To the editor:

Lee Davidson's Jan. 13 story, "Utah's no Marlboro Country, study says," concerns me, and as a representative of the smokeless tobacco industry, I feel compelled to respond.The official policy of the smokeless tobacco industry is that "smokeless tobacco is NOT for kids." The Code of the Smokeless Tobacco Industry strictly prohibits marketing or advertising strategies that target youthful audiences. As the Code states, our advertisements "shall be directed to adults and shall not appear in publications that are primarily youth oriented."

For many years, we have conducted a nationwide public awareness campaign to inform parents, teachers, coaches, retailers and other youth authority figures of our policy that smokeless tobacco is an adult product, NOT for kids.

In addition, we support - and have testified on behalf of - state legislation establishing 18 as the minimum age for purchase of smokeless tobacco products.

It is interesting to note that a recent report by the Mayo Clinic indicates that peer pressure, not advertising, is the most decisive factor in the use of our products by those under 18 years of age.

Michael J. Kerrigan

Smokeless Tobacco Council Inc.