CURRY COUNTY BOARD OF COMMISSIONERS AGENDA ITEM ROUTING SLIP FORM 10-001.1 Revision 3-22-2018 PART I-SUBMITTING DEPARTMENT: RETURN TO BOC [email protected] PROPOSED AGENDA ITEM TITLE: CCH tobacco business license

TIMELY FILED Yes~ No 0 If No, justification to include with next BOC Meeting

AGENDA DATEa: , 10/10/2618 DEPARTMENT: (aSubmit by 9AM five days prior to the next General Meeting (six days if a holiday falls within that five day period)) RECOMMENDED AGENDA CATEGORY DISCUSSION ONLY

MEMO ATTACHED Yes 181 No D If no memo, explain: CONTACT PERSON: Clark Schroeder TODAY'S DATE: 10/4/2018

BRIEF BACKGROUND OR NOTE: Brooklyn Wease is the Tobacco Prevention and education program coordinator at Curry Community Health. She is going to discuss the idea of a tobacco business license for Curry County

FILES ATTACHED: (1) Ms. Wease handouts (2) (3) INSTRUCTIONS ONCE SIGNED: ~ No Additional Activity Required OR D File with County Clerk Name: DSend Printed Copy to: Address: DEmail a Digital Copy to: City/State/Zip: DOther Phone: Note: Most signed documents are filed/recorded with the Clerk per standard process.

PART II - COUNTY ADMINISTRATOR REVIEW 181 APPROVED FOR BOC MEETING O Not Approved for BOC Agenda because

ASSIGNED TO: DISCUSSION ONLY

I Tobacco Retail Licensing

An Effective Tool for Protecting and Promoting Public Health

What is Tobacco Retail Licensing?

A tobacco retail license (!!il) is an effective tool used by communities to ensure retailers comply with safe and responsible-- tobacco retail practices, much like a liquor or cannabis license. TRL is a way to regulate businesses by ~ quiring all tobacco retaile, s to obtain a license in exchan g_e for th~ vilei;\£,f selling tobacco products. This provides for improved public health and safety by reducing youth access ~ obacco and ensuring that businesses comply with local, state, and federal tobacco laws. In Oregon, there is no state-wide tobacco retail license requirement for selling tobacco products. However,- several counti~ in Oregon are passin~ their own !Q bacco retail licensing ~ dinan£_es . - Elemen- ts of IBL; ~ The fees for a local TRL ordinance would be calculated based on the approximate cost of administration, monitoring, and enforcement, balanced with the number of tobacco retailers within the jurisdiction. For a list of potentia'16ffi's\see ~ \,\ow .,y\e..~'\ Mt. ~ C..'1<<'\ (e"4 '? Administration. Monitoring, and Enforcement: Specific agencies would be chosen to be responsible for th e administration, monitoring, an d enforcement of TRL. This should be based on which agencies would be best suited for and have the means to adequately perform the specified tasks of administration, monitoring, and enforcement.

Penalties: Discretionary 2.1" rri andatory, these penalties could include fines, license suspension, or license revocation.

Additional options for TRL:

A tobacco retail license can provide an ~ portunit) for tobacco retaile':.:..to receive training as part of licensure. TRL can also include additional poliSY plug-ins (seee{lpend,x]lwhich can help reduce the negative public health impact of tobacco, such as prohib iting tobacco retailers nw locations frequented by children (e.g. k-12 scho,Q) s), requiring a minimum distance between tobacco retailers, or banni~ the :!le of flavored tobacco product s.

What's being done in other counties in Oregon?

The following comes from a survey (seee:ndix Salem, Silverton, and ~ ingfiajs!) which have ~ enacted local TRL ordinances: r\c,~ W\'~'\ Jlrt-~•~'f• ~~\\enf '1-JV\l •.Ua.d. f~ ( 1 ('~o)~.11$ •

Fees: The fees of the nine jurisdictions ranged from $10 annually to a ~73 d9 initial fe,e and ~ ____.. ~ renewal. With an approximated $85 cost------per retail inspection, none- of the jurisdictions' fees were e--.!:!2ugh to cover the recommended- 2 i,U; pections ~ r. -- Administration, Monitoring, and Enforcement: ~ dictions ~ @iliigleilto administer, ~ r, ~ ~ e ~ because off!!!ae qua!Jadministration~ ~ a ~ seecificj!y i!J regan1s t,;> ageng res ponsibifily. 4' i't.t~ ..\-o ~"'cct•~ .Sao~ . ,,,~qtA ,.,"~"""·~~ •""'b' 4~~n \"'°'"c"+~•" ~ ~~u.-..5d (~~'1 o\vlf&J~~) Ce~ -h t.of\~v""'fM E'>t~~r\!: \oo'\\U \o~\\ ,cA,tt'I\ - V\"'~t t~ 1 Penalties: Most jurisdictions have a standard, graduated penalty structure which imposes a monetary fine for the first violation and possible license suspension occurring after repeat violations within the "look-back" period (typically 2 years).

Klamath and Multnomah Counties have also enacted a local TRI prdinance (seef pp; ndix D]

Curry County ~ Tobacco Use:

According to the Oregon Health Authority's 2017 Healthy Teens Survey,

!.. 7.4% of 11th graders in Curry County smoked a cigarette (including menthol) in the past 30 days.

• 12.5% of 11th graders in Curry County used any tobacco (including vaping products) in the past - 30 days. • 50.6% of 11th graders in Curry County had seen an advertisement promoting tobacco or a vaping - product in a storefront or store in the past 30 days . TRL in Curry Count'£:

Like other jurisdictions in Oregon, Curry Cpugty can join the ~ to reduce the negative public heal!_h S£nseguegces o.,! tobacco use. A tobacco retail license in Curry County can help P-rotect and~ ~ e health of the community, promote com pliance with 12£il l, ~ ' and U:9eral laws related to the tobacco retail environment, and reduce youth access to tobacco.

