My comment to regulations.gov on Section 918 of the Tobacco Act

January 5, 2013
RE: Section 918 of the tobacco Act

I am 57 years old, and started smoking in 1968 at the age of 13. I found myself unable to quit, despite losing several family members and friends to smoking-related illnesses over the years. About 16 years ago, I was hospitalized with pneumonia and was told that I must quit smoking, as another such bout of pneumonia could kill me. And so I did, off and on, for about a year. I used nicotine gum, and was completely miserable, unable to concentrate, and thoughts of smoking nagged at me constantly. Eventually I started sneaking a cigarette here and there, and finally threw in the towel and started smoking again. In 2009, several months after fire-safe cigarettes were mandated here, I started developing a persistent cough and congestion. In the fall of 2009, I heard about e-cigarettes from a friend, was intrigued, and did a lot of reading about them. I decided to order one, and as soon as I tried it, I was convinced that it could work for me. Within 5 days, I was done smoking tobacco cigarettes. About 3 months after switching to e-cigarettes, I decided to try a real cigarette, just to make sure I was really done with them. I was shocked at how disgusting it tasted and smelled, and could not finish 2 puffs. This was nothing short of a miracle to me, and now over 3 years later, I have had absolutely no desire for a tobacco cigarette.

It didn't take long to observe improvements in my health and well-being. The persistent cough and congestion vanished within days. Within a few weeks, my senses of smell and taste improved dramatically. My blood pressure dropped. I discovered that I had more energy and stamina when doing physical work such as shoveling snow. Friends and colleagues told me that I looked better. I'd had migraine headaches for about 7 years, for which I regularly needed sumitriptan to manage, and they disappeared - this alone was an enormous change in my quality of life. During the first couple weeks of e-cigarette use, I had fairly mild withdrawal symptoms - I am speculating that these were due to the absence of many of the other substances present in tobacco cigarettes. But they were easily manageable, and subsided quickly. The only adverse affect of the e-cigarette that I have observed is the need to drink more water, as the propylene glycol can be somewhat dehydrating.

I believe that several factors made the e-cigarette successful for me:
1). It mimics the act of smoking
2). The many flavors available provide a much more pleasant alternative to smoking
3). The variation in strength of nicotine allowed me to tailor it to my needs - I have reduced the strength of nicotine that I use by 75% since I started, but that reduced level would not have been adequate in the beginning
4). The wide variety and rapid innovation of devices enabled me to further adapt the experience to my requirements.

The combination of these factors gave me a sense of control. By tailoring the experience to my needs, I was able to relax and enjoy the improvements in my well-being, without the constant feeling that I was being deprived of something.

If e-cigarettes are to be regulated, I would strongly urge that any such regulations be centered around purity and safety of the nicotine liquid. I have never had a problem, but as a consumer, I would like to be assured that the liquid was produced under sanitary manufacturing standards, does not contain unsafe ingredients such as diacetyl, and that the nicotine strength is accurate. I also believe that lot tracking and labeling standards are prudent requirements.

I believe that the e-cigarette is one of the most promising developments in the struggle to reduce tobacco-smoking rates. Any punitive regulations that severely limit the nicotine strength or variety of flavorings of the liquid, or limit the selection of devices, will result in either a dramatic reduction in the success of e-cigarette use replacing tobacco cigarettes, or in the creation of a black market. Neither of these outcomes serve the public. As such, I would urge the FDA to not propose the "deeming" regulation that has been under discussion.

I would further urge the FDA to change the verbiage on its web site regarding e-cigarettes and other smokeless alternatives such as snus. Evidence clearly shows that these alternatives are safer than smoking, yet the web site's current text leads the reader to believe that those who cannot quit may as well just continue smoking, rather than pursuing one of these alternatives.

Sincerely,
Brad Preston

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