The Campaign for Tobacco-Free Kids is attempting to recruit thousands of America's youths to help Philip Morris achieve its chief legislative goal - the enactment of federal legislation that would secure the company's market share and profits for years to come and would grant unprecedented special protections to the tobacco industry -- protections that are not enjoyed by any other industry.
But the Campaign is not informing the youths who they are recruiting about these basic facts regarding the FDA tobacco legislation.
In a recruitment guide for Kick Butts Day, the Campaign attempts to get youths to organize events intended to promote the passage of the FDA tobacco legislation. For example, one suggested event is called "They Put What in a Cigarette?" Youths are encouraged to highlight the various chemicals present in cigarette smoke and to write their Congressmembers in order to promote passage of the FDA tobacco legislation: "Let your Members of Congress know you think Big Tobacco should tell the public what exactly is in their deadly products. You can take action! Let your Senators and Representatives know how you feel about these fatal ingredients, and that Big Tobacco is still targeting youth. Send letters urging they do something about it and protect America’s youth. You can hold a letter writing campaign at your event."
The recruitment guide highlights one group of youth anti-smoking advocates, who met with Congressmembers to urge them to support the FDA tobacco legislation.
Throughout the recruitment guide, youths are urged to plan events intended to promote the FDA tobacco legislation, and they are encouraged to organize letter-writing events to Congressmembers to promote this legislation: "Let them know you want stronger warning labels on tobacco products, and that they should give the U.S. Food and Drug Administration the authority to regulate tobacco products and require stronger warning labels. Visit tobaccofreekids.org for more information about FDA regulation of tobacco, and check page 37 for contact info for your members of Congress."
The Rest of the Story
Nowhere in the recruitment guide, however, are youths informed that the FDA legislation is being supported by none other than Philip Morris, the nation's leading tobacco company. Nowhere in the guide does it inform youths that the legislation would provide special protections to the tobacco industry - protections not enjoyed by any other industries whose products are regulated by the FDA. Nowhere in the guide does it inform youths that the legislation would tie the FDA's hands by precluding it from removing the nicotine from cigarettes. Nowhere does it inform youths that the legislation would prevent FDA from banning cigarettes sales in pharmacies or any other specific retail outlet. Nowhere does it inform youths that the legislation gives Congress veto power over any major FDA regulation, ensuring that the decisions will be based on politics, rather than the public's health. Nowhere does it inform youths that the legislation would make it impossible for tobacco companies to develop and market potentially safer products. Nowhere does it inform youths that there is no evidence that removing specific constituents from tobacco will make cigarettes safer. Most importantly, nowhere does it mention that the legislation contains a number of political compromises that were inserted solely to appease the interests of Philip Morris, even though they interfere with the protection of the public's health.
This is as unethical as anything I have witnessed in 21 years of tobacco control practice.
There is nothing wrong with encouraging youths to become politically active. In fact, it is an admirable action. However, it is wrong to misuse kids by using them to support legislation without informing them of all the relevant facts about that legislation and allowing them to make their own informed decisions about whether to support it or not. One could just as easily recruit youths to oppose the FDA legislation, telling them (correctly) that the legislation contains provisions that were inserted solely to protect the financial well-being of the tobacco companies. If presented in this way, most youths would oppose, rather than support the legislation.
The problem is especially severe because the entire tone of the recruitment guide is one that speaks of how despicable and destructive the tobacco companies are and how we should not be offering them any special protections. But the proposed FDA legislation does just that.
This particular piece of legislation is a very complicated one, and unless one reads the fine print, it is impossible to make an informed judgment about whether to support or oppose it. It is not as simple as asking kids to support a smoke-free policy, where the issues involved are quite easy to understand. Here, the issues are quite complex. Even as an expert in the field for the past 21 years, it still took me about two months to analyze the legislation, and it took about 36 pages for me to simply summarize the results of my analysis. You simply cannot ask kids to lobby for such a bill without taking the time to inform them of the complex regulatory, policy, political, and scientific issues involved.
The Campaign for Tobacco-Free Kids is doing none of these things. They are casting the issue as a very simple one. Other products -- food and drugs -- are regulated by FDA; so should tobacco. But they don't go beyond that. They don't explain to youths the compromises that were made by politicians (and by the Campaign itself) in fashioning legislation in such a way that it would appease the financial interests of the nation's leading tobacco company.
Why, for example, does the bill not allow FDA to ban the sale of tobacco at pharmacies (or at community centers, for that matter)?
