanna E. Cohen, PhD, MHSc
Director, Institute for Global Tobacco Control
Bloomberg Professor of Disease Prevention
Department of Health, Behavior and Society
Johns Hopkins Bloomberg School of Public Health