Here's my three minute presentation during the public comment period.
FDA Electronic Cigarettes and the Public Health: A Public Workshop
June 1 & 2, 2015
Testimony by
William T Godshall, MPH
Executive Director
Smokefree Pennsylvania
1926 Monongahela Avenue
Pittsburgh, PA 15218
412-351-5880
BillGodshall@verizon.net
I’m Bill Godshall, founder and executive director of Smokefree Pennsylvania. Since 1990, we’ve successfully campaigned to ban smoking in workplaces, stop cigarette marketing to youth, increase cigarette tax rates, and require the FDA to impose a regulation for large color graphic warnings on all cigarette packs, which the FDA doesn’t deem important.
In 2010 we filed an amicus brief with other public health advocates opposing FDA’s e-cig import ban with the DC Court of Appeals, which upheld Judge Richard Leon’s 2010 ruling striking down FDA’s ban as unlawful.
Since 2011, we’ve opposed the FDA’s proposed “deeming” regulation because it would ban >99.9% of nicotine vapor products, protect cigarettes, increase smoking, threaten the lives of several million vapers and tens of millions of smokers, and create a huge black market for totally unregulated vapor products.
For disclosure, neither Smokefree Pennsylvania nor I have ever received any funding from any tobacco, drug or vapor product company, nor from any government agency whose policy is to ban vapor products, which is also a conflict of interest.
The scientific and empirical evidence consistently finds nicotine vapor products are 99% (+/-1%) less hazardous than cigarettes, have never been associated with any disease, and pose no known risks to nonusers.
Nicotine vapor products have already replaced >3 Billion packs of cigarettes, and >99% of nicotine vapor products are consumed by smokers or by ex-smokers who switched to vapor products, which are more effective and pose fewer risks than FDA approved smoking cessation drugs.
Adult and teen surveys consistently find that smokers and ex-smokers account for >90% of past 30 day e-cig users. It appears that >99% of daily vapers are smokers or ex-smokers who switched to vaping, but DHHS funded surveys still don’t inquire about daily vaping or even if nicotine was vaped, which has only served to bury the truth.
Two recent surveys found that 3 and 4 million US smokers respectively are no longer regular smokers because they switched to vapor products. Thus, it is mathematically impossible for vapor products to harm overall public health, even if every nonsmoker in America began vaping daily.
And yet, there’s no evidence vapor products have created daily dependence in any nonsmoker, nor is there any evidence vaping has served as a gateway to daily cigarette smoking for anyone.
But since 2009, the FDA and CDC have made many false and misleading fear mongering claims to confuse, scare and lobby to ban these lifesaving products under the deceitful guise of protecting children and public health. Dozens of DHHS funding recipients have also misrepresented the scientific evidence to scare the public to lobby to ban vapor products and/or vaping, including most presenters and panelists FDA has invited to speak at its three so-called public workshops on e-cigarettes.
The FDA should stop protecting cigarettes, and begin to protect public health.