2 Appendix A

Buageting for a Local obacco Retailer License Fee in California A Checklist for Cities and Counties

Tlte effect,vcncss cf a y iOCJI Ca11forn1J tooacco retailer license ( RL) ordinance depends iilrgely en ('nforccment. The bill y to hmd mplem('ntatton and enforcement is Urns Important to com mun1 ,es. ntcr('sted In adopting a TRL ordinance. Chan<;1e ab Solutions has developed a TRL ree CdlCul-,tor to nelp ,c,es ano counties de ermine an approprl.Jle fee hat JdC!'quatel•; supports the costs assoefated wftll ,mplerr.enting ,md en ore mg a TRL system. his ee ca lc11lator 1s iJVallabl at: ww.cnan9elsbr;o/u1/ons.orq/ cco-conl ror/trl ·f ee ·r:alculator:

Tills clleckll!.t has been preparnd to be used In con1unctlon with thl! TRL fee calculator thOuqh lt rnn also be used sep,3,rately as a re erence without using the calculator. It Is. dcs1qneo to llclp 1umdlct1ons h,n~ through all the costs assoc1a eel w,th a TRL ordinance. including staff ana non-staff costs (the la tter refcrrlng to costs suctl a.s fuel/ mileage, sapplll!s, overhead, etc.). hrs checklist s based on Change l ab So lutions.' lcaal analysis o perm,ss10,c costs that mily be recoupcel from a TRL fee. The 11st of tasks and budg~t line llems i>e.low snot meant lo be elhaust,vc. Each Jt.1rlsd1ctlon may have different costs associated v,lth lmplemen at1on and 1mforcemont.

Tilsk / Budqet Line Item I Type of Cost Comments

£STABLISH, MAJNTAIN, AND ADMINISTER TRL SVSTEM

r, gurc out , ·.,stem for Staff This ma•f nc lude the following: 2 ~u1n9 license~ • rlgur ng out Yhat dcpar mcnt and wll,ch staff ~ responsible for rcJch,n out t.o lhe ,s commun1Ly, illld whict, Clcpartment ,md wh,ch s a will ~ ponsib_Jt for iss\/J.P g r('nev.1ng/maiiiT.;n,n g hccnscs . • rt"gunng out how to coo~ bi:- tween aepa~ and staff. • F'lguring out Yhlch alvtslon or subdlv son wlthfn a department is responsible for tl'lc abo'le.

2 ,Compile! and rn.aj ntaJn list 2,1 Staff This mav lncludl' the following: pot ntial tobacco reta1ie!,s. • 'i2,J labo~ with the California Board ol EQuallzatlon (BO[) to obLlin a list of tobacco ret ailers. - • Checkm,9. the list from the 2 to see which cstab!Jshmgrus need a locgt TRL. This lnctudes cl'ctemiiri'ing ~establliflmerml rom the Bo t list 3re wltTirn •,ou~ Jurisdic tJ!ln ilnd ~ompa~ q t'Tie aotlist v,tith ¥,Our o,:!!.n locill ijslj>I fcioai:co retailers. - • Conducting onllne~ {e.g., GOO!]lfl, 'lelp) to com lete a~eensiVll 5.eilrch of e_otentlal tooacco retailers that re ulre a ocal . a Determin1----- g,g ~-- establi.!;hments ~ ..... er.;xcepti~ , if ilnv. • ~ ning pe.!!Q dlc repog s or ~ son exis ting tobacco retailers.

changelabsolut,ons.org Juno 2014

3 Establish Jncl ma1nta1n Sta( • This Is. the tcchnolo9'( co~t rclJted to cstabl1 . hJ.t.l g Jnd (!)airltdlillDQ an electronic d ed rcn1c d3 all,%c !or TRL dJld \h]!j(;. f hl!a. mayrncludc l1me/C05 s pent [D C5tJbll511 J databa~C from ~istcm -\\tN~• '? scrJtch or Incorporate into the 1umdtc 1on·s, ex ist ng databas.e or other types of licenses: and costs assoc.latl?d with ~ystMi updates or Im rovemcnt s. • he dJtilbq;c shauld nave tl'le )l lld,ltJ ~ ~ r r~ s ~ d all v101a t.!.9.!ls ~ r ach rtl,lllcr. ~ -----= Non starr The dty/county may outsource t!lls ta s;: instcaa or u~1ng its own employees.. In ~ that casl!, an ilmount can be budgeted unaer t1i1s lfnc Hl!'m (non·s.ta costs). 1---+--...------i-.'We»uu 4 C Proactiygly ~ the Staff ibis may mcludc the following: business community s that,. • Qllllng tiui;mcsl,g:; ano/orcommer'l'.e/ traol? groups, arn aware of the ffitl, 1ID. • E·malllag b.u slne~ and/or commerce/trade groups ([ncluding drafting, the ordinance (e.g., cffcctsve e· mall and attachments. if any). ~ . requirements, f~s/ penalties.) - • ~ending US Postal mail to businesses and/or commerce/trade groups (lncludlng raftfng letters or five.rs}. - • Attendmg communltv meetln s or meet.In-gs hosted by commerce/trade grou:ps <'!iiclmliiig rn tlng e ers or yers). • Conducting ln·person visits to businesses dlrectlv. Non·staff This may Inc lude-- the following costs: - • Calls •- Posta~ • Env alc.pe10Lf1 aesr ;""Mlleage/fuefLJuto tr-afl.Sp~ 5 Amw~1 gues lli2!1 S tJy ti StJff This may mcluoe> the following. ~us ,nc s~ comm~ · • ![lsw,: r1 qg retullcrs' que>st..1.Q ns whe~ • Answering e mails • Answer ;~g ~ ns 1n person wllen pe ?,£ e com,:,~ he~

6 Pfilare and d1sscm)natp Staff This may mc lude the following: mrorma11on allouc TRJ. •~ ra:!!!29 and d1ssemmatmg background IQIO!~ a.!;.d m5tructlom (gr ordlnance;prepare pp ymg for a TRL on the city/ coun webs te. ancl"ffl"ssemmate TRL • !fratt.ng and dissemlna mg background lnf_orrm:itjen and Instructions for appll cati"ons - 1pplvin"q for't'fRL t~rou2n mass di* tlo,,!! ·,ia US ~ ! al""ll41l i. - • Draftmg the a_EPllcation- lorm for license issuance/renewal. Non·statf Tl'lls'may inc lude the following costs: • Calls - •- Postagg • Envelopes/papSI, • Mueage/fuel/auto transport ~ =-- ' 7 Rece ,·,e and ~ Staff This mu '/ ,nc lucJe th e following. a~ ons for 1nicia1 • Pro cc s;,t09 pav:mtnt. license ssuancc • Cne"2'iZ1ng all applications. tor complctenc~s. and reacnlnq out to appllcants who - submit Incomplete forms.. • Cnec~in g cJch applicant 10 ~ that 1t meets thC' reQu ,rements ror rcc c,vin9. a license. • Coordmatmg w1t1, other depurtment~. as 3ppUcab lc (e .., Department of !:,~ 6!3,illl, F111an !i,S Dcmrr!ment, l!usme ~s License Department Police Dcp~rtment, ,ty Attorney·~ Off1ceJ. -

