Ronald Arthur Berry - Comment

December 7, 2010 Docket Number: FDA-2010-N-0568 Regulatory Information Number (RIN): 0910-AG41 I am writing to ask the U.S. Food and Drug Administration (FDA) to reinstate the “Surgeon General’s Warning” in the text of the proposed cigarette warning labels. There are many compelling reasons to keep the Surgeon General present in the warning labels: 1. Since Surgeon General Luther Terry’s historic 1964 report Smoking and Health: Report of the Advisory Committee to the Surgeon General highlighted the adverse health effects of tobacco use, the Office of the Surgeon General has been inextricably tied to smoking prevention. The warning labels which have been mandated by law since 1965 have always contained the words “Surgeon General’s Warning.” At the time of Dr. Terry’s report, 42% of adults in the U.S. were smokers – that rate now stands at less than 20%. This drastic reduction in smoking rates rests on public confidence in the recommendations of the Surgeon General. 2. Without the Surgeon General brand on the warning labels, the warnings promise to be less effective. Since the earliest efforts to reduce the prevalence of smoking, the Surgeon General brand has given legitimacy to smoking reduction programs and has stood as a public emblem of the fight against tobacco use. Without the “Surgeon General’s Warning” prominently displayed on tobacco products and advertisements, that emblem becomes diminished. The context of the warning as an official recommendation from the nation’s most trusted doctor will be lost. 3. Diminishing the Surgeon General’s brand would further diminish the stature of the office and would therefore adversely impact other health promotion and disease prevention efforts. The visibility of the Surgeon General has fluctuated over the years, but the constant presence of the Surgeon General on cigarette warning labels has kept the position in the public consciousness. Efforts in reducing childhood obesity, injury prevention, and reducing underage drinking may be impacted if public awareness of the Surgeon General fades. 4. While the Tobacco Control Act does specify the text of the new cigarette warning labels, it does not explicitly prevent FDA from including mention of the Surgeon General on the label. I am pleased with the new warning labels – the content of these labels promises to improve government efforts to deter smoking. However, I feel that continuing to include the “Surgeon General’s Warning” will further enhance the effectiveness of these warning labels and give needed visibility to the Office of the Surgeon General, thus enhancing other public health initiatives. Respectfully, Ronald A. Berry, RN, FNP Captain, USPHS Commissioned Corps