Monday, 29 September 2014 16:23

My Comment to FDA on the General Snus MRTP Application

Written by Larry Waters
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Updated 18 August 2015 - NOTE:  This story was originally published on 29 September 2014 during the first FDA Public Comment Period on the General Snus MRTPA.  Fast forward almost 11 months and we are reaching the 31 August 2015 for the second and final Public Comment Period.  If you haven't already acted, now is the time to do so.

This article contains my 2014 statement to FDA which was published in the Federal Register.  It was just my snus story from the heart.  This is what FDA needs see. 

You can then review my 30 July 2015 General Snus MRTPA update for instructions on how to get your opinion on the record.  This is our last chance!

The FDA Tobacco Products Division, in reviewing Swedish Match's MRTP application for General Snus products sold over the counter in the US, is in the midst of a required Public Comment period.  During this time, the American public is encouraged to express their opinions, facts, and thoughts on the issue.

Below is my submission.  I encourage all snus users and tobacco harm reduction advocates to join me in participating.


My 2014 Public Comment to FDA on General Snus

FDA Public Comments: General Snus MRTPAHi, my name is Larry Waters and I'm a nicotine addict.  I started smoking when I was 13 years old.  Throughout my smoking life, I consumed 1.5 to 2 packs of cigarettes a day.

My health was suffering because of the 6-10,000 toxic substances in a lit cigarette the older I became and as an added concern, heart disease runs in my family. 

I wanted to quit smoking cigarettes.  I quit smoking many times but always returned to smoking for the nicotine.  Nicotine is as addictive as heroin and I was hooked.

In 2007 I accidentally discovered Swedish Snus.  Ironically, it was General Original Portion Snus, one of the 10 products submitted for MRTP status in this application.  Within a week, I was able to transition completely from a 35 year cigarette habit to Swedish snus.

That was 7 years ago and I haven't smoked a cigarette since.  More importantly, I never craved a cigarette again.  Swedish snus satisfied my addiction and tasted great.

My nicotine addiction no longer impacted the health of others.  Snus is an oral tobacco; there is no second hand snus to affect my family or others around me.  Swedish snus is spitless.  I was not depositing my saliva anywhere except my stomach....which is doing just fine, thank you.

I began writing about Swedish snus and others made the transition from cigarettes to Swedish snus.

Despite restriction, public disdain, and the known health risks of cigarettes, there are still approximately 42 million cigarette smokers in the United States today.  The vast majority would stop tomorrow if they could; smoking has just become too inconvenient and oppressive.  This vast majority just can't stop smoking because they too are nicotine addicts.

Like me, if presented with a reduced harm alternative which really worked when it came to nicotine satisfaction, was completely discreet to the general public, and reduced the damage to their health by conservatively 98% compared to cigarettes, the vast majority would ultimately take advantage of that.

Removing the factually incorrect cancer warning labels now required on General Snus and replacing the current "not a save alternative to cigarette" warning with the more accurate statement in the application will reassure smokers new to snus that General Snus is a considerably less harmless yet viable alternative to cigarettes.

Nicotine is no more dangerous than caffeine although quite a bit more addictive.  Nicotine is not responsible for the millions of deaths and just reported 2 trillion dollar drain on public health resources worldwide caused by lit tobacco products and cigarettes.

FDA has the opportunity to significantly improve the public health and save lives by promoting reduced harm alternatives to cigarettes which work.  The so-called "Swedish Experience" demonstrates that clearly.  The 123,000+ pages of which the General Snus MRTP application consists makes this more than clear.

I implore FDA to make a common sense and science based evaluation of the Swedish Match MRTP application and approve it.  Too much is at stake to allow the political and financial agendas of others to win out.  Millions of nicotine-addicted smokers will continue to sicken and die before their time if this application is denied. 

This is a life or death situation.  FDA can and must break this cycle of unnecessary mass sickness and death.  Please approve the Swedish Match MRTP Application for General Snus.

Best Regards,



Read 4467 times Last modified on Tuesday, 01 September 2015 17:12

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