I’m offended at the terminology used when you mentioned banning menthol flavorings and what this would create.

- In public comments http://www.regulations.gov urge the FDA to truthfully inform tobacco consumers and the public about the vastly different comparable risks of different tobacco/nicotine products.

- Routinely inform media/public via noncommercial speech (press releases, op/eds, LTEs, media interviews, public testimony, litigation) that smokefree tobacco products are less hazardous alternatives to cigarettes.

- Target market smokefree tobacco products to smokers as cigarette substitutes.

- Aggressively defend smokefree tobacco products (including flavored brands) from unsubstantiated charges that they are target marketed to youth.

- In litigation challenging provisions of FDA statute for violating 1st amendment, emphasize that smokers have a human right to be informed smokefree tobacco products are less hazardous alternatives to cigarettes, that tobacco companies (and the FDA) have an ethical duty to inform smokers of this fact, and that the FDA statute violates the 1st amendment by prohibiting tobacco companies from truthfully informing smokers.

- Develop/introduce new smokefree tobacco brands and inform the FDA they are “substantially equivalent” to other similar smokefree tobacco products that were on the market before February, 2007.

- Submit applications to the FDA to make “modified risk” claims stating that a smokefree tobacco brand is a less hazardous alternative to cigarettes (and/or to cigarette brands).

- Submit applications to the FDA to make “modified risk” claims stating that pasteurized snus is not associated with oral cancer, unlike fermented smokefree tobacco products.

- Submit applications to the FDA to make “reduced exposure” claims stating that snus or other low nitrosamine tobacco products emit fewer carcinogens than chewing tobacco or moist snuff.

- Do NOT submit applications to the FDA to make “modified risk” or “reduced exposure” claims stating that a cigarette brand is less hazardous or contains fewer smoke constituents than other cigarettes (and/or other cigarette brands).

- truthfully inform smokers and the public that smokefree tobacco/nicotine products are less hazardous alternatives to cigarettes,

- eliminate the misleading “This product is not a safe alternative to cigarettes” warning on smokeless products,

- eliminate the unsubstantiated “This product may cause mouth cancer” warning from snus and other low nitrosamine smokeless products (as there is no scientific evidence these products cause mouth cancer),

- require a warning on all cigarette packs stating “Smokefree tobacco and nicotine products are less hazardous alternatives to cigarettes”,

- evaluate and publish the relative and comparable health risks of different tobacco/nicotine products,

- establish stricter standards for “modified risk” and “reduced exposure” claims for cigarettes than for smokefree tobacco products,

- require a warning on all cigarette packs stating “There is no such thing as a safer cigarette; all cigarettes are similarly hazardous”,

- not propose/approve cigarette emission standards for nicotine/tars/CO etc.,

- not propose/approve banning menthol cigarettes as it would create black market for untaxed menthol cigarettes,

- not propose/approve banning or restricting flavorings/additives in cigars or smokefree tobacco products,

- redefine e-cigarettes as a new category of smokefree tobacco products and develop reasonable product regulations,

- approve NY Health Cmsnr’s petition to make NRT products (i.e. gums, lozenges, patches, inhalers) more accessible (i.e. allow sales of $5-$10 daily dose packages, and in all stores that sell cigarettes), and to change mandatory warnings to state that NRT is less hazardous alternative to cigarettes and can be used concurrently with tobacco products (the current warnings are scarier than cigarette warnings and say not to use if tobacco is also being used),

- approve temporary and long term use of NRT products (FDA currently approves NRT only to be used for 10-12 weeks and only for tobacco cessation),

- inform smokers and the public that cold turkey is the most effective smoking cessation method (not NRT products, which have a 93% failure rate after 6 months and a 98% failure rate after 20 months),

- stop deceiving the public and misrepresenting scientific evidence (e.g. tobacco flavorings/additives, marketing to youth, e-cigarettes, NRT success rates for smoking cessation).

Much of the harm reduction dialogue and development effort has migrated to smokeless tobacco products while smokers get almost no attention.

Keep up the good work guys.