19 Jun 2014
In April the FDA took a big step towards regulating cigars in a way that could be devastating to the handmade cigar industry, and initiated a public comment period that will run until August 8. With time running out to submit your comment, here are a few tips to use when you register your comment here.
Don’t Lose Sight of the Goal
The point here is to protect cigars, not just vent anger at the FDA. If your comment includes lots of words in ALL CAPS, multiple exclamation marks, or frequent references to nazis and fascism, it may make you feel better when you hit submit, but it will probably be more easily dismissed by the bureaucrats at the FDA. Unfortunately, the FDA has already been granted the authority to regulate cigars, so the only questions now are if it will use that authority, and, if so, what form the regulations will take and what exemptions the FDA may create.
Don’t Bury the Lede
I doubt I’m going to single-handedly disillusion any readers about our government here, but odds are your comment won’t individually get a careful, thorough consideration. Rather, the FDA uses the comment period to hear from prominent stakeholders and to generally gauge the opinions of those who take the time to comment. So be clear upfront about your position. And feel free to repeat it at the end.
Emphasize the Key Points
Cigar Rights of America has a helpful list of message themes here. You should definitely read the whole thing and feel free to borrow from it while writing your comment. (There are no extra points for originality.) To their excellent points, I would add two additional ones. First, there is no reason for treating flavored or infused cigars differently from non-flavored premium, handmade cigars (for more on that point check out this piece I wrote a few weeks ago). Second, given the FDA’s limited budget and the fact that it has only ruled on 34 of thousands of outstanding new tobacco products waiting for approval, the agency’s resources would be better off focusing on products other than handmade cigars. Of course, most of all, be sure to point out that you are a responsible adult who smokes in moderation.
Pause Before You Hit Submit
Proofreading is important. A comment full of spelling or grammatical errors or, worse yet, sentences that don’t make sense, will undercut your message. As someone who edits quite a bit of writing, I can tell you it’s always tougher to edit and proof your own writing, so don’t hesitate to ask a friend to look it over.
Don’t Wait Until Tomorrow
A rhetorical masterpiece complete with citations to relevant scientific research is great if you can pull it off, but lets not kid ourselves: This is in large part a numbers game. A short, to-the-point comment is infinitely more helpful than the long, in-depth comment you never get around to actually submitting. To that end, if you know someone who would be willing to submit a comment but probably doesn’t have the time to write it up, send them a comment they can use along with the link where they can submit it.
photo credit: Stogie Guys