4 Non·staff This may include the following costs. • S,tl¥C: IQJ!;!.s/p~ er/cert1ficates -ffO'Jf9 ~, • !'ostage

9 Morn or f C!o~ S f~ I~ S!Jff This Includes tirne for mon,tor,ng rcta11crs i or li cense c~p,rat,on and renewa l ~ ~ - -....--., ..s~elf,J\1011 ~ renc:::t41 ~""'? 10 Prepjlre and ,P IHSrolna t,e Staff This may include the following: tnform.:ition/a epllcallon,s & • Draftlng r,:mjnd(lr/ lnstryctlollS for renc vi ~ which can be ~ through renewal ,ff ovfS '? ~ r;!2_ epst!!_ Jil4i!..., - - • Dratting and lssemlnating background lnformat1on 'and nstrycUons (qr ~ g IIC(l[)!j.l! on c y couflfy w~§sl t~.

Non·staff This may mcludc the following costs : - • Envelopes/paet'r lfe"ty ~ • Postage

11 and .£:OCC § S Staff Th-is may mc lu.dc the ro uowmg: - ~ c Jppli cat, gos for Il een ~ • Process,ng payment. renewal #fol)(S '? • Checkin g all a£ pllcations or completeness and reaching ou to applicants~ - subma 1ncomp etc forms. • Checking eacha ppl1Coln! to ensurc that ~ cc-ts l,.h.c requ,reme rl! s for rcce ,v1 n9 !§till- . ------, Coordina ting with gthcr depar tmen» . as applicable e.g., Department of ~'!,!!5 Health, Finance Department. Business L1c(ill_se Department. Police Department. '!'ityA t~ Olficet -

12 ~~a into and updati Staff This Includes l!WC [PC r1i>la Go.tf.¥-- '? ~ laba4e for~ lfewrl'. ~e ~~ I

This ·m·olve~ lnter;,39cnc •r coordination an may 1nctudc. as applicable : (1) Dcoa rt· ment D PubilcHealth; ( 2 ) r 1nJnce Department: (3) Bus1nt'SS License Dep;irtm t, {4l Police Department, Jndf o,-(~) f_! tY Attor nw O IC C. h .s mJ•r 1nciu e he ~ r~ different agenc,e,s...

14 r ' Prepare/ upda1c ~ Staff ;_9Hc,ctlo !;) !2,rrm. ~c,fs '? --- - 15 Prepilre/upd.:i,tr !:91J,_l es Q.r Staff '? This includes t~ for pr eparing !he rou tt;. tor e.:ich day's entorcement .Q pN at on ~. he buy operat,om "'?. ff,l,($ • 16 - Recruit and ~ youth Staff ~J'.l a~ c.!JjBG .. Hl>"rs? ->I.. ¥6)"~ 1:>et-f Non·stafl This may ,nc1ue1e the followl~ costs: - -e!l!nf1@ fo~ ufh doco~ nc!Q""_a_p-er_o_n_cA"' -1- ~ ~p ca..ro Ni• • ~ or youth de

changelabsolutlons.orq 3

5 This Includes _[ ~ for C.Qfl ducting cco op rations. Non·staf ----Th Is may include the following costs: • Equ,pmcnl/::.oftware/tcchnical supper used to illO enforcement effort' (e.g., ra bict, !ilptops, phones. S,2!J1£f i15, .JucJ10 dcv1ccs1 • Mllcage/fuc!/auto- transpon "' -

19 Ulldute database or This Includes rime for aa a entr~ en forcement/comp11ancc m um ENFORCEMENT: AFTER THE COMPLIANCE CHECKS

20 I ~ t~ llh ail fCfol!!,9 Staff This lnvolvcs. intcr·agenc coordination and may Include, as applicable: (1) Depart· errorffl"'el as neces1;ary ment of Pu · ( ) nance cpartmcnt, (3) Business Ljcen:-,e Depa~: to: l1 coordinate post· (4) Police Department: and/or {51 City Attococ~s Office. This may Include the ftrnc '""§T J?Lianc I! ch eek stratl! gx.; for trail)lAQ different agencies. w 4 and (2) nexr stl!ps for violators.

I 2] :_scparc 3nd ~ Staff Thts ncludcs the time for preparing Jncl dcllvcrmg violation notl!;£,5 ilnd/or ~ ­ ~ lation nolfcc; J.l•vrl "? ,..._.....tKes Of non·violatjgn (1. 4 ,.ccm gfli ffi13! 1~...~ ------1 Non·staff This may inc lude the fo llowing costs: ltc,urs~ • tnvelopes/papcr •, Posta ge

22. ~ prosec.u e/settle casg.s 1 Staff This .mav inc lude tlle foUowlng: He.,,s ~

Non-staff 23 Staff U,uB_1-----+------~, 24 :;..,.;;::;;::;;;~:i":'::::--1Staff This Includes lfme tor develggjnp a press release and handling media lngmr ji:s. _h."'-11L"'-~~·-i---,------r------~-----1 25 ~!lor reta1lers for license Staff Th[s may include the following. su!:.pens1on/ revocaf ,on - • Kee pmg trac:ko f retai lers!£r 11cense :;, uspcnsion/revocallon. ------1/eJB ~ • Suspendln9/ rcvok 1n ~ t~ . as appropr1a e (inc1ugmo time on iHlm1n,s rat!,X,.e !J.tarinn and co llaEio ill~ Hh different agenc,es, as appl,cable,. • 1nspecl,!!!9 estubhshments to ensur e. that re.la li !,;J;Sw,th suspended/revoked licenses .mfi1ofmjt mi toba.>-co produ c..t ie- ----,._. iii#_. Non·staff lfj\J(S- ? • Postage • "tl1lea.J1£.l~/auto transWi'L! r ~ ted to 1ns..Q ect1ons f~ 5_!:spended/rCVO i\Cel l!S£!J.C:S

6 Think Jbo t and rstt1bl1sh sytt'crr for co11ecflog/ tramfcrrmo r-evenue 28 I Procos.s fiscal clams to ~ rc,mbu~ partfcipa,nE T 29 Matc-r lJl/otner costs: This include!; 5Upplles a~ equipment not alrnady listeJ1. J,bo,.:i: e. miscellaneous 'upp11cs, cqu1pmenfi 30 Mater ial/other costs: This Includes overhead expenses not alr~ady listed above. ensC?s

This checklist was dc~eloped by Ctiangclab Solutlorc; wi t funds rcce1'.•ea from the Ca1ifornla Department of Public l'lcilllh under con rac i;09·l l 182:.

