Thursday, January 11, 2018

Trials and Tribulations of Reduced Risk Tobacco Products



When Congress gave the FDA regulatory authority over tobacco in 2009, it provided a pathway for companies to obtain approval for “modified risk tobacco products (MRTPs)…, sold or distributed for use to reduce harm or the risk of tobacco-related disease…” (here).  While decades of epidemiologic studies prove that non-combustible tobacco products are vastly safer than those involving inhaled smoke laced with thousands of toxins, the legislation required proof from manufacturers that MRTPs must “benefit the health of the population as a whole taking into account both users of tobacco products and persons who do not currently use tobacco products.” (here)  In other words, MRTPs must benefit the 60 million Americans who smoke as well as 250 million American non-smokers.

Despite this challenge, tobacco manufacturers have made credible efforts to seek MRTP status.  Swedish Match in 2014 started down this pathway (here) to remedy inaccurate warning labels that are required on their smokeless tobacco products and marketing materials (here).  The FDA denied the company’s application in 2016 (here).

In November of that year, Philip Morris International (PMI) requested MRTP status for its IQOS heat-not-burn tobacco (here).  IQOS is already available in 31 other countries.  However, since it is an entirely new product, the company must also pursue an FDA premarket tobacco application (PMTA) before it can be sold in the U.S.

PMI seeks MRTP approval for any one of three messages:

“Switching completely from cigarettes to the IQOS system can reduce the risks of tobacco-related diseases.”

“Switching completely to IQOS presents less risk of harm than continuing to smoke cigarettes.”

“Switching completely from cigarettes to the IQOS system significantly reduces your body’s exposure to harmful and potentially harmful chemicals.”

Another manufacturer, R.J. Reynolds, filed an MRTP application in March 2017 for its Camel Snus products (here).  They, too, submitted three messages, this being the most comprehensive: “Smokers who switch completely from cigarettes to Camel Snus can significantly reduce their risk of lung cancer, oral cancer, respiratory disease, and heart disease.”

Despite a wealth of evidence to support such statements, FDA took two and a half years to reject the Swedish Match MRTP application (here), as can be seen in the following table.


Key Dates for General Snus, IQOS and Camel Snus MRTP Applications




EventGeneral Snus (Swedish Match)IQOS (PMI)Camel Snus (R.J. Reynolds)




Submission DateJune 6, 2014November 18, 2016March 31, 2017
Time to next step2 months6 months9 months
FDA AcceptanceAugust 27, 2014May 24, 2017December 18, 2017
Time to next step8 months8 months---
TPSAC MeetingApril 8, 2015January 24, 2018---
Time to next step20 months------
FDA DecisionDecember 14, 2016------

In the 30 months it took the FDA to analyze and reject the first MRTP application, 1.2 million Americans died from smoking.  The agency must move faster in its evaluation of obviously lower-risk smoke-free tobacco products and give them MRTP status.


Wednesday, January 3, 2018

Tobacco Gateway Report Omits Important Information



Here we go again.  Another federally funded study from the University of California, San Francisco, claims that “Nonsmoking adolescents who use e-cigarettes, smokeless tobacco or tobacco water pipes are more likely to start smoking conventional cigarettes within a year.” (UCSF press release here)  Researchers analyzed data on some 10,400 teens enrolled in the Population Assessment of Tobacco and Health (PATH) Survey in 2013-2014, then followed up with the subjects one year later.

“We found that teens who experimented with tobacco in any form were at greater risk of future smoking,” said senior author Dr. Benjamin W. Chaffee; his study appears in JAMA Pediatrics.

The researchers report that teens who had ever used e-cigarettes, hookah, other combustible products or smokeless tobacco at the baseline survey were two or three times as likely to be smoking cigarettes (in the past-30 days) one year later than those who had not tried any tobacco product.  Those who had tried two or more products were 3.8 times more likely to be smoking.

The authors used a sophisticated analysis to arrive at these results, but news stories describing this as evidence of a gateway to teen smoking (examples here and here) are inaccurate.

Chaffee and his colleagues, including anti-tobacco crusader Stanton Glantz, omitted information that is critical to putting their findings in perspective.  Although teens trying other tobacco products were more likely to smoke, the majority of new smokers after one year came from the group that had not tried tobacco at baseline.  I offer the following calculations based on obscure information in the published article.

Odds Ratios (ORs) And Numbers of Teens Smoking Cigarettes After One Year, According to Ever Tobacco Status at Baseline
Ever Tobacco Status- Baseline (n)OR (95% Confidence Interval)Number Smoking At One Year (%)



Never tobacco use (9,058)Referent175 (79.9)
E-cigarettes (255)2.1211 (5.0)
Hookah (189)2.158 (3.7)
Other combustible (114)3.087 (3.2)
Smokeless tobacco (93)1.533 (1.4)
Two or more products (200)3.8115 (6.8)



All (9,909)
219 (100)




After one year, 219 teens had smoked a cigarette in the past 30 days, and 175 of those (80%) had never used any tobacco product at baseline.  Even though the odds of smoking were higher among youth who had tried other products, the number of smokers contributed by each of these groups was minuscule.  (While actual survey numbers may vary slightly, the relative contributions of the groups will not change.)

