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Thread: CASAA blog: FDA releases e-cigarette rules

  1. #11
    CES
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    As I wait for the call to action, some thoughts that crossed my mind were the lack of guidance and clarity in the proposed regulations, the obvious potential for creating a black market (expressly identified as a no-no in the tobacco act?), and the potential for an undue regulatory burden on small businesses. These thoughts are on top of my continued annoyance with the fact that the FDA continues to ignore the science that exists, is asking for proof of negatives, yet is still willing to consider exempting certain high end cigars.

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  3. #12
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    We are working hard to scrutinize the proposed rule, so as to not miss any potential issue. We are also discussing the rules and potential courses of action with other advocacy and industry groups.

    It is very easy to make snap judgements at a glance, which many armchair advocates seem to be doing, but the more we CAREFULLY get into our review, the more we see. We believe cautious and methodical dissection of these rules is what we owe the CASAA membership and they'd expect nothing less. There would be far more outcry over us missing something and giving the wrong advice than there is currently, asking why CASAA doesn't "do something" immediately.

    I would also remind people that this isn't CASAA's first rodeo regarding FDA comment periods. There are things going on behind closed doors, so-to-speak, and we ask our membership to be patient and continue to trust us on knowing the process and seeking expert council where we don't.

    The second part of our assessment should be posted tomorrow.
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    Quote Originally Posted by kristin View Post
    We are working hard to scrutinize the proposed rule, so as to not miss any potential issue. We are also discussing the rules and potential courses of action with other advocacy and industry groups.

    It is very easy to make snap judgements at a glance, which many armchair advocates seem to be doing, but the more we CAREFULLY get into our review, the more we see. We believe cautious and methodical dissection of these rules is what we owe the CASAA membership and they'd expect nothing less. There would be far more outcry over us missing something and giving the wrong advice than there is currently, asking why CASAA doesn't "do something" immediately.

    I would also remind people that this isn't CASAA's first rodeo regarding FDA comment periods. There are things going on behind closed doors, so-to-speak, and we ask our membership to be patient and continue to trust us on knowing the process and seeking expert council where we don't.

    The second part of our assessment should be posted tomorrow.
    I have every bit of faith and respect to CASAA for what they do and are currently doing in this matter. TY Kristin etal...

    Vape for Freedom.
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    Thank you for taking the time to do the detailed analysis. My head wants to explode when i try to read it.

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    Unfortunately, there are already 538 comments posted at regulations.gov

    I can only imagine....
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    Quote Originally Posted by pamdis View Post
    Unfortunately, there are already 538 comments posted at regulations.gov

    I can only imagine....
    I am sure it is quite helpful for FDA to get very early comments. They know that they can ignore them.

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    Quote Originally Posted by kristin View Post
    We are working hard to scrutinize the proposed rule, so as to not miss any potential issue. We are also discussing the rules and potential courses of action with other advocacy and industry groups.

    It is very easy to make snap judgements at a glance, which many armchair advocates seem to be doing, but the more we CAREFULLY get into our review, the more we see. We believe cautious and methodical dissection of these rules is what we owe the CASAA membership and they'd expect nothing less. There would be far more outcry over us missing something and giving the wrong advice than there is currently, asking why CASAA doesn't "do something" immediately.

    I would also remind people that this isn't CASAA's first rodeo regarding FDA comment periods. There are things going on behind closed doors, so-to-speak, and we ask our membership to be patient and continue to trust us on knowing the process and seeking expert council where we don't.

    The second part of our assessment should be posted tomorrow.
    We can't be too careful with our analyses. Whether we like it or not, the deeming regulations, once enacted, will become a seminal piece of legislation for years to come. That legislation will affect everyone in this country and have a ripple effect throughout the world. The FDA hopefully realizes this and that's why they are so cautious and non-committal in their first draft. They can't, of course, proclaim that vaping is a perfectly safe and innocent pastime, but they have the chance to send a signal that they acknowledge that vaping is safer than smoking by taking their legislative foot off the accelerator--just a bit.

    We should very strongly argue that the 2007 date is a non-starter because the hardware that was in use at that time simply doesn't exist anymore; Zeller himself opened the door by consenting that that date is problematic. If they could find a way to grandfather existing hardware and take it from there that would be very nice.

    As for nicotine, well, it's already present in tobacco and in all NRT products and even ANTZ advocate NRT use.

    Vaping is a revolution in tobacco harm reduction and should remain legal and easily accessible to all smokers who wish to quit their deadly habit. Furthermore, vaping has been so successful that it has the potential to eradicate smoking altogether and hence should be encouraged and allowed to improve and develop in the future.
    Last edited by Katya; 04-28-2014 at 04:18 AM.
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    Quote Originally Posted by Mowgli View Post
    <snip>
    Yes, I had already seen that when I did my post. I must be missing something in yours.

    1) Are you saying: "Whoa! Calm down now. CASAA will address this on Monday!"

    If so: my response is: "Great. I just wanted to be sure they picked up this one point." (Which is why I did my post in which I wanted to be sure that I explained precisely why I felt it was salient. So far, it hasn't been addressed by many folks who might be in a position to speak authoritatively on the matter.)

    2) Or is the answer to my question (regarding the scope of the deeming), already present in what you quoted?

    3) Or are you just quoting this section for general informational purposes?

    I'm lost.

    As long as I'm posting, I'll add one more point. There are many folks at ECF who DIY, and who have lots of nic. in their freezers. I know at least one of them is absolutely convinced that they will not be affected by any reg.s the FDA enforces as a result of this rule (since they already have nic.). That's the kind of reaction that will not help our cause, particularly if it's not based on fact.
    Last edited by Roger_Lafayette; 04-28-2014 at 12:45 AM.
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    Thank you for keeping us updated. I agree that getting this right the first time is essential in that once finalized, the regulations would take an act of Congress to change - as in never. It also seems that reps from tobacco firms and Zeller have hit the streets with a publicity tour, re-energizing misleading claims ("it's in anti-freeze") and both are heralding the FDA as a "science based organization" over and over and over again. At the same time a handful of people don't see much change. It's very frustrating to passively watch from the sidelines. Meanwhile local bans march on with Calif's ban with online sales coming up this week.

    I have no idea how you all do it, I'm just glad you do.

    P.S. I thnk Roger brings up a valid point that there is a significant number of hobbyist's in vaping; woodworkers, glass, mods, drip tips, in additiion to DIY. That tends to fall in line with cigars exempted being their artisian based.
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    Quote Originally Posted by Roger_Lafayette View Post
    Yes, I had already seen that when I did my post. I must be missing something in yours.

    1) Are you saying: "Whoa! Calm down now. CASAA will address this on Monday!"

    If so: my response is: "Great. I just wanted to be sure they picked up this one point." (Which is why I did my post in which I wanted to be sure that I explained precisely why I felt it was salient. So far, it hasn't been addressed by many folks who might be in a position to speak authoritatively on the matter.)

    As long as I'm posting, I'll add one more point. There are many folks at ECF who DIY, and who have lots of nic. in their freezers. I know at least one of them is absolutely convinced that they will not be affected by any reg.s the FDA enforces as a result of this rule (since they already have nic.). That's the kind of reaction that will not help our cause, particularly if it's not based on fact.
    this ^#1

    I DIY and have a ton of nic stashed and will fight tooth and nail for current & future vapers' rights.
    Sitting on our asses isn't the correct way to cover them.

    Looking forward to what CASAA has to say tomorrow.
    Katya and LaraC like this.



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