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TSRC, Tob. Sci. Res. Conf., 2019, 73, abstr. 004 (Symposium)

Tobacco harm reduction: addressing complexities across the risk continuum

McKINNEY W.J.
JUUL Labs, San Francisco, CA, USA

Government, industry and public health are learning quickly about the complexities of harm reduction in the new tobacco regulatory universe. Each institution acknowledges the harm caused by smoking cigarettes, that a continuum of risk exists for tobacco products, and that youth should never use tobacco products. Disparities reside in how each institution advances harm reduction and resolves unintended consequences. In July of 2017, FDA announced its intention to implement a new comprehensive regulatory plan for tobacco and nicotine that would significantly reduce tobacco-related disease and death and protect kids. FDA noted that cigarette smoking is the primary cause of tobacco-induced harm and that a key component to the success of their approach is increasing awareness that nicotine – while highly addictive – is delivered through products that represent a continuum of risk and is most harmful when delivered through smoke particles in combustible cigarettes. Currently, FDA has not launched a public health campaign to help adult smokers understand that nicotine is not the primary source of harm from smoking. Unfortunately, since the 2017 FDA announcement, adult tobacco users misperceptions about relative risk have increased. Some public health campaigns and statements from notable tobacco control leaders designed to discourage youth from initiating products containing nicotine perpetuate adult tobacco user misperceptions about relative risk. Adult tobacco user misperception about the continuum of risk inhibit switching from more harmful to less harmful nicotine containing products. Some within industry voluntarily imposed restrictions focused on preventing youth access. FDA guidance for industry addressing this issue shortly followed. Time will tell if the FDA guidance and voluntary industry effort effectively advance harm and address unacceptable unintended consequence. Industry is continuing to invest significantly in tobacco products that contain technological advances to inhibit youth use and mitigate other unintended consequences. The ability to market these products in the United States is however restricted by a rigorous regulatory process. The US regulatory process presents a significant barrier to quickly leverage product technology to address complex harm reduction challenges. Tobacco regulation, communication, and availability of product technology are critical components utilized to both advance harm reduction and resolve unintended consequences. More opportunities to discuss barriers and disparate institutional approaches to address the complexities of tobacco harm reduction are needed.