Elizabeth Dubravcic - Comment

I would like to submit findings from Delaware’s 2012 Tobacco Attitudes and Media Survey (DE 2012 ATS), which I believe have bearing on the question posed by the FDA regarding the labeling on smokeless tobacco products. The DE 2012 ATS telephone survey sampled 1200 adults and included both landline and cell-phone components in a 75:25 ratio. More than two percent (2.3%) of adult males in Delaware reported using smokeless tobacco in 2012. This represent s some 7,800 smokeless tobacco users statewide. The state’s FY 2012 counter-marketing campaign included messages in various media on the health risks of using smokeless tobacco. The survey found that adult males who use smokeless tobacco (87%) are much more likely than non- users (21%) to recall having seen or heard advertisements about the health risks of using smokeless tobacco products in the past month. (p=0.000) Despite this, relatively more smokeless tobacco users (32%) than non-users (8.5%) said they believe that smokeless tobacco is less harmful than smoking cigarettes. (p = .0967) At the same time, fewer smokeless tobacco users (42%) compared to 72% non-users believe smokeless is just as harmful as cigarettes. Thus, it is clear that 1) smokeless tobacco users are aware of advertising aimed at them; and 2) there is still more work to do in terms of correcting misperceptions about the dangers of smokeless tobacco. Because the FDA proposed labels are targeted directly at smokeless tobacco users and potential users, we believe they will be at least as successful as other counter-marketing efforts in reaching this intended audience. Should such labels become mandatory, Delaware’s Tobacco Prevention Program will be in a position to help measure the reach and impact of these messages on a state-wide population basis. Elizabeth Dubravcic, Evaluator State of Delaware/ DHSS/ Division of Public Health Tobacco Prevention and Control Program Submitted April 1, 2012