Here's the problem: On the Ignite (a youth/young adult anti-smoking advocacy group) web site, it states: "Even though tobacco is addictive and causes over 400,000 American deaths every year, tobacco is still the only consumer product not regulated by the FDA."
To be lenient, that is an inaccurate statement. To be more harsh, it's a lie. It's simply dishonest to publicly claim that all other consumer products (other than tobacco) are regulated by the FDA.
Here's another problem: the Ignite web site acknowledges that "one tobacco company, Philip Morris, has broken with the rest of the tobacco industry to support legislation that calls for strong and effective FDA regulation of tobacco," but at the same time, its action alert letter to Senator Charles Grassley states: "you effectively managed to kill legislation that would have given the Food and Drug Administration the authority to regulate tobacco products. You voted just as the tobacco industry wanted you to vote."
If the first statement is true (that Philip Morris supports the FDA legislation), then the second statement (that a vote against the FDA legislation is just how the tobacco industry wants Senators to vote) is inaccurate and misleading. The tobacco industry most certainly includes Philip Morris (which controls about half of the domestic market), so it is deceptive, I think, to state that the tobacco industry opposes the legislation.
But despite all of this, I do not blame the youths and young adults involved in Ignite for these inaccurate and misleading campaign statements. In fact, I have nothing but praise for the initiative that these young people have taken. If only more youths and young adults would show as strong an interest in government and public policy and demonstrate as strong a commitment to improving public health.
So why is it that I blame the Campaign for Tobacco-Free Kids (TFK) for the campaign dishonesty?
For several reasons:
First, the Campaign has set the example for campaign dishonesty through its own campaign of deception in support of the FDA legislation. The young people are clearly relying heavily upon the Campaign for Tobacco-Free Kids and its campaign materials, so I think that TFK is partly responsible.
Second, the Campaign is a significant funder of Ignite. It helped get the group off the ground and it appears to be a current funder of the group. As a primary funder of a youth advocacy group, I think TFK has a responsibility to make sure that its donors' money is being used appropriately. And one measure of the appropriateness of that money's use is ensuring that the campaign materials are truthful, accurate, and not deceptive or misleading.
Third, the Campaign played a significant role in training many of the individuals who are running the Ignite organization. The Campaign certainly appears to have been responsible for the training that many of these young people received about the FDA legislation and the issue of federal regulation of consumer products, and tobacco products in particular. But that training seems to have been dismally flawed, as the youths do not appear to even understand the basic regulatory framework for consumer product safety in our federal regulatory system (in which the safety of the overwhelming majority of consumer products do not fall under the jurisdiction of the Food and Drug Administration).
Fourth, it is very unclear whether the young people appreciate the many loopholes in the FDA legislation and the way that these loopholes protect the interests of the tobacco industry. They also don't seem to appreciate the fact that these loopholes resulted from a negotiation process in which the Campaign for Tobacco-Free Kids made compromises, on behalf of the entire public health community, essentially to appease the concerns of the nation's largest cigarette manufacturer and to ensure that "terrorist" (in the words of Ignite) company's support of the legislation.
The Rest of the Story
One of the essential principles, I think, of directing youth in public health advocacy campaigns is full disclosure of the relevant facts. And I think that the nature of the loopholes, the way in which the loopholes came to be, and the reasons why the loopholes were included in the legislation are an essential part of that disclosure process.
Without full disclosure of the relevant facts, I do not think that it is ethical to use youths for our public health advocacy purposes. In a sense, it violates the ethical principle of "informed consent."
Do I know for a fact that TFK did not share the intimate details of the negotiation process of S666 and HR1376 with the youths they were training? No. However, it seems quite unlikely that they did since TFK has still not shared those details with the public health community at large, and still denies that there was any negotiation that took place with Philip Morris at all.
These young people's support of S666 and HR1376 seems to be completely inconsistent with their views on the tobacco industry and the need to keep the tobacco companies' interests out of policy making. After all, if these young people are so concerned that the tobacco companies' interests should not play a role in the public policy process that they are calling for the ouster of every poltician who takes any money from the tobacco companies, then one would naturally assume that they would find it objectionable to have the dominant tobacco company's interests play the critical role in shaping the development of legislation to regulate a product that kills over 400,000 Americans each year.
When I start seeing that the youths are doing something that is entirely inconsistent with the principles that they themselves have expressed, that is a clue that something is wrong. That is a clue that there is undue influence going on. And in this case, I think it's pretty clear that influence is coming from TFK, their primary funder and trainer.
I can't prove this, but my guess is that the youths are inwardly quite uncomfortable about supporting legislation that Philip Morris supports (hence their sincere, yet uncompelling attempt to reconcile that support with their contention that the bill is not in the interests of Philip Morris) and my guess is that they are even more uncomfortable with the notion that they are supporting a bill with so many gaping loopholes that are in the legislation only to protect the expressed interests of Philip Morris, who these young people consider to be a terrorist organization.
But youths should not be uncomfortable with their actions. The Campaign for Tobacco-Free Kids should never have involved the youths in lobbying for this legislation, for that reason alone.
It takes an incredibly sophisticated knowledge and understanding of the tobacco control field, and years of experience with tobacco company behavior and federal, state, and local regulation of tobacco products, as well as experience and understanding of the issues of tobacco toxicity, tobacco smoke ingredients and components, the epidemiology of tobacco-related disease, reduced risk tobacco products, influences on tobacco use rates, the nature of tobacco litigation, the legal issues involved in that litigation, and a host of other very complex issues to even begin to be able to make an informed judgment that S666 and HR1376, despite their substantial loopholes inserted to appease Philip Morris, would still be, overall, more beneficial to the public's health than detrimental.
While I strongly disagree with TFK's judgment on this precise issue, I nevertheless respect the fact that the individuals working there have years of experience and tremendous knowledge and expertise in this area, and I believe that they are fully capable of making their own informed judgment of the costs and benefits of this policy proposal, a judgment which is incredibly complex. While I disagree with the ultimate judgment that TFK has made, I respect their right to make the judgment, I believe that the judgment was made in a fully informed manner, and they certainly have the right to run their public policy campaigns based on that judgment.
The situation is far different, however, with youths. I do not believe that they have enough experience, knowledge, or expertise to be able to make an informed judgment on this complex issue, because with the complexity of this legislation, it took years of experience in epidemiology, smoking etiological research, tobacco marketing research, litigation and legal issues, and knowledge in the areas of the chemistry and biology of cigarettes and tobacco-related diseases, epidemiology, public policy, politics, and the history of tobacco legislation and regulation for me to be able to make an informed judgment on this issue.
And it took me no less than 36 pages to analyze the legislation and provide my argument for why I viewed the costs of the legislation to greatly outweigh any potential benefits.
I don't think that youths can or should be asked to make this kind of complex judgment. And if they are unable to make a judgment on their own of the bill's merits, then I think it is inappropriate (and unethical) to involve them in advocacy for this particular proposed policy.
I have no problem with the basic idea of involving youths in public health advocacy efforts. But I think to do it ethically, the youths need to be fully informed and must be able to make a fully informed judgment about the merits of the bill that they are being asked to support. And in the case of this complex legislation, I don't think that is possible.
The rest of the story suggests that the Campaign for Tobacco-Free Kids' use of youths to help support S666 and HR1376 (and similar bills in the 2004 Congressional session) is highly unethical because it involves the use of youths without the possibility of their fully informed consent.
In the case of Ignite, the Campaign appears to have involved these youths in supporting legislation that is inconsistent with the very principles that these youths themselves have expressed.
That is quite sad. It is unfortunate. And most of all, it is unethical, and I condemn it for that reason.