Changelab Solutions 1s a nonprofit organization th.:it orovldc~ legal information on matter s relJt1ng to public tieJltn. The legal informJt1on ,n this document doe5. not cons titute legal adv,ce or legal representation. ror legal adv,ce. readers ~t">ou ld consu lt a 1.:w,ycr 1n tnecr state .

..~~ ZD l4 Cl1 ,mgeLao Solu ions

changelabsolutions.or g 5

7 Appendix -B [icensing Ordinanc Checklist

POLICY OPTIONS IN MODEL ORDINANC E, Who Must Obtain License Requirements and Prohibitions for Licenses 0 All lob.Keo product rnlailers must obtain a nontransferable Jj) Pay an annual licensing lfHl th al fully covers all program "" license costs, including admi.11.istralio11 and enforcement 0 Dolioo "tobacco product" lo include aJJ nicotine and 0 Violating any tobacco law is also a violation ol the Iiccnso ' nontraditional products (eg, e-cigarettes, sn,~s) "'o lfoquire retailers to check ID ii purchaser appears lWder D Retaile1 of Mlobacco paraphernalia" (eg, rolling pape1s, age 27 pipes) must also obtain license O Prohibit the sale of all flavored tobacco products, including me.nlhol cigarettes Restrictions on Eligibility for a License O Prohibit the redemption ol tobacco product coupons, discounts, and promotions D No license may be issued lo mobile vendors 0 Establish a minimum package size for little cigaIS and cigars D No license for a business that contains a phannacy O Establish a minimum price for cigarettes, little cigars, and D No licenses near schools and youth-populated areas cigars D New tobacco retailers must be localed a specified minimum O Prohibit all solf-sorvico displays distance from e.irisling retailers O Require on-silo sales for aU tobacco products and D Number of available licenses is limited based on population paraphernalia D No license for a cannabis business D New tobacco retailers must be Joc.ated a specified minimum distance Imm existing cannabis businesses

Enforcement of License Requirements j Licensing progrnm wiJJ be aclmjnistered by (eg, who issues the license?): ______12J Licensing program will be enforced by but also e nforceable by any agency -D Youth decoy operations will be c.onducted by (ii different from enforce ment agency): ______D Number of mandatory inspections is (eg, times each store is checked pt>.r year), ______D The hea1ing process will be an administrative process (attorneys and court system need not be involved)

Consequences of License Violation

~ Each violation results in a .,uspu11sion of tho privilege lo scU tobacco products aml paraphernalia for _ days for a 1st licousi119 violation; _ days for a 2nd violation; _ days for a 3rd violation; and revocation of the privilege for a -4th violation jJ Number of ye.us past violations will be tracked (the "look-back period~), __ (minimum of 5 years) D Prohibit display or tobacco products and paraphernalia during suspension period D Prohibit display ol tobacco product and paraphernalia advertising during suspension period O Increase suspension periods and penalties for retailers who sell tobacco without a license 0 Seize and destroy tobacco products offered for sale without a license

"PLUG-IN" POLICY PRAY l$ 10NS

O No license for a restaurant or bar O No license lor a business Lbat allows smoking anywhe.re on Lbe premises O No sales of drng paraphernalia D Retailers may nol cover more than 15% of windows with signs D Allow lhe retailer to pay a fine in lieu of license suspension

June 2018

8 California Comprehensive Tobacco Retailer Licensing I ChangeLa ... httQ_Jlwww.changeIabsolutions.org/pu b Iications /model-TRL-Ordinanc5

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Home/ California Comprehensive Tobacco Retailer Licensing Related Tools Big Tobacco Tastes Defeat California Comprehensive Tobacco Retailer Licensing MODEL ORDINANCE, CHECKLIST, AND SUPPLEMENTAL PLUG-INS Implementing Tobacco-Free Pharmacies

How to Reduce Tobacco Retailer Density and Why ChangeLab Solutions developed this model ordinance to help California cities and counties that want to establish or strengthen a Tackling Tobacco in California - Part 2 local tobacco retailer licensing (TRL) program. Licenses are one Tackling Tobacco in Cali fornia - Part 1 way to ensure compliance with local business standards, reduce youth access to tobacco, and limit the negative public health effects associated with tobacco use. Comprehensive TRL policies CONNECT WITH US can also help reduce tobacco-related health inequities by countering the tobacco industry's predatory targeting of Get the latest news, join discussions on public health underserved communities. issues, show us change in your community, or make a donation. Start with our checklist, which includes a 5-phase model for You enacting a TRL law ( created by the American Lung Association in li!m M Now California's Center for Tobacco Policy & Organizing) and lists the various policy components of our model ordinance. The ordinance contains all the essential elements for a local tobacco retailer license, including descriptions of who must obtain a license, requirements and prohibitions for licensees, enforcement provisions, and penalties. The ordinance also includes additional policy options for regulating the tobacco retail environment-for example, restricting the sale of menthol cigarettes and other flavored tobacco products or establishing a minimum price for tobacco products.

We've also drafted supplementary "plug-in" provisions that can be added to the model ordinance. Each of the plug-ins provides a different policy option; for instance, some impose limitations on which businesses can be licensed, while others create additional requirements and prohibitions for licensed retailers.

Comprehensive TRL model ordinance resources

• 1'RL Model Ordinance Checklist: A companion checklist that highlights key policy options available in the model ordinance (download below). • Co,nprehensive 1'RL Model Ordinance: A model ordinance containing all the essential elements for a comprehensive local tobacco retailer license (download below). • Co,nprehensive 1'RL Model Ordinance "Plug-in" Policy Options: Plug-in provisions that can be added to the model ordinance to provide additional regulation and enforcement options (download below). • 1'obacco Retailer Licensing Fee Calculator: A tool to help California communities determine an appropriate fee that will adequately support the costs associated with implementing and enforcing a TRL system.

