Becky Wallace - Comment

The is a Comment on the Food and Drug Administration (FDA) Proposed Rule: Menthol in Cigarettes, Tobacco Products; Request for Comments

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As a former United States Marshal from 1994-2004, overseeing the Middle District of North Carolina, I worked with local, state and federal law enforcement officers. Prior to my role as a U.S. Marshal, I served as a law enforcement agent with the Town of Troy, a Deputy Sheriff for Montgomery County and an officer with North Carolina Alcohol Law Enforcement. Thus, I have seen an array of issues facing all levels of law enforcement.

One of the most complex issues I have witnessed over my many years of experience has been tobacco smuggling. Over the past few decades, it has continued to grow across our state and nation. As recent as last month, federal agents indicted 16 members of a criminal ring that flooded New York City and upstate New York with over 1 million cartons of untaxed cigarettes illegally imported from southern states. So far the investigation has uncovered approximately $55 million in illegal cigarette sales. This is a demonstration of the contraband issue currently existing for cigarettes and specifically menthol cigarettes.

If the FDA decides to ban menthol cigarettes, then this underground market will expand even further. Federal, local and state law enforcement agencies realize the issue of tobacco smuggling is complex and intertwines with other criminal enterprises. Illicit tobacco trade has a financial impact on states, which lose millions of dollars annually due to unpaid tobacco taxes. Furthermore, contraband operations have been linked to terrorist organizations, which jeopardizes national security. With a ban on menthol cigarettes, governments would be forced to reduce spending, due to loss in tax revenue, possibly impacting law enforcement agencies. When government is faced with limited or reduced financial resources, a reduction in funding for law enforcement and tobacco control should be one of the last places given the concerns addressing national security.

Therefore, the FDA should take into serious consideration the unintended consequences of a ban on menthol cigarettes.
Comment Period Closed
Sep 23 2013, at 11:59 PM ET
ID: FDA-2013-N-0521-0063
Tracking Number: 1jx-87eh-n9oe

Document Information

Date Posted: Sep 6, 2013
RIN: Not Assigned
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Submitter Information

Category: Other Government - G0022