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RTs Can Help Influence Tobacco Policies

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July 21, 2014

As a respiratory therapist treating individuals with chronic lung disease, you have seen firsthand the devastating effect use of tobacco products has on the health and lifestyle of your patients. That’s why it’s important for you to share your experiences with the Food and Drug Administration (FDA) as they look to expand their regulatory authority. The message is a simple one—Regulate all tobacco products.

The FDA currently regulates cigarettes, smokeless tobacco and roll-your-own tobacco. The agency has proposed a new rule, referred to as the “deeming rule,” which would extend its authority to regulate all other tobacco products, including electronic cigarettes (e-cigarettes), cigars, pipe tobacco, hookah tobacco and dissolvable tobacco products. Public comments on this proposed rule are being accepted until August 8, 2014.

As part of the Tobacco Partners Coalition (Coalition) headed by the Campaign for Tobacco Free Kids (CTFK) along with the American Lung Association and the American Cancer Society, AARC has been involved in meetings and conference calls regarding this and other tobacco-related issues.

Generally when we respond to regulations that may have an impact on respiratory therapists or the profession as a whole, the AARC submits comments on behalf of its members as a national professional organization. With respect to the deeming rule, AARC plans to follow this process in addition to signing on to joint comments with our Coalition partners.

However, this time around we want our members and State Societies to get in the act as well. Why is this different from other regulations? Because AARC and other Coalition members need to generate comments on the FDA’s deeming rule to counter the tens of thousands of comments being submitted by cigar lovers and vapers (i.e., those who smoke e-cigarettes). We have been told that the quantity of public comments FDA receives is as important to the agency as is the quality of the comments.

We need to make sure our voice is heard as advocates for our patients and to oppose actions by “big tobacco” to seek special exemptions that have the potential to put children and young adults in harm’s way.

To make it easy for our members and others, in the past few days CTFK has set up a website aimed at generating thousands of comments to counter those in favor of the tobacco industry. It can be accessed at http://regulateALLtobacco.org.

So what do you need to do? Go the site and review the materials. It includes background info, talking points, fact sheets on cigars and e-cigarettes, and sample comments for parents, health care providers, concerned citizens and public health advocates. There are several click-through opportunities to submit comments directly into the deeming docket at Regulations.gov, along with some basic instructions on how to fill out the comment form. It is not branded with any logo (although it does state at the bottom that it was developed by CTFK so people know where it came from). AARC and other Coalition members have been assured that the names of those who click through to take action will not be captured by CTFK. The site has been tested in all major web browsers and has been designed to work on smartphones and tablets.

Pick a sample letter that best fits your situation. Either the health care provider or public health advocate sample letters can be tailored for your use. You may want to add your personal experiences as a respiratory therapist or as a State society supply data from your state. It is entirely up to you if you want to supplement the letter. For example, before the CTFK website was established, the Utah Society for Respiratory Care submitted comments to FDA that included data on the percentage of adults and high school seniors in the state who use e-cigarettes (the high school rate is 4 times the adult rate); the increased use (tripled) of e-cigarettes among students in grades 8, 10 and 12 since 2011; and the increased rate of e-cigarette use among these students over other forms of tobacco or nicotine products. If you choose, any data that you can provide will be helpful.

Keep one thing in mind, however. Make sure the facts contained in the sample letters are part of your submission because it’s very important that FDA gets the support they need to carry out their regulatory authority.

But don’t stop there. Get your friends who may not be in the respiratory profession to get involved as concerned citizens and also tell your patients about the website. We need to mobilize our members to fight against the stronghold of the tobacco industry and its lobbyists in affecting public policy. Now is your chance to make a difference in the lives and future of young adults who may be swayed by the glamour and marketing of tobacco products that will only increase over time without the strong regulatory arm of the FDA.