Additional TRL resources

• 1'obacco Retailer Licensing: An Effective 1'ool for Public Health: A fact sheet explaining how TRL works, why many communities are pursuing this policy, and what goes into creating and implementing a strong TRL law. It also describes how TRL provides a framework for other policies that can advance tobacco­ related health equity. • Show Me Your License: 1'he Basics of 1'obacco Retailer Licensing: A fact sheet that answers common questions about TRL, provides talking points about the public health and equity benefits of TRL, and identifies complementary resources for communities that are ready to develop a policy. • 1'obacco Retailer Licensing Playbook: A guide that outlines the 10 strategies necessary to develop, implement, and enforce a comprehensive TRL policy. • Point of Sale Playbook: A publication that outlines policy options for regulating how and where tobacco products are marketed and sold, including strategies for addressing the "four P's" of tobacco marketing: place, price, product, and promotion.

I of2 I 0/9/2018, 4:0 I PM California Comprehensive Tobacco Retailer Licensing I ChangeLa ... http://www.changelabsolutions.org/publications/model-TRL-Ordinance

• rR.L FAQs: Changelab Solutions answers questions you may have about tobacco retailer licensing.

To learn more, please contact us for technical assistance. Remember to subscribe to our news updates and support our work.

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GiJ CHECKLIST: Tobacco Retailer Licensing Model Ordinance (6/18) 280.3 KB

~ MODEL ORDINANCE: Comprehensive Tobacco Retailer Licensing (6/18) 1.57 MB

~ "Plug-in" Policy Options for the Comprehensive TRL Model Ordinance (8/18) 1.06 MB

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10/9/2018, 4:01 PM 2 of2 Appendix C

PART TWO: Tobacco Retail icensing in Local Jurisdictions in Oregon

A~ ~ er oJ local communities i!,_Ores2r1 ~ ve enacted_g>bacco retaillicensing (TR() ordinances. To establish a context for consideration of statewide TRL in Oregon, we felt it was important to understand how licensure, in these local Oregon communities was established, and how licensure currently works. This component of the assessment also provided an opportunity o gather information...9..n the advantages.and disadvantaM s 2,f state- evel TRL from the perspective of local tobacco control stakeholders.

There are nine jurisdictions in Oregon that have enacted ordinances that require retailers to obtain a license to sell tobacco: Ashland, Benton County (and within Benton County, Corvallis and P rl omath), Central Potnt, Eugene, Salem, Silverton, and Springfield. The assessment team ~amined each ordinanc,e .fQ!. ~ purpo1,e and contenJ of the ordinance, the license fees, penalty structures, and monitoring and enforcement. After examining the ordinances, ~ Tobacco Prevention and Education Program coordinato~ P~ i~ each county e!,'"licipat~ .!!' an informational interview. Th.e TPEP coordinator either poke about the local TRL programs or referred us to the issuing agency of the local program. The tobacco retail license issuing agency was typ ically the business or finance department of the local city government. ~ s , - The interview guide covered a general overview and history of the ordinance, the monitoring and enforcement activities, training for new tobacco retailers, and barriers or challenges for implementation. Additionally, each participant was asked about their recommendations or thoughts about a state law requiring tobacco retail licensure. A total of six interviews were ~ b!.tween July and August of 3011., covering all of the jurisdictions. 1

Purpose and content of local ordinances

There. are several reasons that a local Jurisdiction might require retailers to obtain a license to sell tobacco. Especially in the absence of state licensing, the jurisdict ion might want to have licensure as an additional tool for enforcing existing state laws that regulate tobacco use (Oregon has laws that prohibit sales to minors, require vendor-assisted sales, establish minimum pack size, among others (see additional information in Part Three)). Or, a Jurisdiction might plan to enact additional, more stringent regulations than the existing state laws, If not prevented through preemption. Regardless of the reason, conceptualizing licensure as-an enforcement mechanism is the key element that makes TRL useful. An Important outcome of the interviews was to get a picture of how Oregon's local ordinances fit within the larger picture of enforcement of tobacco laws.

Ordinances in the nine jurisdictions were passed in thtlate 1990s or early 2000s. Most r~ pondents had no historical knowl;'dge about their TRL ordinance. When asked about the

9 purpose of TRL In their community, some stated that the purpose was to know who was selling tobacco in the community. One stated that the purpose was to keep tobacco out of the hands of minors. In one location respondents stated that the ordinance had not been implemented since its creation; the Health Department in that Jurisdiction first heard about the TRL ordinance when a business owner contacted them wanting to know where and how to obtain a license. They are currently working toward activating the ordinance.

Only tw o ordinances link licensure to compliance with any c ty, county, state, or federal law applicable to tobacco products (and one of those addresses tobacco stores8 only). Most link licensure only with sales to minors and vendor-assisted sales. The Ashland ordinance has explicit introductory language describing the health risks of tobacco use, citing smoking prevalence figures for youth and stating that most youth initiate smoking by age 18. Nevertheless, the regu lation d~s not attempt to link licensure with any other tobacco-related ~ restrictions. We have outlined the major characteristics of the nine ordinances ini ppendix U r Cc, u t l n•-\ \ oca.1¢ -Fees Fees ranged fr~m ~ annuaJJy ~ a $73.50 initial fee ~ $47.25 renewal. The number of tobacco retailers estimated by respondents ranged fro~ to 12~ One respondent ~ imat~ that it costs$~ for on(youth deco't}<:2 m__p liance check per year. Since it is estimated that at least two checks should be done annually at each licensed establishment to keep compliance rates at 80%, 9 no municipality has a fee high enoui.hto cover this cost 2!. any additional costs that might be Incurred in the program administration.

Administration, Monitoring, and Fnforcement

Most tobacco retail licenses in Oregon communities are issued by the local business omce.~ of the nine urisdictions (Benton County, Corvallis, Eugene, Philomath, Salem, Silverton, and Springfield) o no equire businesses to have a business license in addition to the tobacco license. For some jurisdictions with TRL, the a,c.k of a regular business license p_9 sed a challenge. Stores may be required to have a license to sell tobacco, ~ if they are not required to register \heir businesses local! ¥, the local government ,does n(lt have any way of identifying them. Some jurisdict ions address this Tssue by using liquor licenses as a means of ident ifying businesses that need a tobacco license, as In many local areas, the same office issues each type of license.

8 De fined as esta blishments whose sales or tobacco product s meets or e.>cceed 90% of the gross receipts of the establishment.

