Electronic cigarettes are not tobacco products and should not be treated as such. Deeming them as tobacco is a grave error with deadly consequences for more than 40 million American smokers who will be denied access to an alternative that is more than 1,000 times safer than combustible tobacco.
The proposed deeming regulations would remove more than 99% of electronic cigarette (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. This is because many of its premises are constructed on faulty assumptions (http://link.springer.com/article/10.1007/s00204-013-1127-0), junk science (http://tobaccoanalysis.blogspot.com/2014/05/glantz-review-article-is-little-more.html), and unsubstantiated propaganda (http://tobaccoanalysis.blogspot.com/2014/03/new-study-on-electronic-cigarettes-by.html) from the tobacco control industry (TCI).
One of the most flagrant exaggerations perpetrated by TCI and unfortunately reiterated numerous times by this proposed regulation is in the assertion that little or nothing is known about ecigs, that health effects are completely unknown, and that very little research had been done on the subject. These statements are demonstrably false in light of the recent systematic literature review published by Zyoud et al (2014; http://www.biomedcentral.com/content/pdf/1471-2458-14-667.pdf). These authors searched for all available peer-reviewed literature on the subject of ecigs and retrieved 356 documents, among which 31.5% were original journal articles, 16% letters to the editor, 7.9% review articles, and 44.6% documents that were classified as other types of publications. The retrieved documents were published in 162 peer-reviewed journals, by scientists from 27 countries. These authors also found that FDA was the most productive institution for articles related to ecigs.
All 356 documents discussed by Zyoud et al (2014) should be mandatory reading for any professional and/or regulator with a serious and honest commitment to improving public health and reducing smoking rates. All ought to be critically reviewed, referenced, and thoroughly discussed by any evidence-based regulatory document related to ecigs. The critical review ought to be performed by qualified, impartial scientists with the motivation and ability to distinguish slanted junk science and deceptive inference from rigorous studies employing the scientific method, using appropriate analyses, and coming to defensible conclusions. None of these appear to apply to the current version of the proposed deeming regulation.
The FDA has a mandate and a moral obligation to protect public health by actively seeking and critically reviewing all the available evidence, as well as funding additional research that will further improve our understanding of ecigs. Researchers who are not conflicted by any current or previous association with tobacco control, pharmaceuticals, or Big Tobacco should be supported and encouraged to pursue these studies. Continued improvement and innovation of electronic cigarettes is in the interest of public health, not snubbing them by deeming as tobacco products.
The proposed deeming regulations would remove more than 99% of electronic cigarette (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. This is because many of its premises are constructed on faulty assumptions (http://link.springer.com/article/10.1007/s00204-013-1127-0), junk science (http://tobaccoanalysis.blogspot.com/2014/05/glantz-review-article-is-little-more.html), and unsubstantiated propaganda (http://tobaccoanalysis.blogspot.com/2014/03/new-study-on-electronic-cigarettes-by.html) from the tobacco control industry (TCI).
One of the most flagrant exaggerations perpetrated by TCI and unfortunately reiterated numerous times by this proposed regulation is in the assertion that little or nothing is known about ecigs, that health effects are completely unknown, and that very little research had been done on the subject. These statements are demonstrably false in light of the recent systematic literature review published by Zyoud et al (2014; http://www.biomedcentral.com/content/pdf/1471-2458-14-667.pdf). These authors searched for all available peer-reviewed literature on the subject of ecigs and retrieved 356 documents, among which 31.5% were original journal articles, 16% letters to the editor, 7.9% review articles, and 44.6% documents that were classified as other types of publications. The retrieved documents were published in 162 peer-reviewed journals, by scientists from 27 countries. These authors also found that FDA was the most productive institution for articles related to ecigs.
All 356 documents discussed by Zyoud et al (2014) should be mandatory reading for any professional and/or regulator with a serious and honest commitment to improving public health and reducing smoking rates. All ought to be critically reviewed, referenced, and thoroughly discussed by any evidence-based regulatory document related to ecigs. The critical review ought to be performed by qualified, impartial scientists with the motivation and ability to distinguish slanted junk science and deceptive inference from rigorous studies employing the scientific method, using appropriate analyses, and coming to defensible conclusions. None of these appear to apply to the current version of the proposed deeming regulation.
The FDA has a mandate and a moral obligation to protect public health by actively seeking and critically reviewing all the available evidence, as well as funding additional research that will further improve our understanding of ecigs. Researchers who are not conflicted by any current or previous association with tobacco control, pharmaceuticals, or Big Tobacco should be supported and encouraged to pursue these studies. Continued improvement and innovation of electronic cigarettes is in the interest of public health, not snubbing them by deeming as tobacco products.