The Chaffee article emphasizes odds ratios but omits or obscures important contextual information.  While teens who try one tobacco product are more likely to try another, the dominant gateway in the PATH survey was from no previous tobacco use to cigarettes.

No underage tobacco initiation is acceptable; neither is misdirection by researchers.


Wednesday, December 27, 2017

Tobacco Truth Top Ten



During the holidays we celebrate this blog’s eight years of factual reporting and critical analysis of science and policy surrounding tobacco and tobacco harm reduction.  We’ve strived to satisfy the curiosity and technical interests of health professionals, while couching our message in terms that are comprehensible to the lay consumer as well.  We are proud to note that Tobacco Truth has some 450 posts, with over 2.8 million pageviews.  We sincerely hope this translates into a significant number of lives extended and improved.

Based on pageviews, here are the Top Ten Tobacco Truths, with notable quotes from each.

    I’m a Smokeless Tobacco User – Will I Get Mouth Cancer?  2012  “Harm reduction doesn’t allow us to enjoy risk-free lives. It does give us valuable information to manage the risks of the activities that make life enjoyable.”

    Nicotine Levels in American Smokeless Tobacco Products  2012  “The broad range of free nicotine levels among these products is good news for smokers.  They should look for a smokeless substitute that satisfies them.”

    The Proven Positive Effects of Nicotine and Tobacco  2010  “It’s time to be honest with the 50 million Americans, and hundreds of millions around the world, who use tobacco. The benefits they get from tobacco are very real, not imaginary or just the periodic elimination of withdrawal. It’s time to abandon the myth that tobacco is devoid of benefits, and to focus on how we can help smokers continue to derive those benefits with a safer delivery system.”

    Tobacco Trick or Treat by Florida’s Surgeon General  2012  “The availability of flavored tobacco products is important for tobacco harm reduction among adults who smoke…it is important that these individuals have access to appealing, vastly safer smoke-free alternatives to cigarettes…Banning tobacco flavoring is no more logical than banning flavored beer, wine and mixed drinks on the grounds that those products appeal to youth.”

    More Evidence That Smokeless Tobacco Products in the U.S. Have Low TSNA Levels  2012  “this study shows that TSNAs are present in tiny concentrations.  As discussed in a previous post (here), there is virtually no evidence that current TSNA levels are associated with any measurable cancer risks.”

    Nebraska Legislature Passes Tobacco Harm Reduction Resolution  2012  “The Nebraska legislature on March 27 [2012] passed resolution LR 499 to ‘recognize the importance of tobacco harm reduction strategies as an additional choice to assist cigarette smokers in quitting.’ ”

    The Health Risks of Cigar Smoking  2012  “Cigars, the data show, have few health effects when used in moderation.”  Also see this popular post in 2016.

     Regulatory Purgatory: Tobacco Harm Reduction at Risk  2012  “The FDA should abandon regulatory fundamentalism that condemns safer product development to a purgatory of red tape.”

     Cancer Risks From Smokeless Tobacco Use: Next To Nil  2009  “The clear implication is that the deaths each year of 103,635 male smokers in the U.S. could be avoided if public health leaders shared the truth about safer smokeless tobacco, and if tobacco manufacturers were allowed and encouraged to urge smokers to switch.”

    E-Cigarettes – No Toxic Effects from Inhaled Propylene Glycol Aerosol  2011  “First, even high concentrations of PG vapor don’t have any measurable harmful effects, which is fully consistent with its designation by the FDA as “generally recognized as safe” as a food additive for all food categories up to 2% (here). Just as important, there will be no impact on bystanders from “second-hand” exposure to e-cigarette vapor, if it occurs at all.”

The following posts from the past year have been very popular as well.

E-Cigarette Toxic Chemical Exposure Is Same as for Nonsmokers  “The fact that vapers’ [volatile organic compound] exposures are similar to those of nonsmokers is headline-worthy.”

Federal Studies: ZERO Mouth Cancer Deaths Among Men Who Dip or Chew Tobacco  “The U.S. Food & Drug Administration (FDA) on January 23, 2017 published a proposed smokeless tobacco (ST) regulation that is based on erroneous calculations of ST risks.”

FDA Tobacco Director Ignores 2.5 Million “Anecdotal Reports” About E-Cigarettes  “The FDA’s refusal to acknowledge population data on e-cigarettes facilitates its effort to impose industry-killing regulations on the vapor market.  The chief federal regulator of tobacco products should acknowledge government survey data showing that e-cigarettes have helped as many as 2.5 million Americans quit smoking and/or stay smoke-free.”

We approach the new year with a renewed commitment to elevate global public discourse on the science of tobacco harm reduction.