I've smoked only the pipe for 47 years. I would never put RYO in a pipe. RYO tobacco is much too small a cut for the pipe bowl and would smoke very hot. Pipe tobacco's larger cut would also not be suitable for RYO because it is cut too large to roll into a wrapper. It is unfortunate that the RYO industry has tried to fool the government with labels. The fact is you are on the proper track by distinguishing between the two types. I suggest you base your analysis by examining reputable tobacco manufacturers and interviewing user's of both types. Pipe tobacco is not meant to be directly inhaled unlike RYO products. I sincerely hope you will be successful in your endeavor to separate the two types. I generally agree with the comments put forth thus far. If you have pipe smoker's on your staff, they will surely be able to help you distinguish the difference in cut, character and content of the product. I wish to preserve the pipe smoking hobby and appreciate the opportunity to comment. I know it is a difficult situation.
Comment 5: Coffey, Robert J.
This is comment on Proposed Rule
Notice No. 106: Standards for Pipe Tobacco and Roll-Your-Own Tobacco
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