Tobacco Documents Online

k / a J WEBSTZR SHEFFIELD FLEISCHMANN HITCHCOCK a CHRYSTIE cD-..[ r...[[«.r JOrr v. l~rDf.~ tOrr7t• By Hand Zach Toms, Esq. Liggett & Myers Tobacco Co. 630 F if th Avenue New York, N.'Y. Dear Ms. Toms : Enclosed herewith is a copy of a letter written on behalf of the American Medical .,•,. Association to the Federal Trade Commission~-'~ dated February ?8. You will note that the AMA opposes the labelling provisions of the proposed industry-wide rules. Sincerely yours, /.L FPH:of Enclosure f1C- 602.cJJ.C.J7 ., K C T R N N 02 8 5- -0 G_

,N1L 'dic;1 l .1~.0L ~i:(t il/ii r0ATt1 b[AhwpPIN •TftttT • CM/CAOO IO, ILLINOIs .~ ., Y. ~ .{ /. 1. L )ar ....~ Y : 4+.w l Xw.•. Y > ..~..r .~.+..+ .... ,..... . rebruary 28, 1964 Chicf, Division of Trade Beavlation ILules Bureau of Industty Guidance ~' aas.hington, D. C, Federal Trade Coomission ' 6th Str.et.at Pennsylvania Avenwe Dear Sir: •µ.. .. • . .'.~. ..~:~. ,, . FC- 60_JJ.°'6 . The Maerican Medical Asaociation is a .•.,;,... , ppreciative of the invi. .~ tetion received from George Dobbs, N.D,, Associate Chicf of your Division of Scientific Opinions, to express its views with rerpcc; • . to the Proposed Trade ftegulation Rulea fot the Ad t i i d v ~ er r ng an Labelin8 of Cigarett.r' . Theee ~`- proposed rules were published in the pederal Re i t f J 22 1464 re o ,, g r anwry , . At the outaet, we ahould lika to state that the AMA has, hii- ;~ . torically, endorsed and pro>:oted federal and state legislatior. co•^.- tainina labeling requirements with reepect to the sale of drvgs, coaastier and hasardovs household products.to conaumers. product. He =sy choose the product and exercise the caution called for by its lebel, or purchase another product for the same, pur•po,e vhich .aF invelvi a lesser or no risk. tions, as in the case of hair dyes. Where labeling requirementa now exist, the conrumor esa7 be influenced in his choice of the nu-nerour products which are availeble to him for purchevo. Nere,.tabeling serves to convoy inforoation to a conruser •+ho migh: otherwise bo uninformed as to the 'riskr inherent in a particular Ordinarily, the labeling of drugs, cosmeticr,and hazardous household products will protect the.public by calling its attentio^ to tho need for careful handling, as in the case of hazardous hou:.- hold productr,• or by alerting the conrumer to possibleallergic rea:• With respect to cigarettes, cautionary labeling cannot be an- tieipated to serve the public interest with any particular degree of sueeers. Tbe health hazards of excessive smokina have been ve:l- ;~. publicised for .ore than tsn yearr an,d are coo.on knovledge. • y ... _ ~ ,. ..RU eooa s.a ~~..: . . . . • ~ . ~-. . t ., ~ -~ COPY CTR ti. • S { S 0i.. ti...• ~..~ 07

.' Labeling will not alert even the young cigarette snoker to any riskt of which he is not alreody aware. While labeling may infiluence the '. purchaser in the choice he makes in the purchase of many products, it vill not, in our opinion,•do so in the purchase of cigarettes. ~ ~ At th ti e presentme, whether the habitual smoker selects the pro- duct duct of one miaufaeturer or another, appears to be relatively in- material. Ihe health hasard involved is substantially the same. We do not believe that the anever to the cigarette problem lies in cautionarr labelirg requirements. Experience in other countries :` indicates that the effect of such labeling at beat is only to reduce temporarily the consumption of cigarettes. After a.rhile the habit- ual smoker i.gnores •the cautions expressed on the label. Since it is evidcnt that cigarette smokina vill continue dos- pite any restrictive labeling that might.be ireposed, it is our opinion that the answer which will do most to protect the public health lies not•in labeling (which is likely to be ignored), but in research. The AMA House of Delegates stated this when it approved, on Dece=ber 4, 1963, a proposal to inaugurate an AMA intensive re- search program. fi• actiocti'of the House•of Delegates included this deicrtption of thl ppograta;;;.. ,,. "The proposed research projects would be designated to probe beyond statistical evideoee,-to search for answers not now available to such questions as which disease- ~. in man may be caused or induced by the use of tobacco. Dctermination needs to be made whether some element or ele=ents in smoke may be a direct or aggravating cause of cancer and other diseases and to identify these substances cheaically. Questions of constitutional and physiologic factore, of physiological dependence, and of habituation require answers. Continuing and further clinicaland pathologic studies need to be made along with collection and correlation of statistical data as it is collected to establish what relationships exist betveen the use of tobacco and disease. Since s.moking may produce a tranquilising effect as voll as ot so vall iderti- ti hi ~ ons n c reac other favorable psye fied, these factors need •fu•rther -study in evaluating the whole matter of the relationship of tobacco and disease. Implementation of the Deeamber action of the AJiA House of Dsle- gates was undertaken a little more than a manth later. By mid- Januarp, the Aaerican Kedical Association Educational ard B.s.arch I I ~ RC- b11...JJJ9 COPY VTR Ht { 0f... ir. a~.. 0L...

1 0 Sincerely, for Research on Tobacco that grants will be made soon to proven investigators who have time and facilities available to begin promptly on studies that are needed and which appear to be pro- mittee had its initial meeting and began to develop a series of recoromendetione for on extensive, objective, and hopefully ef- fective research program. .It is the thinking of the Co=Sttee research of tobacco and health. Shortly thereafter, thc Com- ductive of helpful information. The American Medical Association hopes to be ins[rtimental in obtaining many of the•facta which are necessary to an.intelligent and useful understanding of this Foundation appointed a five-mcmber committee of distinguished scientists to direct the Foundation's long-range program of basic • subject. We have already indicated our belief that the most rewarding approach to the problem of relating cigarette smoking to discases will be by way of productive research. In addition to this sub- stantive reco®endation, we should like to express our opinion and express our. vie++s. labeling and advertising of tobacco, be controlled by the Congress of the United States in the form of enacted legislation, if any, rather than by promulgated administrative regulations. Thq hotice contained in the January 22nd issue of the Federal RegisEer invited "written data, views or argument concerning the proposed rules and the subject matter of this proceeding". We believe that our re•marks respond •to this invitation and vish to express once again our appreciation for the opportunity to commont appropriate that a subject of this magni tude, regarding the millions of dollars of tax revenue.. For these reasons, it is most -3- i that regulatory action in this matter should be instituted by the Congress rather than by the Federal Trade Comaission. More than 90 million persons in the United Statee use tobacco in some form; and, of.these, 72 mil'lion use cigarettes. Long standing social customms and practices are established in•the use of tobacco; the economic lives of tobacco,.growers, procesaers, and merchants are entvined in the industry;'and local, state, and the federal governments are the recipients of and dependent upon many , 1 J P: J L. Bl~aitTgatae, M.D. F.C- 60_JJ6C1 .1 . COPY CTR [ [ { { 028509