HomeMy WebLinkAbout4F - Tobacco Ordinance
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STAFF AGENDA REPORT
AGENDA NUMBER:
PREPARED BY:
SUBJECT:
4F
FRANK BOYLES, CITY MANAGER
CONSIDER APPROVAL OF ORDINANCE 97-XX
AMENDING THE TOBACCO ORDINANCE TO
BRING CONSISTENCY WITH FEDERAL AGE
REQUIREMENTS
APRIL 7, 1997
DATE:
BACKGROUND:
At the March 17 meeting Council Member Schenck
suggested that amendments were needed in the City Tobacco
Ordinance to bring it into consistency with Federal
requirements. This agenda item would accomplish this
objective.
DISCUSSION:
Enclosed is a draft ordinance amending the Tobacco
Ordinance. The amendment would change the age
requirement for the purchase of tobacco. The current
ordinance requires of proof of age from persons 25 years of
age and under. The amendment is consistent with the
Federal requirement and requires proof from those 27 years
of age and under.
ISSUES:
The Council is required by law to bring the ordinance into
compliance with Federal requirements and age limitations.
Additionally, there is a body of FDA tobacco regulations that
ultimately may effect the City's Tobacco Ordinance. For
example, it may be that the city's ordinance prohibiting all
vending machines could, without a waiver, be preempted by
FDA regulations which allow that vending machines can
only be eliminated in those places where no one of 18 years
of age is allowed. Enclosed with this agenda item is
information on this subject. The City Attorney will continue
to research this matter and advise the Council should further
amendment of this ordinance become necessary.
16200 ugi04€r.o:k Ave. S.E., Prior Lake, Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245
AN EQUAL OPPORTUNllY EMPLOYER
AL TERNATlVES:
RECOMMENDATION:
ACTION REQUIRED:
REVIEWED BY:
47974F.DOC
1. Adopt ordinance 97-xx as proposed.
2. Defer action with direction to staff.
Alternative No.1, which will bring the City's tobacco
ordinance in conformance with FDA requirements.
Motion and second as part of the Consent Agenda to adopt
Ordinance 97-xx amending the City's tobacco ordinance with
respect to age limitations.
art.
Q3/25/97 17:14
'6'612 405 9845
CAMPBELL KNlITSON
141 002
ORDINANCE NO. 97-
CITY OF PRIOR LAKE
SCOTT COUNTY, MINNESOTA
AN ORDINANCE AMENDING TITLE 3, CHAPTER 13, OF THE
PRIOR LAKE CITY CODE REGULATING THE
SALE OF TOBACCO-RELATED PRODUCTS
THE CITY COUNCIL OF THE CITY OF PRIOR LAKE ORDAINS:
Section 1. The Prior Lake City Code, Title lbree, Chaptcr 13, Section 3-13-3, paragraph 8. is
amended. by changing the age specified in the pardgrd.ph, tu read as follows:
3-13-3: LICENSE REQUIRED:
8. Instructional PTolmlm. No person shall be issued a license or renewal license to sell
tobacco~related products unless an applicam or license holder has an approved program for instructing
all employees at the business premises for which the license was issued, in the legal requirements
pertaining to the sale of tobacco-related products. including, but not limited to, reviewing the law on
the sale of tobacco-rclated products. providing information on the health risks of using tobacco-related
pruducts, and requiring employees tn request jdentification from every cu.stomer who appears to be
under 27 years of age. No license shall be issued unless the applicant or license holder signs a City
form attesting that each employee of the applicant or license holder has received Lr.tining and instructiun
on the sale of tobacco-related products and Lhe date such training occurred. The training shall include
information that the sale of tobacco~related products to minors is illegal, explains what proof of age is
legally acceptable, and that a sale to a minor can subject the applicant or license holder and their
employees to criTT1inal and/or civil liability .
Section 2. This ordinance sball be effective immediately upon it.c: passage and publication.
PASSED AND DULY ADOPTED by the Prior Lake City Council
this
day of
,1997.
