Submission by Clive Bates and David Sweanor to FDA consultation on a proposed rule: Tobacco Product Standard for N-nitrosonornicotine (NNN) Level in Finished Smokeless Tobacco Products. Docket: FDA-2016-N-2527 (Our comment Tracking Number: 1k1-8xev-p31g)
We respectfully suggest the proposed rule is withdrawn as soon as possible. Our submission highlights four main areas of concern:
1. Overstates benefits.
2. Understates market disruption.
3. Ignores unintended consequences.
4. Fails tests for public health and good regulation.