~ Canadian Cancer Society. A critical Analysis of Youth Access Laws. http:/ /www.cqct .Qc.ca/Documents_doc:s/DOCU _2003/ME M0-02-09-00-CCS­ Critlca rAnalysisYouthAccess laws_en.pdf. Publ.she

10 Only one-third 9f ordinan~ s specifically ~ ntify a monitoring agency JA,Jhe municipal cod,!. When a business has violated a tobacco law linked to TRL, most ordinances hold the license holder responsible for the infraction and allow the accused a hearing if they would like to appeal. However, regardless of whether or not TRL is used as an enforcement mechanism for all laws·or only a few, most site€ ve @J2 een conducting any formal monitoring of licensed stores.

There were '@ ried reasons for why inspections were not being conducted. Some stated that they lacked the ca pacity or resources to monitor TRL. ~ places did state that ~ ir offi..£!: was ng_t regulatory in nature, but instead was c'omplaint-driven, as a reason for not monitoring. One""' city which- has not done any monitoring or enforcement of TRL stated that if they received a complaint, they would mail a citation with nofin e attached. Anoth~ ed that monitoring was not doneb ecause t~eir community :as not large 2nd@1d no) have many st~ or businesses, thus, monitoring was not necessary. Another mentionea that rncai law enforce~ nt had not received training in@:uth deco}.operatlons.

As noted, fees are low, a~ ~re inadequate to cover the administrative costs of monitorin the ordinance. To address this issue, .£!le county jurisdiction (Lane County is givm a ran ~ the,,, city of Eugene to conduct enforcement and compliance checking.

In addition to challenge.s around staffing, capacity, some ordinancesfJ@"iiolspecl,_fy who would 29 the enforcement, and o,ne respondent mentioned that while their~ nce has been around for a whil~ o o3 felt like they were responsible for it." ~ h no fundi~g, staffing, and in some cases, specified agency, it@as nQ)surpris!!!g that licensure w~ t being monitore,d 2! enforced in many locations.

Penalty structures

Lack of enforce men! of any la~ is often a resource issµe, However, even If adequate resources for enforcement are availabl e, the effectiveness of a law remains dependent on penalty structures. Penalties need to be strong enough to avoid the perception that they are merely "the cost of doing business."

Many of the local ordinances we examined have a standard, graduated penalty structure {see _t\ppendix 1). In this structure a monetary fine is imposed on the first violation of the local law (but not of other federal or state laws). License suspension is not introduced until the second violation. The "look-back" period is two years, I.e. repeat violations only incur greater penalties if they occur within that period.

The city of Eugene has a unique structure specifically for violations of the sales to minor's regulation. It considers: 1) the effort made by the responsible person In taking all feasible steps or procedures necessary to correct or prevent the violation, 2) the frequency of prior violations, 3) the cause of the violatJon, and 4) the knowledge of the responsible person regarding tobacco

11 regulations. Each of these factors is measured on a scale of 1, 3, or 5, and is then summed and multiplied by $10 to calculate the penalty imposed per day, up to a maximum of $2000. The language in this regulation is exemplary, as it describes to retailers the types of changes they can make in the environment to discourage sales to minors, such as posting signage at the door and register, using scanners, calculators and "Born by Today" signs for clerks, as well as providing staff training. Eugene is the one jurisdiction in which a license has been revoked from an offending retailer.

The majority of ordinances also have mandatory penalties, while Eugene has an additional civil penalty for those who violate the sales to minor law. Salem, Silverton, and Springfield's penalties are discretionary.

These penalty structures, although graduated, have fairly short look back periods, and do not impose license suspension until the second violation. However, the second violation in a two­ year period does Impose a 45-day license suspension, which is a significant time period for the loss of the privilege of selling tobacco. If enforcement efforts were increased, and suspension were accompanied by additional stipulations, such as removal of product from shelves (not specified in current ordinance language), these penalty structures could be useful in the efforts to regulate the retail environment.

Retailer training

In most jurisdictions~ pecific traininjjs attached to licensure. In general, the TRL application contains information about the ordinance or directs the applicant toward web-based information. ~ local participant ~ that t~ y offeredS-!!.ining a~ they assumed. that the retailer was receiving tcaioiOi' from elsewhere

@ Benton County offers regular training attached to a tobacco license. Training is for alcohol and tobacco retailers, and is offered twice a year as part of local alcohol and tobacco control efforts. The partnership coordinating the training includes representatives from law enforcement, bar owners, liquor store owners, the local OLCC officer, and the fire department. Linn County has now started a similar training modeled after Benton County's training. Topics covered in the training include checking identification, laws specific to the sale and consumption of tobacco and alcohol, and tips for recognizing someone who is Intoxicated. Those who participate get free black-lights for checking IDs.

The city of Eugene also requires licensees to be responsible for implementing tobacco regulations training for employees at the commencement of their employment and annually thereafter. All licensees are supposed to maintain records of all training pr~rams which have been implemented, and must provide the city access to the records upon request.

12 Appendix D

BOARD OF COUNTY COMMISSIONERS

KLAMATH COUNTY, OREGON

IN THE MATTER OF ORDINANCE NO . 90.00 ) ESTABLISHING TOBACCO RETAIL LICENSING IN) ORDINANCE NO. 90 . 00 KLAMATH COUNTY .AND AMENDING KLAMATH ) COUNTY CODE )

WHEREAS , businesses in Klamath County that sell tobacco products currently do not have to obtain a license in exchange for the pri vil e ~e o f selling tobacco; and WHEREAS , research shows a tobacco retail license is an effective way t o reduce youth a c cess to tobacco products; and

WHEREAS , t hirty-five (35%) percent of youth were able to s uccessfully purchase tobacco products during the 2014 - 2015 Food and Drug Administration inspections; and WHEREAS, twenty-eight (28%) percent of 11th graders in Klamath County reported regular tobacco use; and WHEREAS, ninety percent (90%) o f smokers start before age 18. NOW THEREFORE , i t is the intent of the Board of County Conunissioners, in enacting this ordinance, to provide for the public health, safety, and welfare of youth by amending Klamath County Code to require a l icense to sell tobacco , resulting in a restriction o f tobacco sales to those younger than the minimum age established by state law f or the purchase or possession 0£ tobacco products. Klamath Count y Code is hereby amended to add Chapter 412 , Tob a cco Retail Licensing, as set forth below :

Ordinance No. 90.00 Establishing Tobacco Retail Licensing in Klamath County Page 1

13 Show Me Your ticense The Basics of Tobacco Retailer Licensing

Q: What is a tobacco retailer licensing (TRL) law? A: A tobacco retailer license is a special license the government issues to businesses that sell tobacco products. State and local governments commonly use licensing to regulate certain kinds of businesses and professions, such as alcohol retailers, pharmacies, and restaurants. Similar to other licensing schemes- such as dri ver's licenses- TRL is aimed at ensuring that licensees are aware of eligibility requirements and performance standards. TRL also puts in place a system to address the problem when licensees fall short. If a business fails to meet the eligibility requirements or performance standards, its license can be suspended or revoked, prohibiting the business from selling tobacco until the license is reinstated. As with a license to sell alcohol products, obtaining the license is acknowledgment that selling tobacco products is a privilege, not a right.