CITY OF PRIOR LAKE
BY:
Lydia Andren
Its Mayor
ATTEST
Frank Boyles, CitY Manager
4B6lo6
03/26/97 WED 09:04 FAX 612 452 5550
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raJ002
LMC
145 Univenity A,.enue West, St. Paul, MN 55103-2044
phone: (612) 281-1200 · (800) 925-1122
Fax: (612) 281-1299 · TDD (612) 281-1290
L-g1UI 0/ Minn..a'" C;tiu
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FDA Tobacco Regulation Summary
Briefing Paper
1. What are the FDA tobacco regulatioDs?
The FDA tobacco regulations were adopted in the August 28, 1996 Federal Register and signed
into law in October 1 ~96. They arc an attempt by the Food and Drug Administration to reduce
youth aecess to, and use of, cigarettes, eigarette tobacco, and smokeless tobacco by establishing
tight restrictions on the promotion and sale of such products. The FDA adopted the regulations
pursuant to its powers under the Federal Food, Drug, and Cosmetic Act. At the current time, the
regulations do not extend to other tobacco products or related devices such as cigars, pipes, and
lighters. .
2. What do the FDA regulations require/prohibit, and when do the regulations take effect?
With regard to cigarettes, eigarette tobacco, and smokeless tobacco, the following regulations
have.been adopted:
Effective Februarv 28. 1997:
- Prohibit sales to anyone under the age of 18;
_ Require photographic identification as proof of age for anyone 26 years of age or
under.
F:ffcctive Au~ 28. 1997:
- Ban on free samples and the sale of individual cigarettes or packs of fewer than 20;
_ Ban on vending mac;hines and self-service displays, except for limited types of
establishments where persons under the age of 18 are at all times prohibited from
entering the establishment;
_ Ban on outdoor advertising (including windows) within 1,000 feet of schools and ..
publicly owned playgroundS; .....
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AN EQUAL OPPORTUNITYI AFFIRMATIVE AcTION EMPLOYER
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OJ/~6/97 WED 09:04 FAX 612 452 5550
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- Only black-and-white text advertising allowed for most other advertising, including all
point-of-sale advertising;
- Ban on the sale or giveaway of promotional materials such as caps and gym bags
containing product brand names or logos for cigarettes or smokeless tobacco;
- Tighter labeling restrictions.
Effective August 28. 1998
- Ban on sponsorship of any sporting or other event, team. or other entry, if the
sponsorship identifies a specific tobacco brand (includes ban on symbols, etc. associated
with a particular brand name. Corporate name sponsorship is allowed.).
3. Who is responsible for enforcement and compliance?
The FDA regulations impose the burden of compliance on the manufacturers, distributors. and
retailers. Each manufacturer will be responsible for removing non-complying self-service
displays, advertising, labeling. and other non-conforming items owned by that manufacturer.
Retailers are also responsible for removing non-complying items from their stores, and are
additionally responsible for verifying the age of customers, refusing sales to anyone under 18,
and allowing sales only in the form of a face-to-face transaction where there is an actual
exchange of the cigarettes or tobacco between the clerk and the customer.
Only authorized agents of the FDA have the authority to seek the imposition of a penalty for
violation of the FDA regulations. The FDA is currently seeking to deputize select State
Attorneys General for enforcement assistance, and may seek additional deputies as needed.
Local law enforcement officials may continue to enforce local ordi~ces and in addition are
encouraged to notify the FDA of suspected violations of the FDA regulations. Such officers,
however, cannot directly issue a citation for violation of the FDA regulations.
4. What is the penalty for violation of the FDA regulations and on wholll can it be
imposed?
The general penalty under the FDA tobacco regulation will be a civil fIne of $250. However.
seizure of unlawful items, injunctions, restraining orders, additional fines. and possible
imprisonment are also potential penalties. Penalties may be imposed upon any person convicted
of violating the regulations. Employers can be held liable for the actions of their employees.
Penalties under the FDA regulations may be imposed in addition to any penalty imposed for
violation of a local regulation.
03/26/97 WED 09:04 FAX 612 452 5550
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S. What is the impact of the FDA regulations on local ordinances?
The FDA has made it clear that they want to encourage local units of government to continue to,
adopt and enforce local regulations that have the effect of furthering the prevention of youth
access to cigarettes and tobacco. However, under the provisions of the Federal Act authorizing
the regulations. any provision of a local regulation that regulates in a different manner any matter
covered by the FDA regulation is preempted. Provisions that are identical or substantially
similar to the language contained in the FDA regulations are not preempted. nor are provisions
governing issues not directly addressed in the FDA regulations.
J
Examples of preempted ordinance provisions include complete bans on vending machines and
self-service restrictions that are not a complete ban on such transactions. On the other hand.
general licensing requirements are not preempted as the FDA regulations are silent on the issue
of licensure. Further. an ordinance provision prohibiting the sale of cigarettes to anyone under
the age of 18 would not be preempted as such a provision mirrors the FDA requirement. Penalty
provisions are also specifically exempt from preemption.
