by Barbara McCullough-Jones.
Q Center is pleased to share this important letter with you from one of our community’s strongest allies, Commissioner Loretta Smith. Commissioner Smith believes, as we do, breaking barriers to good health is a responsibility we share as a community, as organizations and as individuals. The mission of Q Center’s Health and Wellness program area is to enhance the quality of life for LGBTQ people and our allies by supporting a holistic approach to mental, physical, emotional and spiritual well-being. We believe strong healthy LGBTQ individuals and communities will make a greater contribution to the world. We hope you find the content here of value to more fully understand how the LGBTQ communities and communities of color are strategically targeted to sell these types of products. Please join in our campaign to build a healthy future for all Oregonians.
November 21, 2013
In Regards: Menthol in Cigarettes, Tobacco Products; Request for Comments
To the U.S. Food and Drug Administration:
Serving as a Commissioner for Multnomah County, Oregon’s most populous county, I wanted to take this very important opportunity to comment on menthol tobacco products. As a woman of color in a leadership role, I have the responsibility for, and am dedicated to, reducing tobacco-related disparities in my community. For the compelling reasons below, I strongly urge the U.S. Food and Drug Administration to exercise its regulatory power to protect America’s health by prohibiting menthol in cigarettes AND other tobacco products.
Menthol is a “starter” product.
The addition of menthol makes cigarette smoke “smooth” and easier to inhale, covering up the harshness of tobacco, which makes menthol cigarettes especially popular among young and beginner smokers. Review of tobacco industry documents shows that the industry studied smokers’ menthol preferences and manipulated the menthol levels to appeal to a variety of smokers, including adolescents and young adults . Additionally, marketing at the retail level shows significant targeting of youth and communities of color. For example, menthol cigarettes are more likely to be marketed in stores near schools with higher proportions of African American students . Data exemplifies the popularity of menthols with youth. For example, the youngest age groups smoke the most menthol cigarettes, and more than half (51.7%) of recent initiates (those who had smoked a cigarette for the first time in the 12 months before the survey interview) from 2007 to 2010 smoked menthol cigarettes in the past month . Additionally, more than 80% of African American youth who smoke and more than half of Latino youth who smoke use menthol cigarettes, and more than half of Asian American middle-school youth who smoke use menthol cigarettes . Brand preference is also a sign of heavy marketing, and among adolescents who are current smokers, 21.8% of the 10 most commonly preferred brands are sub brands of Newport, a menthol brand . Additionally, 59.3% of African American adolescents who are current smokers preferred Newport .
Menthol was excluded from the national ban on flavored cigarettes.
Given the persistent disparities in the use of and health impacts of specific tobacco products, it was disappointing that menthol was excluded from the national ban on flavored cigarettes. The Family Smoking Prevention and Tobacco Control Act of 2009 included a ban on flavored cigarettes including strawberry, grape, orange, clove, cinnamon, pineapple, vanilla, coconut, licorice, cocoa, chocolate, cherry, and coffee flavored cigarettes, but did not include menthol . This ban was included in the Family Smoking Prevention and Tobacco Control Act specifically because these products are especially attractive to youth and are widely considered “starter products.” Given the evidence that menthol cigarettes are a flavored tobacco product that appeals to youth and makes it easy for youth to smoke harsh tobacco and become addicted, menthol should be included in the flavor ban per the same reasoning. Having menthol exempt from the flavor ban was actually to the benefit of the tobacco industry – the flavored cigarettes included in the ban represented less than 1% of market, but menthol cigarettes represent more than a quarter of all cigarettes sold .
The fact that menthol was not included in the list of banned flavorings prompted seven former Secretaries of Health, including Drs. Joseph Califano and Louis Sullivan, and a former Surgeon General to write a joint letter with the National African American Tobacco Prevention Network in opposition to the exclusion of menthol from the list of banned flavors . A survey conducted by Schroeder Institute for Tobacco Research and Policy Studies at Legacy found that nearly 40% of menthol smokers would quit smoking if menthols were banned, which could mean up to the elimination of 600,000 smoking-related premature deaths by 2050, a third of those among African Americans . In March of 2012, Brazil passed a resolution that banned the import or sale of tobacco products with additives including menthol , providing a model for other countries.
Targeted marketing of menthol cigarettes works.
Tobacco industry documents and insider testimonials show that the tobacco companies have specifically marketed menthol cigarettes to low income communities of color , , . For example, one study found that magazines read predominately by African Americans were 9.8 times more likely than magazines read predominately by Whites to contain ads for menthol cigarettes and magazines read predominately by Latinos were 2.6 times more likely than magazines read predominately by Whites to contain ads for menthol cigarettes . Another study found that low-income, minority communities have more tobacco retailers and advertisements are more likely to be larger and promote menthol products . This finding is supported by La Tanisha Wright, a former tobacco company manager. She describes how retailers in the “focus” communities (described as communities with high economic insecurity and/or risk of poverty, with unemployed, poorly paid full- or part-time positions, lower education, and uninsured or medically underserved) have high menthol brand placement, receive higher discounts on mentholated products, and receive a greater quantity of promotions more often than in “non-focus” communities (described as communities with economic security, full time or salaried positions, at least some college education, and insured with access to medical services ).
