616 



that the reported use of smokeless tobacco (defined as use on at 

 least one occasion in the last 30 days) by 12-17 year old males 

 decreased from 6.6% in 1988 to 5.3% in 1991. 



Moreover, a survey published in October 1993 by the 

 Substance Abuse and Mental Health Services Administration 

 (SAMSHA)-' reported that use of smokeless tobacco by 12-17 year 

 old males had further declined in 1992 to 4.8%, which is very 

 close to the 4.0% "target" for the year 2000 in Healthy People 

 2000 Review . 



Furthermore, the reported use of smokeless tobacco by the 

 total 12-17 year old population (males and females) was only 2.6% 

 in 1992 according to the SAMHSA survey. 



Allegations Regarding A "Graduation Strategy" 



Dr. Connolly has alleged that U.S. Tobacco "employs a 

 'graduation' strategy with the intent of moving new users from 

 the low nicotine brands up to higher nicotine brands as 

 dependence occurs." And Dr. Kessler has asserted that "there is 

 evidence that smokeless tobacco products with lower amounts of 

 nicotine are marketed as 'starter' products for new users, and 



National Household Survey on Drug Abuse: Population 

 Estimates 1992 DHHS Pub. No. (SMA) 93-2053, Oct. 1993, p. 97. 



15 