A waiver process has been established to allow local regulations that arc more restrictive than the
FDA regulations. or for which the local unit of government can demonstrate a compelling need
based on the unique circumstances of that particular entity. The League is working with
representatives of the Minnesota Attorney General's office and the Minnesota Depamnent of
Health to 'develop a coordinated waiver application process for cities with ordinances containing
preempted language. A preemption review guide and model waiver application form will be
made available to cities by late March or early April. May 6, 1997 has been set as the deadline
for priority review of waiver applications and it is hoped that a coordinated application on behalf
of at least a majority of cities in need of a waiver can be submitted by that date.
6. Isn't there a pending lawsuit over the FDA tobacco regulations?
Coyne Beahm, Inc. et a1. V. United States Food &. Drug Administration and David Kessler was
filed in Greensboro, North Carolina seeking an injunCtion against the regulations as "vell as a
finding the FDA lacks authority to regulate tobacco. and that the regulations as adopted are
unconstitutional. A hearing was held on February 10 seeking a preliminary injunction blocking
enforcement of the requirements but no immediate order was granted. At least a pre1imin~ry
ruling is expected in April. Even if the regulations were to be enjoined or held unconstitutional
in North Carolina, which is in the fowth federal judicial district, the FDA may elect to continue
enforcement in other districts such as Minnesota, which is in the 8th federal judicial distric~ until
such time as a Supreme Court ruling is issued or further successful challenges are made in other
judicial districts.
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7. What sources of information are available?
As it becomes available, updated information will be placed in the League Bulletin. Information
may also be obtained by calling the FDA hotline number, 1-888-FDA-4KIDS (1-888-332-4543).
In addition, the Tobacco Control Resource Center at Northeastern School of Law in Boston has
established the "FDA Exemption Clearinghouse" to assist cities with the preemption waiver
process. Clearinghouse iDformation can be obtained by calling Bob Kline at 1-888-FDA-
EXEMPT (1-888-332-3936).
Web sites on the Internet that contain helpful information, including downloadable copies of the
actual FDA regulations include the following:
www.fda.gov
www.tobacco.neu.cdu (Clearinghouse homepage)
www.ash.org
www.'[obacco.org
As always, cities may contact the League directly with any questions about this issue. The
contact person for questions about tobacco issues and the FDA regulations is Kent Sulem. LMC
Codification Attorney, a.t (612) 281-1245.
Prepapred by: Kent Sulem
03/25/97
17: 14
'a'612 405 9845
CAMPBELL KNl~SON
1aI 003
FDA tobacco regulation pre-emption update
;,-.....
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Kent Sulem
Thc February 12 Citi~s Bullerin
provided ll. SUUUlIliI)' of the new FDA
tobacco along with a warnin~ to citic!;
about the possible pre-emption of
cerlain local tobacco-related nrdi-
nanceS and the neerl or cities to seek a
waiver of pre-emrtion from the: FDA. .
While final de~,ils are still being
discussed, The League has obtllined
additional information 3$ to who will
need to seek a waiver and how the
waiver process will worle.
First, only those provisions of a
local tobacco ordinance that provide
for a different regulation on II matter
expressly covered by the FDA regula-
tions will be considered pre-empted
without 11 waiver. Provisions not
regulc.ted by the FDA or that impusl::
the SIUl1C re8trlctions as the FDA
regullltions arc not pre-elllplcd. In
other words, a city ordinaJ'Jl.:t: prohibit-
ing anyone under the age uf 18 from
selling tobacco produc~ would not be
. pre-c:mpted by UJe FDA regulations
since those regulat..iuns do not address
the age of clerk::;, Similarly, a local
ordinance prohibiting the sale of
individual ciglU'l!:ttes would not be pre-
empted as ::luch a restriction would he
identicallu the provision in the FDA
regulaLions. On the other hliJ1d, a
complete ban on vendi!", mlll.""hines
would be pre-empterl without a waiver
since the FDA reeulations Will allow"
~dinl! machines 1n certain busi-
-"esses. provided that no one under
the age of 18 i!lllJlowed in the:-
establishment.
Difrerences in penalty provisions
are exempt from the scupe of possible
preemption. Also, contrnry to original
report.;, a local ordinance will not be
pre-empted !limply because it fails to
address an ~a the FDA has decided
to regulate. Vendors, however, will still
need to comply with the I;DA regula-
tions. Law enforcement agents wil1 be
ei>pected to enforce the FDA l'egulay
tions in the: S\arnc mannel' as any other
state or feder-.d law.
