My views on the ANPRM, described in greater detail
below, can be summarized as follows:
1.
The increase in the number of calls to poison control centers related to e-cigarettes is not the best metric for determining the need for and appropriateness of exposure warnings and child-resistant packaging requirements for e-cigarettes. FDA should rely instead on comparative data that quantify the risks posed by these nicotine products relative to other household products and impose restrictions and requirements according to these relative risks.
2.
There is a real risk of unintended consequences should customers take exposure warnings to mean that the appropriate use of e-cigarettes poses harms or risks akin to
tobacco. Traditional cigarettes are known to contain many potent carcinogens that are not present in liquid nicotine. Moreover, second-hand smoke poses known and serious risks for bystanders, especially young children, and the fire-related risk from cigarettes poses additional serious safety
threats. If exposure warnings discourage people from switching from traditional cigarettes to e-cigarettes, greater harm to children—not to mention smokers and other bystanders—may be imposed by these regulations.