Q: Why is TRL good for my community? A: Communities adopt TRL laws for many reasons- for example, to ensure comprehensive local enforcement of all tobacco laws that affect the retail environment. This and other points are discussed below.

TRL is a comprehensive enforcement tool. Local governments can use TRL to enforce all tobacco-related laws that affect the retail outlet. For example, under state and/or federal law, it is illegal to sell tobacco to youth,* display tobacco products via a self-service display, or sell single cigarettes, but each of these laws currently has a different enforcement mechanism. Furthermore, enforcement of these laws may not be a top priority for state or federal agencies. Under a strong TRL law, violation of these laws also constitutes a violation of the local tobacco TOBACCO RETAILER LICENSE reta iler license. Because TRL can be enforced locally, local communities can --~ use it to prioritize enforcement of state and federal laws even when state and federal authorities are unable to do so. TRL protects youth. TRL is an effective tool for reducing tobacco sales to youth because it helps ensure that retailers comply with existing laws that prohibit tobacco sales to youth. Research has shown that local tobacco retail ordinances dramatically reduce youth access to cigarettes. For example, a review of 33 California

• Federal law prohibits the sale of tobacco products to in divid uals under the age of 18. However, many state and local governments have establi shed hi gher minimum legal sales ages ranging from 19 to 21. For a li st of local governments that have increased the minimu m legal sales age to 21, see www.tobaccofreekid s.org/assets/contenV what_we_do/state_local_issues/sales_21/states_localities_MLSA_21.pdf. For a list of minimum legal sa les ages in each state, see the American Lu ng Association's State Legislated Actio ns on Tobacco Iss ues State Pages at www.lungusa2.org/slati/states.php. communities with strong TRL laws overwhelmingly Q: It's already illegal for youth to buy demonstrated a decline in each community's youth tobacco products. Why do we also need to sales rate after the local government enacted the law, license retailers? with an average decrease of 26%. 1 Similarly, a study A: All state governments, as well as the federal Family of several Minnesota cities found that an increased Smoking Prevention and Tobacco Control Act (often licensing fee along with strict enforcement of youth known as the Tobacco Control Act), prohibit the sale of access laws led to a decrease in the percentage of tobacco products to youth.5 However, under existing youth able to purchase tobacco from 39% to 5%.2 laws, youth purchase rates remain quite high. In 2014, TRL also can be used to prohibit or limit the sale of nearly 10% of retail outlets illegally sold tobacco to other tobacco products that appeal to youth, such as minors.6 A strong TRL law can help counter the tobacco menthol cigarettes, flavored electronic smoking devices industry's predatory practices that disproportionately (like e-cigarettes), and flavored little cigars. target youth; facilitate comprehensive enforcement of TRL helps communities track tobacco sales. federal, state, and local tobacco laws; and ensure that Through TRL, local government can maintain an inspections and compliance checks occur in all the inventory of all the businesses that are selling tobacco, stores in the community. including the different kinds of businesses that sell tobacco and where they are located relative to schools, Q: My state already has a TRL requirement. youth-populated areas, and each other. Why would a loca l law benefit my TRL fees provide for self-financing enforcement. community? A key advantage of a TRL system is that the fee the A: Although nearly 40 states have TRL laws at the state business pays annually to keep its license can be used level, most of these programs were created to ensure to fund implementation and enforcement of a TRL that retailers comply with the requirements of tax laws, program, which allows for regular compliance checks such as selling tobacco products with a legitimate of retailers. tax stamp, rather than to promote public health and advance equity.7 Most state-level TRL laws are TRL can help communities improve health equity. administered and enforced by a state department of One of the most promising potential uses ofTRL is revenue or taxation, and these agencies may not have to reduce inequities in how tobacco products are the same public health priorities as a local community. marketed and sold in underserved communities. By adopting a local TRL law, a jurisdiction can enforce Research has found that the prices of tobacco local, state, and federal tobacco-related laws-all on products tend to be lower in neighborhoods of the local level. low socioeconomic status and African American neighborhoods.3 Evidence shows that these same TRL gives local government the authority to intervene communities have higher rates of tobacco use and as needed, making enforcement more effective and addiction, worse health outcomes, and increased more efficient. For instance, if there are reports of health inequities.4 Because the health problems the convenience store near the high school selling associated with tobacco use fall disproportionately cigarettes to youth, local officials can address the on underserved communities, policy interventions problem directly by conducting their own compliance that affect consumption, price, or marketing also have check instead of waiting for a state enforcement a greater impact on these populations and have the operation to come to town. It is possible to create a potential to address these inequities. state-level TRL law (or amend an existing state law) to accomplish the same things as a strong local TRL law, but to date, no state has done so.