There is clear evidence that the targeted industry marketing works. The prevalence of menthol cigarette use is highest among African Americans across all socio-demographic and smoking-related categories, whether stratified by income, age, gender, marital status, region, education, age of initiation or length of time smoking . Combined 2004-2008 data shows that 82.6% of African American, 53.2% of Native Hawaiian/ Pacific Islander, 32.3% of Hispanic/Latino, 31.2% of Asian, 24.8% of American Indian/Alaska Native and 23.8% of White smokers aged 12 years and older reported using menthol cigarettes in the past month . National data also shows that menthol cigarette use is high among the unemployed and people with an annual income of less than $10,000 . Additionally, a national study found that 71% of lesbian, gay, bisexual and transgender young adults (18-25 years) who smoke reported smoking menthol cigarettes .
I strongly urge the U.S. Food and Drug Administration to exercise its regulatory power to protect America’s healthy by prohibiting menthol in cigarettes AND other tobacco products. As mentioned earlier, menthol tobacco products pose an especially dangerous threat to public health and contribute to tobacco-related disparities. Menthol should be prohibited as an additive at any level and should cover not only cigarettes, but all types of tobacco products. I believe it is also imperative to promote culturally appropriate cessation services to maximize the opportunity for menthol tobacco users to quit, rather than transition to a new or different tobacco product.
Commissioner Loretta Smith,
Multnomah County, District 2
501 SE Hawthorne Blvd., Suite 600
Portland, Oregon 97214
Kreslake JM, Wayne GF, Alpert HR, Koh HK, Connolly GN. Tobacco industry control of menthol in cigarettes and targeting of adolescents and young adults. Am J Pub Health 2008; 98(9):1685-1692.
U.S. Department of Health and Human Services (USDHHS). Preventing Tobacco Use Among Youth and Young Adults: A Report of the Surgeon General. 2012. Atlanta, GA.
Substance Abuse and Mental Health Services Administration. National Survey on Drug Use and Health report: Recent trends in menthol cigarette use. 2011. Accessed online at http://www.samhsa.gov/data/2k11/WEB_SR_088/WEB_SR_088.htm
TPSAC, pg 48
USDHHS, pg 177
ibid., pg 177
Family Smoking Prevention and Tobacco Control and Federal Retirement Reform. Pub. L. 111-33. 123 Stat. 1799. June 22, 2009. Accessed online at http://www.gpo.gov/fdsys/pkg/PLAW-111publ31/pdf/PLAW-111publ31.pdf
Proctor, R.N. Golden Holocaust: Origins of the Cigarette Catastrophe and the Case for Abolition. 2011. Berkeley and Los Angeles, CA: University of California Press.
National African American Health Coalition. What’s the deal with menthol? Accessed online on Sept. 28, 2012 at http://www.naatpn.org/whats-the-deal-with-menthol/.
Legacy. News Release: Many Menthol Smokers Say They Would Quit if Menthols Were No Longer Available. Sept. 20, 2012. Accessed online at http://www.legacyforhealth.org/5165.aspx
Brazil Resolution – RDC Number 14, of March 15, 2012. Accessed online at http://www.tobaccocontrollaws.org/files/live/Brazil/Brazil%20-%20RDC%20No.%2014_2012.pdf
Balbach ED, Gasior RJ, Barbeau, EM (2003). R.J. Reynold’s targeting of African-Americans: 1988–2000, Am J Public Health; 93: 822–827.
Kreslake JM, Wayne GF, Alpert HR, Koh HK, Connolly GN (2008). Tobacco industry control of menthol in cigarettes and targeting of adolescents and young adults. Am J Public Health; 98: 1685-92.
Yerger VB, Przewoznik J, Malone RE (2007). Racialized geography, corporate activity, and health disparities: Tobacco industry targeting of inner cities. J Health Care Poor Underserved; 18: 10-38.
Landrine H, Klonoff EA, Fernandez S, Hickman N, Kashima K, Parekh B, et al. (2005). Cigarette advertising in Black, Latino, and White magazines, 1998-2002: An exploratory investigation. Ethn Dis; 15: 63-7.
Seidenberg, AB, “Cigarette Advertising Differs by Community Demographic Profile,” American Journal of Health
Promotion, 2010 July/August; 24(6):e26-e31.
Wright, La Tanisha. Tobacco Industry Retail Contracts in African American & Low Socioeconomic Communities. National Conference on Tobacco or Health. Kansas City, MO. August 17, 2012. Presentation.
TSPAC, pg 41.
Substance Abuse and Mental Health Services Administration, Office of Applied Studies. The NSDUH Report: Use of Menthol Cigarettes. 2009. Accessed online at http://www.oas.samhsa.gov/2k9/134/134MentholCigarettes.htm
TSPAC, pg 48.
National Youth Advocacy Coalition. (2010). Coming Out about Smoking: A Report from the National LGBTQ Young Adult Tobacco Project. Washington, DC.