May 2, 2015
On Saturday May 2, 2015, San Diego State University held its 6th annual campus wide cigarette butt clean-up event. More than 32 volunteers participated in the event and picked up 14,063 butts in 1 hour. This averaged out to approximately 439 butts per person collected from different locations around campus. Over the last 6 years, there have been 114, 769 butts collected from these events. Although a campus-wide no-smoking policy is in effect, we still didn’t see a significant decrease in the amount of cigarette butts collected from around campus. The map shows how the campus was divided into zones and how many butts in each area were collected over the years. The hot spots for butts was near the bus/trolley stop, library and international language school. The campus has increased the amount of signs around campus stating that the campus is tobacco-free, however enforcement is minimal at best. We hope the data collected from these events will help the university to put into place better enforcement strategies to assist in making SDSU truly a tobacco-free campus.
Campaign Kick Off Event
Join us on November 20th (The Great American Smokeout) to launch our kicking butts campaign. We will learn more about what is happening to help get rid of cigarette butts from our environment and how we can partner to tackle this huge problem. There will be hors d’oeuvres, drinks and great discussion to kick off our upcoming campaign. Please join us on November 20th from 6-8:30pm at 3035 Talbot St. San Diego, CA 92106. RSVP to Heidi at email@example.com
A new rule is being proposed that will allow the tobacco industry to regulate themselves on environmental impacts of tobacco. Comments on the proposed rule are due by April 8, 2014. We have drafted our own comments and would like to share them with everyone and hope that you and your organization will adapt them and comment as well.
Here are our comments:
March 19, 2014
To: FDA, via its Center for Tobacco Products
Fm: Tom Novotny and Clifton Curtis, Cigarette Butt Pollution Project
Su: Comments on FDA proposal to exempt tobacco waste related actions from Environmental Impact
Statements or Environmental Assessments, and to instead authorize the tobacco industry to take the lead in addressing those issues – 21 CFR Part 25 [Docket No. FDA-2013-N-1282]; NEPA; Environmental Assessments for Tobacco Products; Categorical Exclusions
Core Issues: The FDA’s Center for Tobacco Products is proposing a new rule that would exempt certain tobacco-related actions from having to prepare Environmental Impact Statements (EIS) and/or Environmental Assessments (EA). Instead, it would allow tobacco product manufacturers to submit Substantial Equivalence (SE) applications without an EIS or EA. The proposed rule reflects the FDA’s decision that, as a matter of policy, new tobacco products approved through the SE pathway do not significantly affect the quality of the human environment. While FDA would still retain discretion to require an EIS or EA for a particular action even though it is in the class of actions that are being exempted, as a general rule those exemptions would apply universally.
The proposed rule needs to be rejected as it defies sound policy on two fronts:
- First and foremost, for decades the tobacco industry (TI) has lied, misrepresented and hidden facts and relevant information regarding the adverse impacts of its tobacco products, and it should NOT be given authority or responsibility to prepare decision-documents regarding the environmental impacts of those products; and
- Second, while new information on the environmental impacts of tobacco product manufacture and disposal (tobacco product waste or TPW) is needed to assess potential health impacts from environmental contamination, consistent with the precautionary principle, there is sufficient information to warrant closer scrutiny. The environmental impacts of tobacco product manufacture and disposal are best addressed by having FDA retain the lead role in preparing any necessary EIS’s or EA’s.
FDA vs TI: Regarding the TI’s role in addressing EIS and EIA matters, the civil law suit of U.S. v Philip Morris’ final opinion by U.S. District Judge Gladys Kessler in August 2006 states the obvious, that for decades the TI has survived and profited from “selling a highly addictive product which causes diseases that lead to a staggering number of deaths per year, an immeasurable amount of human suffering and economic loss, and a profound burden on our national health care system. [They] have known many of these facts for at least 50 years or more. Despite that knowledge, they have consistently, repeatedly and with enormous skill and sophistication, denied these facts to the public, the Government, and to the public health community.”
Going forward, the Framework Convention on Tobacco Control (FCTC), which entered into force in 2005 and currently has 177 Parties from all regions of the world, makes it clear that governments need to be very circumspect and cautious in their dealings with the TI. As set for in Article 5.3’s “General Obligations”, the Convention states that “in setting and implementing their public health policies with respect to tobacco control, Parties shall act to protect these policies from commercial and other vested interests of the TI in accordance with national laws.” While that statement references governments’ public health policies, the diverse environmental impacts resulting from TI practices likewise necessitate governments acting to “protect” those policies, especially given Article 18’s parallel interest and concern in calling for the protection of the environment.
National Environmental Policy Act (NEPA) Standards: Regarding NEPA standards and procedures related to the preparation of an EIS or EA, we question the statement of David Ashley and Hoshing Chang that TPW is individually and cumulatively trivial in the context of making a determination that the environmental impact of that TPW “may significantly affect the quality of the human environment.” Among the 15 referenced source materials provided at the end of the proposed rulemaking statement, reference 13 affirms the toxicity of butt waste leachate on saltwater topsmelt and the freshwater fathead minnow. Taking into account the precautionary principle, preventive, anticipatory measures are called for when an activity raises threats of harm to the environment, wildlife or human health, even if some cause-and-effect relationships are not fully established scientifically.
Clearly, additional research is needed to explore the actual risks that TPW pose to human and animal life. As also noted, the growing of tobacco and manufacturing of cigarettes may result in a variety of pesticides, herbicides, insecticides, fungicides and rodenticides being deposited into the environment. Additionally, 4,000 chemicals may be introduced to the environment via TPW, third-hand, and second-hand smoke. Those include chemicals such as carbon monoxide, hydrogen cyanide, nitrogen oxides, polycyclic aromatic hydrocarbons, ammonia, acetaldehyde, formaldehyde, benzene, phenol and others, over 50 of which are known to be carcinogenic to humans. Absent solid proof that these and other toxins are insignificantly impacting the environment, when neither the individual or cumulative studies have been given adequate attention, it’s very risky to just declare those risks as inconsequential. Moreover, one could reason that in such a situation, an “exceptional circumstance” might well be recognized as meeting the “may significantly affect” threshold unless and until sufficient studies to make those determinations have been carried out.
For these reasons, we ask the FDA, through its Center for Tobacco Products, to reject the proposed rule.
Respectfully submitted on behalf of the Cigarette Butt Pollution Project,
San Diego State University (SDSU) is one of the many California campuses going smoke free! SDSU will be implementing a new campus-wide smoking ban after getting the green light from university President Elliot Hirshman. The smoking ban was approved by the University Senate in April and has been under review by employee unions on campus. According to Assistant to the Vice President of Business and Financial Affairs, Nancy Demich, the ban is moving forward into the implementation stage. The smoking ban will go to a committee headed by Associate Vice President of Operations Robert Schulz in the first week of October to work out logistics. Go to the Daily Aztec to read the full article by clicking here.