! 2 Q: Is a local TRL law legal? Q: In addition to preventing tobacco sales to A: Yes. A TRL law is a valid exercise of a local government's youth, how can a community use a police power authority to protect the health, safety, TRL system? and welfare of the community. However, some state A: TRL can be used to enforce virtually any tobacco-related laws prohibit or preempt local laws regulating the retail policy at retail outlets, including strategies to increase environment. To find out if a state has a preemption the price of tobacco products, to require a minimum provision that would affect a local TRL law, consult with pack size for little cigars, to restrict the sale of menthol a local government attorney or a provider of state or cigarettes and other flavored tobacco products, and to national legal technical assistance. Changelab Solutions regulate tobacco retailer location or density. Changelab and the Tobacco Control Legal Consortium are legal Solutions has model policy language available on each organizations funded to provide technical assistance on of these topics. retail issues pertaining to tobacco control nationwide. Q: Are tobacco control advocates In addition, several states are served by a legal collaborating with professionals who are technical assistance provider, funded to work directly working t o increase access to healthy food with communities in those states. Collaboration with and reduce access to alcohol in the retail local city or county attorneys may also be necessary environment? to ensure that a local government has the authority to implement TRL. If there is no state preemption, a A: Yes. For example, California's Healthy Stores for a Healthy local government will likely be able to adopt its own Community campaign is a statewide collaboration of TRL law. Although the federal Tobacco Control Act partners advocating healthy nutrition, prevention of regulates some tobacco products, it explicitly allows tobacco use, and prevention of alcohol use, coordinated state and local governments to adopt laws that are by the California Department of Public Health's Tobacco stricter than the federal law.8 Control Program. The campaign focuses on the link between the store environment and community health. Q: Is it fair to charge retailers a fee to sell In 2016, counties throughout California conducted a product that is legal? Couldn't it put surveys at more than 7,000 stores that sold tobacco. The small retailers out of business? surveys included questions on the availability of and advertisements for tobacco, food and beverage, and A: Tobacco is one of the only addictive and deadly alcohol products. This survey found that statewide, more products that does not require a government license stores sold fruit-flavored tobacco than real fruit; nearly and fee in order to be sold. In the case of alcohol, for 70% of stores had exterior advertisements for unhealthy instance, each state either requires retailers to have a products (alcohol, tobacco, or unhealthy food); 41 % of license to sell alcohol products or allows sales only in stores sold sugary drinks at the checkout; and more than state-run outlets. Such licenses can cost hundreds or 69% of stores that sold alcohol also sold alcopops, which thousands of dollars per year.9 are sweet, often fruit-flavored alcoholic beverages that In addition, retailers generate tremendous income are particularly appealing to youth.11 from the sale of tobacco products. Cigarettes are the number one product sold at convenience stores, and Q: How do I get started developing tobacco in 2012, they generated average sales of $622,248 per retailer licensing? store. 10 Licenses and fees are required for a variety A: Changelab Solutions has developed the Tobacco of activities, such as driving, hunting, and getting Retailer Licensing Playbook, an easy-to use guide that married. Businesses in industries such as personal or outlines strategies to develop, implement, and enforce animal care, mental health, professional services, or a comprehensive TRL policy. The playbook provides food services also need to obtain licenses or permits all the steps and considerations involved in building before conducting business. A local licensing program support for TRL, and it includes examples and key is a way to ensure that sales of a deadly product are resources to help communities create a strong local done lawfully. policy that improves public health. Contact Changelab Solutions for technical assistance on implementing TRL in your community.

: 3 1 The American Lung Association in California Center for Tobacco Policy and Organizing. Tobacco Retailer Licensing Is Effective, 2013. Available at: http://center4tobaccopo1icy.org/wp-content/ uploads/ 201 6/ 1O/Tob acco-Retailer-Licensing-is-Effective­ Se ptember-2 01 3.pdf.

2 Forster JL, Murray OM, Wolfson M, Blaine TM, Wagenaar AC, Hennrikus DJ. The effects of community policies to reduce youth access to tobacco. American Journal of Public Health . 1998;88(8):1193-8. 3 Cantrell J, Kreslake JM, Ganz 0, et al. Marketing Little Cigars and Cigarillos: Advertising, Price, and Associations with Neighborhood Demographics. American Journal of Public Health. 2013;103(1 ):1902-9. Toomey TL, Chen V, Forster J, Coevering PV, Lenk KM. Do Cigarette Prices Vary by Brand, Neighborhood, and Store Characteristics? Public Health Reports. 2009;124(4}: 535-40. Feighery EC, Schleicher NC, Boley Cruz T, Unger JB. An Examination of Trends in Amount and Type of Cigarette Advertising and Sales Promotions in California Stores, 2002-2005. Tobacco Control. 2008;17(2):93-8. Henriksen L, Schleicher NC, Dauphinee AL, Fortmann SP. Targeted Advertising, Promotion, and Price for Menthol Cigarettes in California High School Neighborhoods. Nicotine and Tobacco Research. 2012;14(1):116-21. 4 Tobacco-Related Disparities. Centers for Disease Control and Prevention website. www.cdc.gov/tobacco/ disparities/ index.htm. Accessed February 20, 2018. 5 Family Smoking Prevention and Tobacco Control Act (Pub. Law 111-31, June 22, 2009); A summary of the retail provisions of this Act can be found at: US Food and Drug Administration. Family Smoking Prevention and Tobacco Control Act - An Overview. 2018. Available at: www.fda.gov/tobaccoproducts/ guidancecompliancereg u latoryinformation/ ucm246129.htm. 6 Substance Abuse and Mental Health Administration, Tobacco Sales to Youth, FFY 2014. Available at: https://store.sa mhsa .g ov/ shin/ content// SYNAR-15/ SYNAR-15.pdf. 7 More than 40 states require a tobacco retailer license for over­ the-counter sales, vending machine sales, or both. State Tobacco Activities Tracking and Evaluation (STATE} System. 2018. Available at: www.cd c.gov/ STATESystem. Most state tobacco retailer licensing laws are implemented and enforced by the state agency that enforces tax laws.

8 21 U.S.C.A. § 387p(a}(l}.

9 For example, $500-$1,000 in Indiana (Ind. Code. § 7.1-4.41-12(c}}; $624-$1,820 in Florida (Fla. Stat. § 565.02(1 }(a}-(f}}; $300-$3,000 for two years in Delaware (Del. Code Ann. tit. 4 § 554). ChangeLab Solutions is a nonprofit organization that provides lega l 10 The American Lung Association in California Center for information on mauers relating to public health. The legal information Tobacco Policy and Organizing. Cigarettes Generate Big provided in this document does not constitute lega l advice or legal Revenue for Convenience Stores: Analysis of 20 73 State of the representation. For legal advice, readers should consult a lawyer in Industry Report. Available at: http://center4tobaccopo1icy.org/ their state. w p-content/ uploads/20 16/ 10/Ci garettes-Generate-Big -Revenue­ September-2 013.pdf. This publication was originally made possible through funding from the Centers for Disease Control and Prevention under Cooperative 11 California Department of Public Health, Healthy Stores for a Healthy Agreement 5U380T00014 7-02. Its contents are solely the responsibility Community. Available at: http://healthystoreshealthycommunity. of the authors and do not necessarily represent the official views of the com/ media-ce nter/ ?ca mpaign. Centers for Disease Control and Prevention.

Th is updated version was made possible by fu nds received from Grant Number 14- 10214 with the Ca lifornia Department of Public Health, Ca lifornia Tobacco Control Program ..

Orginally published September 2015. Updated in June 2018.

I ,, 4 l