Why does the bill not allow FDA to increase the age of cigarette purchase?
Why does the bill not allow FDA to remove nicotine from cigarettes?
What evidence is there that regulating levels of specific tobacco smoke constituents will result in a safer cigarette?
How likely is it that the FDA will be able to pass any meaningful restrictions on cigarette advertising that will be upheld by the Supreme Court?
By the way, it is not just youths that the Campaign is failing to inform about these critical aspects of the legislation. The Campaign is not adequately informing any public health groups that it is recruiting - its propaganda on the legislation does not disclose any of this critical information.
But it is particularly egregious that the Campaign would misuse youths in this way. It's one thing to fail to properly inform adults. They could presumably research the issue on their own and come to an informed decision. But youths are not capable of doing this. Youths are extremely vulnerable to this kind of propaganda, especially when it is highly rhetorical, one-sided, unbalanced, and based on pure jargon and rhetoric.
There is no serious effort taking place by the Campaign to inform youths of the critical information they need to have to make an informed decision of their own on the proposed FDA legislation. This violates one of the central ethical principles of public health practice: informed consent.
The deception of young people by the Campaign has been so widespread that an entire organization it helped to form - IGNITE - is running a website that is almost like a Campaign for Tobacco-Free Kids, Jr. It mimics the TFK's tactics by recruiting young people to support the FDA legislation without informing them about the most critical facts. It deceives them in a number of important ways.
For example, I logged onto the site and attempted to write a letter to my local newspaper about the FDA legislation. Automatically, the title of my letter was inserted as follows: "Congress must regect Big Tobacco's political money." [complete with the misspelling]. What a deceptive title! The implication is that Big Tobacco opposes the proposed FDA legislation. But the truth is that the largest company within Big Tobacco -which commands half of its market share - vigorously supports the legislation!
Then, with a click of a button, I inserted this text: "Big Tobacco has marketed a deadly, addictive product to young people like me all across the world for years. As a result, 1,200 Americans die every day due to tobacco-related disease. And still, our politicians across the nation do so little to curb this public health crisis by holding Big Tobacco accountable for its actions."
Again, this is massively deceptive. The FDA legislation would not help hold Big Tobacco accountable for its actions. It would completely take Big Tobacco off the hook. It would give the companies an FDA blessing - a stamp of approval - and make it virtually impossible to hold the companies accountable in court for any damages caused by their products.
Another click of a button and I "wrote": "The FDA can do a lot to stop tobacco companies from killing Americans. We just need Congress to let the FDA do it."
This is deception on a grand scale. First of all, how specifically can the FDA stop tobacco companies from killing Americans? Supporters of the legislation have yet to articulate a single mechanism by which the proposed legislation will save lives. On the other hand, there are a number of demonstrated mechanisms by which the legislation could actually result in increased smoking and increased deaths.
But more importantly, this is deception because it hides the fact that the proposed legislation would tie the FDA's hands in a number of critically important ways. If we really want Congress to "let the FDA do it," then this is the last piece of legislation in the world that we want.
Elsewhere, Ignite complains that "Right now, macaroni and cheese, among countless other products, is checked by the FDA to make sure consumers won't be hurt by eating it. But cigarettes, unlike macaroni and cheese, goes completely unchecked. Isn't this crazy?"
Perhaps it is crazy, but Ignite is deceiving young people by making them think that the proposed legislation would give the FDA the authority to check cigarettes to make sure that people won't be hurt by smoking them. The legislation does nothing of the sort.
As much as I admire the young people for becoming politically active for a public health cause, I am saddened by the fact that they themselves have apparently been so deeply deceived about the scientific, policy, political, and regulatory issues involved with tobacco products that they are now deceiving their fellow young people.
Don't get me wrong - I'm not blaming Tobacco-Free Kids, Jr. I'm laying the blame directly at Tobacco-Free Kids, Sr. They are the ones who apparently recruited, organized, educated (really, failed to educate), and supported these young people.
The rest of the story is that by misusing kids to support its own desired legislative goals -- by failing to inform the youths they are recruiting of the critical information they need to make an informed decision -- the Campaign for Tobacco-Free Kids is engaging in what I consider to be the most unethical practice of tobacco control I have observed in 21 years in the field.
The Campaign is entitled to promote the FDA legislation on its own and it is entitled to deceive adult tobacco control and public health groups in order to gain their support for the legislation, but it has no ethical business misusing kids for this purpose. I call on this misuse of kids and young people to end immediately.