DC2 inquired
Bill, I thought I remembered you saying previously that our 5,000+ comments on the FDA website had some effect on them?
The clearly had an impact on the FDA, as the agency has tried to bury all of the comments and the testimony by vapers at the Dec 17th hearing.
That's why the FDA still (4 months later) has only posted about 75 of the 5,336 comments that were submitted to the docket, while the FDA's Report to Congress on Section 918 not only failed to acknowledge that any comments or testimony was submitted by vapers, but it also misrepresented comments by vapers as if they were endorsing long term nicotine maintenance using NRT.
I just don't think the FDA considers the views of vapers to be very important in their drafting of the deeming regulation and additional regulations for e-cigarettes.
What the FDA truly cares about are the legal arguments made against the deeming regulation by e-cig company lawyers and some of us with connections to those lawyers, the views of federal judges who might adjudicate a lawsuit against the FDA, and the views/actions of Republicans on the House E&C Committee (who have oversight over FDA activities and funding).
Secondarily, the FDA cares about the views of drug companies and their funded PR/lobbying front groups (CTFK, ACS, AHA, ALA, Legacy, Pinney Associates, ATTUD, etc.), and the views of large
tobacco companies.
The concerns of vapers are way down on the FDA priority list, as the agency still doesn't even consider tobacco consumers as Stakeholders in FDA tobacco regulation.
But that doesn't mean vapers shouldn't continue criticizing FDA, testifying at hearings, and submitting lots of comments to relevant dockets.
If/when the deeming regulations and additional regs for e-cigs are proposed, it is critically important that the
vaping community massively mobilize and submit hundreds of thousands of public comments to the agency's docket. That's when the FDA should begin to view the
vaping community as a force to be reckoned with.