Virginia Foundation for Healthy Youth - Comment

We, the Virginia Foundation for Healthy Youth (VFHY), would like to share updated results of the Meltdown Campaign with the FDA. With these dissolvable products now available nationwide, we hope the FDA find our data compelling enough to take strong action to protect the general public in general and youth in particular from these tobacco products with appropriate rules and regulation. As early as July 2010, members of our youth advocacy group, Y St., have reported seeing Camel Orbs for sale in the Southwest and Central regions of Virginia. Y St. has been dedicated to the Meltdown Campaign since May 2009 to increase awareness about dissolvable tobacco products in their communities and assess public opinion regarding these new products even when the products were still available only in test markets. We first submitted comments for the public docket several months ago, summarizing survey results that youth volunteers collected from 1,400 Virginia residents throughout the state. Similar to our findings then, the updated survey findings corroborate the suspicion that these new products are easily confused for candy, mints, or gum based on their packaging and flavoring. Between May 2009 and June 2010, youth volunteers collected surveys from 2,433 Virginia residents throughout the state. Key findings from the survey are included below: - 42% of teenagers believed Camel Orbs to be candy, mints or gum, based on its packaging; - 28% of teens who currently do not use tobacco said they would try Camel Orbs Fresh based on its packaging; - 53% of respondents believed that Frost, a Snus flavor, was a flavor associated with candy, mints or gum.; - 81% of respondents said they would try a Wintergreen-flavored product. As of September 20, 2010, this campaign is still implemented in Virginia and is being replicated in New Mexico. A similar campaign will be launched in Oklahoma. We hope to submit future findings to the FDA.