505 



-7- 



vn. The Use of Low Nicotine Brands Along with Graduation Strategy Has Resulted in 

 a Sharp Increase of Oral Snuff Sales and Widespread Nicotine Dependence Among Young 

 Males 



From 1981 lo 1991 UST sales of moist oral snuff rose 50% from 27.3 million pounds to 

 41 million pounds. Interestingly, there wai no increase in sales for staner products such as Happy 

 Days and SKOAL Bandits but a 83% increase for the highest nicotine brand, Copenhagen, 12 

 million to 22 million pounds. The failure in sales growth of the low nicotine brands demonstrate 

 that the brands serve as transition products to the higher nicotine brands. 



From 1970 to 1991 , the prevalence of use of snuff by men age 18+ rose from 1.4% to 

 3.1% and among males 18-19 from .3% in 1970 to 7.6% making that age group the heavieist 

 users of the product. The 1990 Youth Risk Behavior Survey found that 24 percent of all white 

 male high school studenls use smokeless tobacco at least once during tlic past month. A 1989 

 National Collegiate Athletic Association (NCAA) survey of college athletes found a 40 percent 

 increase (from 20 percent to 28 percent) in the use of smokeless tobacco from 1985 to 1989. 

 Among NCAA baseball players an alanning 57 percent use. 



CONCLUSION 



Based on the information supplied above oral snuff should be declared a drug under federal law. 



Commissioner Kesbler of the FDA has staled that if tobacco products arc declared drugs, then 

 Congressional action may be needed to prevent proliibition of tobacco products. If Congress does 

 intervene we strongly recommend that the marketing of cigarettes be restricted to standards that 

 currendy apply to other drugs including no direct advertising or promotions to consumers, full 

 disclosure of all additives and full di.sclosure of all health risks and generic packaging. Also, 

 new products such as SKOAL Bandits be treated in the same manner as any other drug and be 

 prohibited from sale if deemed harmful to human health. 



