To Whom it May Concern:

My name is Jeffrey A. Singer. I am a Senior Fellow in Health Policy Studies at the Cato Institute. I am also a medical doctor specializing in general surgery and have been practicing that specialty in Phoenix, Arizona for over 35 years. The Cato Institute is a 501(c)(3) non-partisan, non-profit, tax-exempt educational foundation dedicated to the principles of individual liberty, limited government, free markets, and peace. Cato scholars conduct independent research on a wide range of policy issues. To maintain its independence, the Cato Institute accepts no government funding. Cato receives approximately 80 percent of its funding through tax-deductible contributions from individuals. The remainder of its support comes from foundations, corporations, and the sale of books and other publications. The Cato Institute does not take positions on legislation.

I would like to thank the FDA for providing me the opportunity to comment on the proposed tobacco product standard that would regulate nicotine yield by establishing a maximum nicotine level in cigarettes and other combusted tobacco products. I appreciate this opportunity to provide my perspective as a health care practitioner and policy analyst.

Nicotine is the addictive component of cigarettes, but by itself is relatively harmless. The harm comes from carbon monoxide, a poisonous gas, and tobacco tar that contains carcinogens and other chemicals that harm the lungs and circulatory system. Britain’s Royal Society for Public Health claims nicotine is “no more harmful than caffeine.” One of the characteristics differentiating nicotine from caffeine is that nicotine has both calming and stimulative effects.

Tobacco cigarettes are a type of nicotine delivery system. While some smokers may enjoy the flavor of tobacco and the act of smoking, many primarily smoke for the effects of nicotine.