CRE continues to review reports identified by FDA in the menthol proceeding.

CRE has previously completed its analysis of the Hersey study which is posted on this Forum.

Attached hereto is the CRE analysis of the following study:TPSAC Okiuyemi 2003

Attached Files:

Legacy on Menthol

7 August 2010

Periodically, CRE will highlight a comment sent to a regulatory docket.
In this instance we are highlighting comments made by the Legacy Foundation to CTR, see the attachment.

With respect to menthol, Legacy states that menthol is a starter product for youth(pg. 16).

Virtually no scientific information is presented in support of this claim.

The TPSAC proceeding is aimed at addressing this issue. In this regard see the CRE analysis of the Hersey studied often quoted by FDA which is available at

Pamela Clark, Ph.D. & Phillip Gardiner, Dr. P.H. – Comment

Document ID:
This is comment on PROPOSED RULE: Regulation of Tobacco Products; Extension of Comment Period
Docket ID:
See the attachment for the summary report.
No Topics associated with this document

The FDA has requested comments  on  ”Tobacco Product Advertising and Promotion to Youth and Racial and Ethnic Minority Populations.

In response to this request,  


Mr. Zachary Ryan Morgan writes:

The FDA has even been looking at banning flavored cigarettes, including menthols, but “Joshua Rising, a researcher for the FDA, found no casual link between smoking menthols and an earlier initiation of smoking.”


Roswell Cancer Center states:

“We find no evidence that those who self-report smoking a menthol cigarette brand have different quit rates than those who self-report smoking a non-menthol cigarette brand, after adjusting for other smoking and demographic factors.”

Jun 16 2010 6:14pm

Let’s start this post with some indisputable facts about smokeless tobacco
1. Despite decades of epidemiologic research, long-term use of Swedish or American smokeless tobacco products (other than dry powdered snuff) has not been associated in a significant way with ANY disease.

2. Just like the foods we consume, contemporary smokeless tobacco products contain trace amounts of contaminants.

3. Tobacco-specific nitrosamines (TSNAs) are contaminants found only in tobacco products. They are present in vanishingly small concentrations – mainly in the single-digit parts-per-million range.