December 30, 2020
National Center for Health Research’s Comments Regarding Modified Risk Tobacco Product Application for Camel Snus
We are writing to express our views on the modified risk tobacco product (MRTP) application for six Camel Snus smokeless tobacco products. The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research, policies, and programs on a range of issues related to health and safety. We do not accept funding from companies that make products that are the subject of our work.
We strongly oppose the approval of this modified risk application for six Camel Snus smokeless tobacco products, submitted by R.J. Reynolds Tobacco Company. The FDA requires that modified risk tobacco products must demonstrate that they significantly reduce harm to smokers, as well as promote public health. In addition to the lack of scientifically valid evidence to claim that Camel Snus smokeless tobacco products meet these criteria, there are clear reasons to assume these nicotine-containing products have risks for public health, because they may be appealing to non-smokers, particularly adolescents.
To declare these products as “modified risk” is likely to increase the number of dual users, as well as increase the number of non-smokers using tobacco products after getting addicted to nicotine from smokeless tobacco. CDC statistics indicate that vaping is dangerously common among youth; approximately 20% of high school students have vaped in the last 30 days.1 One of the reasons why vaping is so common among high schoolers is that many believe that it is safe and harmless.2 Currently, about 3% of highschoolers use smokeless tobacco,1 and if Camel Snus are declared to be a MRTP, there is a risk of increased use of these products, due to perceptions of safety as well as the appeal of flavored products. Often, when people hear that a product is “safer,” they misinterpret this to mean that the product is “safe.” However, the use of smokeless tobacco products is definitely not safe, since it increases the risks of cancers, such as oral, esophageal, and pancreatic cancer, as well as other diseases.
- Centers for Disease Control and Prevention. Youth and Tobacco Use. Cdc.gov. https://www.cdc.gov/tobacco/data_statistics/fact_sheets/youth_data/tobacco_use/index.htm. Updated December 2020.
- Guthrie G. Is Vaping Safe? 1 in 5 Young Americans Think So. Cancer.net. https://www.cancer.net/blog/2019-10/vaping-safe-1-5-young-americans-think-so. October 2019.