FDA micro-comment example 2

All available (and respectable) scientific evidence indicates that electronic cigarettes (e-cigs or ecigs) are a major positive development in the public health field and have helped tens of millions of smokers (worldwide) switch to an alternative that is much safer than combustible tobacco. In addition, this evidence thoroughly and definitively debunks the "gateway" myth maliciously invented and propagated by the tobacco control industry.

The following studies reinforce these statements and should be reviewed by any professional and/or regulator with a serious and honest commitment to improving public health and reducing smoking rates.

A new report from ASH Scotland (http://www.ashscotland.org.uk/media/6155/e cig Final report 07.14.pdf) . found:
- 22% of teens (13-18 years) smoked one or more cigarettes per week,
- 15% of teen smokers used an e-cig one or more times per week,
- 2% of teen nonsmokers used an e-cig one or more times per week,
- 39% of teens reported ever use of an e-cig,
- Among teen smokers who used e-cigs, 29% did so to quit smoking, 23% did so to reduce cigarette consumption,
- 53% of teens agreed that e-cigs are less harmful than cigarettes, while 12% disagreed,
- 12% of teens thought cigarette smoking was cool, and 12% thought e-cig use was cool

A similar survey from Wales (ASH Wales: http://www.ashwales.org.uk/creo_fil...nd_e-cigarettes_in_wales_final_march_2014.pdf) had even stronger evidence that e-cigarettes help smokers quit as well as categorically do not entice non-smoking youth:
- 56.1% of teen smokers ever used an e-cig,
- 3.8% of teens who never smoked had ever used an e-cig,
- 33.7% of teen smokers currently use e-cigs,
- 5.6% of teen exsmokers currently use e-cigs
- .3% of teens who never smoked currently use e-cigs

Older results from England also agree (http://www.ash.org.uk/files/documents/ASH_891.pdf):
- The success rate for smoking cessation in the UK by use of an ecig is 33%
- The number of UK vapers has tripled in the last 2 years [1]
- There are more than 2 million vapers in the UK although some have now totally quit (ceased use of any/all inhalation products)
- About 20% of smokers are now vapers or have totally quit both smoking and vaping by use of an ecig
- About 700,000 vapers have quit smoking by use of an ecig or have totally quit
- So around 7% [2] of UK smokers have quit by use of an ecig, and clearly that number will rise significantly over time
- The number of non-smokers who are regular ecig users is almost unmeasurably small
- The number of minors (under-18s) who are regular ecig users is almost unmeasurably small

In addition, based on results from a recent publication from Harvard, Dr. Konstantinos Farsalinos, cardiologist at the Onassis Cardiac Surgery Centre in Athens, told the New Scientist: "This study verifies that e-cigarette use does not renormalise smoking. The results show minimal adoption by non-smokers." (https://uk.news.yahoo.com/harvard-study-e-cigarettes-not-gateway-smoking-110418386.html#qHLTvUi).

The proposed deeming regulations would undo all this progress, remove more than 99% of ecig products from the market and deliver the entire ecig business into the hands of Big Tobacco, doing more damage to public health than any cigarette company ever accomplished.

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I had to trim this one a bit, to make it comply within my goal of keeping these to one page or less.
 

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