If a local ordinance does not
regulllte an area covered by the FDA
regulations, advertiSing for example,
re"to,
..,
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.,-
the city may elect to adopt the FDA
language and enforce the requirements
through their local ordinances. Cities
may alsu elect to amend their ordi-
nances to require compliance wilh the
FDA regulations as conditiull uf
licensure and provide for lht: denial,
suspension or revoclitiun of a llcensc
upon violation or the' FDA regulation!l.
l'inaIly, cilie~ may elect to simply Iceep
their local ordinances separate from
the enforcement of the FDA regull1-
liuns provided no pre-emption c"ists.
Any city that has R lobacco
ordinance, should review the provi-
sions of that ordinance against the
summary of rhe ~DA regulations in the
February 12 Cines Blll/atin to see if
allY differenceS e"ist that might subject
the ordinance to pre-emption. The
Ciries Bulletin will inr:lude any
additional information for making this
(lelc:.rminilLion as it becomes aVllilable.
In the meantime cities should consult
their city attomeys. As alwllYs, the
League is happy to answer questions.
It is unlikely, however, that there will
be time to review each city's indi-
vjdual ordinance. The FDA will
provide fOnnalletter rulin::s on pre-
emption questions, but there is likely
to be a significant delay in response
given the anticipated backlog brougln
on by review requc;sts coming ill from
across the: nation as the FDA lCt(ula-
tions take effect.
The Tobacco Control Resource
Ccnter at Northeastem University
School of Law in .BUllllUn has estab-
lished the "FDA Exemption Clearing-
house" as a n::sourcc for local units uf
govemmenL tu ubtain infomlatioIl
about the FDA regulations, huw to
determine if an ordinance is pre-
empted by the regulation~ lln(l, if it is,
how to seek a waiver. Bob Kline of the
Clearinghouse contacted the League
llnd has offered to e"tend his
organi7.ation's reSOUl'ces to Minnesota
cities. The Cleal'inghoulle eiln be
reached by calling toll free (88g) FDA-
Ex..EMPT or (888) 332-3936. InfonDa-
tion can also be nbtained through the
Clearinghouse'~ website at
Page 7
March 5,1997
www.tobll.cco.neu.edu.Mr. Kline hIlS
alrcal.l iven the League a model
application that COli e use or
requesting a pre-emption waiver from
the FDA.
Leagne sfaft' will be meeting with
the MiMCSOta Attorney Gener.sl's
oftlce on March IOta discuss a
coordinated waiver appliclltion to the
FDA, which is the FDA's stated
preference. It appeurs, however, that
even in a coordinated application,:~
individual city in need of a wavier will
~ve to suP~. ce~~n info1'1u&liqn.
Because Ii May 6 deadl.inc hlCi bt!en 01-
imposed for receiving priorilY review
of waivcr applications, cilielii that
believe they may need a waiver are
encouraged to be~ill cullecting the
following infofUlliliun:
. A copy or all minutes in which liJ1Y
discussion Icll.ding to the adoption of
the tobliCCU ordinance is recurded.
. Any inlerpretation of the local
ordinance that may have been
iSsued.
. A listing of all provision!; nf the
urdinance that may trigger pre-
emption.
· An explanation uf why the city
adoptecl the provision(!::) subject to
pre.emption.
· A summary uf how the provision(s)
is either mure re!::tric:Tiv~ than the:
FDA regulation, or the compelling
local conditions that require that the
provi~inn and not the conflicting
FDA regulations be enforced.
. The nAme of the primary person
responsible for administration of the
ordinance.
The standard of review the FDA
will use in grnntillg a waiver will be to
see if the local ordinance provision is
in fact more restrictive than chI:; FDA
regulation or, if it is nOt. whether there
is a compelling need for the local
regulation in.,tcad of the FDA regulli-
tion. Waivers are expected to be
granted fairly liberally.
Please contact Kent Sulcm. LMC
codification attomcy, at (612) 281-
1245 if you have any question~ ahom
this issue. ~
03/25/97
17:15
'5"612 405 9845
CAMPBELL KNlITSON
141004
FDA tobacco regulations affect city ordinances
Kent Sulem
In October 1996, President
Clinton signed into law the most
restrictive regulations on tobacco ever
adopted. Promulgated by the Food and
Drug Administriltion (FDA), thcse
n:guhllions (all 250+ pages of them)
seek to rt:uucc yuullt liCCL.:::IS [0 lOlJa.CCO
and underage smoking by restricting II
number of practices perceived to
influence a minor's decision to smoke.
