The Indiana General Assembly’s Health Finance Commission met today to discuss tobacco harm reduction strategies to reduce smoking-attributable death and disease. My written testimony, below, was submitted and entered into the record. It was also cited at the hearing by Former Indiana Congressman Rep. Steve Buyer, in his testimony before the commission.

I’m writing to commend the Health Finance Commission for considering how Tobacco Harm Reduction can help reduce smoking related disease and death in Indiana. I’d also like to share some thoughts on science-based harm reduction and how small public policy changes which recognize tobacco harm reduction could yield significant public health goals.

There’s no question that smokers need to be given a variety of tools to help them quit smoking cigarettes. Unfortunately, there is no one way to help smokers that guarantees cessation. Although the ideal would be to get everyone to quit all forms of tobacco use, real world experience and science point to a much more pragmatic approach, rooted in tobacco harm reduction. This method utilizes a range of non-combustible products to help people move down a risk continuum, from the most dangerous product – cigarettes – to less harmful alternatives, such as snus, dissolvable tobacco products, e-cigarettes, and other smokeless merchandise.

In fact, the United States Food and Drug Administration (FDA) is currently taking a serious look at smokeless tobacco products in developing a regulatory approach towards modified, i.e., reduced-risk tobacco products. Tobacco harm reduction strategies are based on the simple fact that cigarettes are more dangerous than other tobacco products, like snus, dissolvable tobacco, and e-cigarettes. With cigarettes, tobacco is burned and inhaled, and that is what makes them far more harmful than tobacco and nicotine products that do not produce carcinogenic smoke.

Particularly instructive is the report issued by the FDA’s Tobacco Product Scientific Advisory Committee (TPSAC) in its March 2012 report on Dissolvable Tobacco Products (DTPs). The official findings of the government report took into account the fact that dissolvable smokeless tobacco products could have a beneficial impact on public health because of the products’ “differing risk profile for tobacco-caused diseases and premature mortality from…partial to complete replacement of cigarette use by DTPs. “

Specifically, the report acknowledged that, “[b]ased on understanding of the delivery of toxins to cigarette smokers, exclusive use of DTPs should be less hazardous than regular smoking of cigarettes now marketed in the United States.”

With certain caveats, the report further found, “that exclusive use of DTPs by an individual would greatly reduce risk for smoking caused disease compared with regular use of cigarettes. The TPSAC framework indicates several ways that DTPs could reduce the population disease burden caused by tobacco use: 1) decreasing the number of smokers, if availability of DTPs increases successful cessation or decreases the likelihood of initiation and use of smoked products, and 2) decreasing the risk of tobacco caused disease, if availability of DTPs sufficiently reduces cigarette smoking.”

In other words, the FDA concluded that smokers switching from cigarettes to non-combustible products would be good for public health.

I encourage the state of Indiana to endorse a range of policies that would create an environment which would benefit the public health in this way. Although the Food and Drug Administration regulates tobacco products, states do have opportunities to to take advantage of the public health promise of tobacco harm reduction. For instance, whereas so called “sin taxes” are used to discourage certain behaviors, those taxes ought to be consistent with the risk of the products the government seeks to discourage. While I oppose sin taxes, I believe that so long as they are in place, they should be applied in a way that is consistent with sound public health policy. Some states tax cigarettes (most harmful) at the same rate as far less harmful smokeless tobacco products. Such an approach undermines the very stated purpose of the sin tax, by removing a financial incentive to move to a lower-risk product.

Along the same lines, other financial incentives can be adjusted as well. For instance, the state of Indiana’s $25 per-pay period discount on health insurance rates to non-tobacco users recognizes that non-tobacco users have fewer health risks and thus lower medical expenses. A similar incentive should be created to encourage smokers to reduce their tobacco-related risks by offering some lesser discount for non-smokers who use smokeless tobacco products to quit smoking.

I encourage the commission to recognize the fact that smokeless tobacco products are far less harmful than cigarettes and can be used to help smokers reduce their tobacco-related risks. As such, it makes sense to tax and regulate these products in a way that is aligned with the science.

Sincerely,

Jeff Stier

Senior Fellow, National Center for Public Policy Research

Director, Risk Analysis Division