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STATEMENT OF GREGORY N. CONNOLLY 

 -1- 



My name is Dr. Gregory Connolly and 1 an^ pleased to testify before the 

 Subcommittee on Heedth and the Environment on behalf of the Anierican Public Health 

 Association in support of the Federal Food and Drug Administration's regT-Uation of 

 tobacco products as drugs- I will focus my remarks on regulation of moist oral snuff as 

 a drug. I am the director of the Massachusetts Tobacco Control Program which is a $52 

 million state agency diarged with curbing tobacco tise in Mtissachusetts. I have 

 conducted research on the health effects of oral tobacco and have published a number 

 of articles in the scientific literature on this topic. I am chairman of the World Health 

 Organization's Study Group on Smokeless Tobacco and a consultant to Major League 

 Baseball. In that capacity I have re.searched dependence among baseball players on oral 

 snuff and developed a cessation program for those who are interested in quittiiig. 



Summary of Testimony 



1) Micotine is an addictive drvig aiid the larger manufacturer of moist oral 

 snuff, U.S. fobacco Company (UST) which has 88% of U.S. sales has 

 conducted research on tlie phaiinacological properties of nicotine and has 

 knowledge of its dependence producing properties . 



2) The manufacturer has used this knowledge to develop low nicotine starter 

 snuff brands with the intent having new users experiment witli the 

 products and gradually develop dependence. 



3) The manufacturer employs a "graduation" strategy with the intent of 

 moving new users from tlie low nicotine brands up to higher nicotine 

 brands as dependence occurs. The manufacturer intentionadly adjusts the 

 nicotine dose in each brand to cause and maintain dependence. 



4) The manufactviring strategy has contributed an 83 percent increase in sales 

 of moist oral snuff from 1981 to 1991 and a 20 fold increase in use among 

 males 18-19 from 1976 to 1991 (.3 to 7.6%). 



5) Based on tlie manufacturer's knowledge of nicotine and intent to cause and satisfy 

 dependence among consumers, moist oral snuff should be classified as a drug 

 under the Federal Food, Drug and Cosmetic Act. 