The neVI l'ules impose a number of
new requin:ments and restrictions all
retailerll, ranging from proof of age
requirements-to banning certain type!>
at' St\IcS".fO restricting rhe Ir:u::ation of
tobal;'cQ advenising. In addition, hy
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Another way to
stay in touch
Remember, you can
reach LMC staff using their
e-mail addresses.
Staff e-mail and ptlone
numbers are listed in the
Directory of Minnesota City
Officials and on the LMC
home page www.lmnc.ory.
For more information call
the League of Minnesota
Cities Communications
Team (612) 281-1200.
August 1998, tobacco companies will
be barred from brand ,name sponsor'.
ship of spOfting and entertainment
cycnts.
Two of these new federal regula-
tions are of immediate importance to
cities. EffcctiVt: February 28, 1997. it
will be unlawful for any retailer to sell
eigan::llc::s ur smokc::less tobacco lo any
per.;nn under the age: of 18. In addi-
tion, retailerll will he specifically
required to check phnrngrnphic
identification as proal" of age r'or any
person undel' the age of 26. These two
regulations give cities additional tools
to combat the problem of under.1ge
smoking. It ili importOlnt eities that
have adopted their own tobacco
ordinances to now update thelie
ordinances to include the new federal
. regulations.
A coun challenge has been made.
to the FDA regulations in the founh
federal district in North Carolina. A
hearing WIlS held un Monday, Febru.uy
10, seeking a preliminary injunction
on the enforcement of the two regula-
tions set to take effect on February 28.
Even if granted, however. the injunc-
tion would not apply to Minnesota. It
could, however, lead to an injunction
by the U.S. Supreme Court, or to local
challenges. Further, the ultimate ruling
on the FDA's authority to regulate
tobacco and whGthcr or not the
adopted regulations arc corustitutional
will have a major impact ~gardless of \j
the final ycrdict,
Cities also ueed to be aWI:lI\: lhal.
the federal statute authorizing the FDA
regulations inauve1tently cn:ated a
preemption of suml.': forllls uf local
regulations. Jt is nut, nor has it been,
the intcnL of the PDA to prohibit local
reeulatinnl'i. To resolve possible
proolems, il pret:mption waivl;;r process
is being developeu. Unfortunately,
final approval has not yet been given.
Lherefore, the League cannot provide
sny 8pecific infonnation at dUs time.
FDA source!;, however. have indic3.ted
thaI a waiver will essl!utially be
automatically granted to any local
ordinance that is at least as restrictive,
Page 6
or which is essentially similar to, thE
new foDA regulations on tobacco_ To
ease the process, the League is
working with the MiJlllc~ola AtlOlTlL:)'
Gcm.:ral's Oml~C tu cuun.Iinl1lc all
waiver appHcations, The League will
inform cities when the waiver process
is leady to begin. Tn the meantime,
cilies with existing ordinances should
conLinue to enforce [hem, and cities
cnnsiuering auupting a new tobacco
O1"chnnnce !'ihnulc.l nnt abandon the
process.
The FDA recemly mailed (I
preliminary compliance g\lid~ for thl~
new regulations to major retailers
acro~s Lhe nation. A more l;'ompr/;'hcn-
liive guide is expected to be inilable
this week. The FDA is posLing all
publicatinn!; ()n their Internet site.
www.fda.gnv. Tn addition, publi(;ll.tions
can be orderecl by calling (RRR) FDA-
'11<.10 l(l~88) 332-4543J.
The League will r.:ontinue tn
monitor all developments and will
provide citieo~ with updated informil-
tion as it becomes ::I.vailable. In the
mcantime. the next date to be aware l1t'
is August 28,1997, when th~ t"ollow-
ing regulations become effective:
Bon on free samples and the sak
of individual cigarettes or packets
of fewer thun 20.
Ban on vending machines and
self-sl;rvice displays. e)(.cept
for limitl;d "adults-only"
establishments.
Ban on outdoor advertising within
1,000 feet of schools and publicly
UWllcd playgrounds.
Only lJlack-nnd-white tcxt
auvel1i.sillg allowed for any other
outdoor ac.lvertising and all point.
of.sale adverti.sing.
Ban on the sale or giveaway of
promotional m:ucrials such llS
cap~ and gym bags containing
product brdlld names or logos for
cigarettes ur smokeless tobacco.
If you have any questions about
the FDA regulations or ulher issues
rt!1ating to tobacco and youth access,
pleas!:: call Kent Su)em. LMC Codifi.
cation Altorney, at (612) 281-1245."
LMC Cities Bulletin