Action regarding FDA: No banter here, please

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KDMickey

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Ok, this is all in another thread, but that thread has degenerated into silliness. I'm ok with silliness, but I really take the FDA issue seriously, and I would appreciate some help from all of you in addressing this issue. I sent this to Dr. Nitzkin of the American Association of Public Health Physicians. The e-mail goes as follows.
Dr. Nitzkin,

I stumbled across the letter which was posted by you on jointogether.org regarding the FDA tobacco bill. I find your arguments for implementation of harm-reduction as the method of choice regarding tobacco intake very compelling.

I decided to contact you because I have recently been worrying about the FDA banning a smoking alternative called the e-cigarette (or, I prefer, the Personal Vaporizer). Personal vaporizers use a mixture of propylene glycol and nicotine to deliver a smoking-like sensation without tobacco. As such, the product contains none of the 60 known carcinogens in tobacco (or the 3000+ other chemicals). And, of course, despite the exhalation of a smoke-like vapor, the personal vaporizer leaves no second-hand smoke in the air.

Currently, some very powerful senators are pushing the FDA to stop the importation of personal vaporizers. The claim is that the safety of the product is unknown. While I understand this take, I find it unlikely that a product with no carcinogens could be as great a health risk as continuing to smoke tobacco! I do, however, find it somewhat likely that pharmaceutical and tobacco companies both have an interest in stopping the product from catching on in the U.S.

I humbly request the support of Public Health Physicians in preventing the FDA from banning the product. I know that several hundred smokers have either significantly reduced or quit their cigarette habit with this product. Many of these individuals have been 1-2 pack a day smokers for over 20 years and have quit smoking entirely with the personal vaporizer. As a former smoker, I can say that traditional nicotine replacement therapies fail to appreciate the gratification the act of smoking brings. The personal vaporizer delivers that satisfaction with, I believe, a significantly reduced health risk. I cannot say how grateful I feel to know that my infant son does not get exposed to the smoke in my clothing or vehicle anymore!

For more information about personal vaporizers, I would recommend looking at www.e-cigarette-forum.com.

Regards,
-Kyle Mickey

A few hours later, I received this reply:

Kyle:

Thanks for your note.

I agree.

I am now in the process of drafting a response to Senator Lautenberg's proposal. I'll make sure to copy you.

Meanwhile, there are some issues that the e-cigarette manufacturers and vendors should address from a public health perspective:

1. Is there any data as to the age of purchasers -- most particularly below 18 years of age.
2. What standards are in place to assure freedom from bacterial and heavy metal contamination of the product during the manufacturing process? While the Ruyan company may be responsible with regard to these issues -- what process, if any, is in place to prevent less scrupulous manufacturers from producing look-alike products that might be heavily contaminated?
3. Has any effort been made by vendors or manufacturers to detect and document adverse effects of the e-cigarette relative to both health and fire-hazard related issues.?

Joel L. Nitzkin, MD, MPH, FACPM
Chair AAPHP Tobacco Control Task Force
(AAPHP = American Association of Public Health Physicians)

Still later, Dr. Nitzkin sent me a copy of the fax going to the senator wanting to outlaw e-cigarettes:
Draft FAX
March 25, 2009
To: Senator Lautenberg, with copies to all House and Senate Members, AAPHP list-serve, Tobacco control advocates and others
Subject: Open letter to Senator Lautenberg Opposing his proposed ban on electronic cigarettes
Honorable Senator Lautenberg:
In my capacity as Chair of the Tobacco Control Task Force of the American Association of Public Health Physicians, I must vigorously oppose your proposed ban on electronic cigarettes.
Conventional cigarettes kill about 400,000 adult American Smokers each year from cigarette-related illness. Over the next 20 years this will total 8 million deaths among current adult smokers, most of which are now over 35 years of age. Cigarettes kill about 30% of consistent adult cigarette smokers.
Smoking cessation rates among these smokers are abysmal –about 3% per year. Pharmaceutical products with counseling, quit lines, etc, are little better – resulting in quit rates no greater than 5% (as measured at 12 months post-intervention) among those willing to try these modalities. In other words, current approaches fail 95% of smokers using them.
Adult American smokers are health conscious, as evidenced by the fact that about 85% of them have switched to light and low-tar cigarettes, believing (incorrectly) that they pose less health risk.
Research to date has clearly demonstrated that smokers smoke because they are addicted to nicotine. This same research also shows that the illness and death due to cigarettes is not due to the nicotine, but due to products of combustion and, to a lesser degree, toxins in the cigarette tobacco.
Alternative nicotine delivery devices, including, but not limited to electronic cigarettes, have no products of combustion and none of the toxins in cigarette tobacco. On at least a theoretical basis, they could and should be seen as generic equivalents of the pharmaceutical nicotine products. As best we can tell, on the basis of currently available research data, these products promise a risk of illness and death well under 1% of the risk posed by cigarettes.
Stated another way – simply informing current adult smokers that they could dramatically reduce their risk of tobacco related illness and death by switching to alternative near-zero-risk nicotine delivery products could possibly save 4 million or more of the 8 million current smokers who will otherwise die of a tobacco-related illness over the next 20 years.
Both houses of Congress now seem poised to pass an FDA/Tobacco bill (H.R.1256 in the House). This bill, if passed in its current form will provide, at least on an interim basis, the FDA seal of approval on currently marketed cigarettes. That being the case, the safety standard that should be used for other tobacco products, and for alternative non-pharmaceutical nicotine delivery devices, should the hazard posed by cigarettes, not a pharmaceutical safety guideline.
All tobacco and nicotine delivery devices should be held to the same safety guideline. Exempting cigarettes, while holding alternative nicotine delivery devices to an impossibly stringent safety guideline, will not protect current American smokers. It will only protect Altria/Philip Morris cigarette sales and profits.
On behalf of the Tobacco Control Task Force of the American Association of Public Health Physicians, I therefore urge to consider the following:
Withdraw your proposal to ban electronic cigarettes.
Urge amendment of the proposed FDA/Tobacco bill to encourage the development and marketing of safer alternatives to cigarettes, under strict but fair FDA oversight, and with marketing restrictions in place to reduce the numbers of adolescents who initiate use of cigarettes and other nicotine delivery products.
The amendments we think will achieve these goals, and the results of our analyses and literature reviews, are posted on the tobacco issues page of our Tobaccolegfeb07 web site.

Joel L. Nitzkin, MD, MPH, DPA, FACPM
Chair, Tobacco Control Task Force
American Association of Public Health Physicians

In this thread, please only post if you can provide suggestions for the contents of the fax to the senator and/or information regarding the safety concerns of personal vaporizers.

Cheers,
-Mickey
 

brandeeashlynn

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Storyspinr

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Mickey, there is one line in the fax that makes no sense to me - sounds like something was left out. It reads: "This bill, if passed in its current form will provide, at least on an interim basis, the FDA seal of approval on currently marketed cigarettes. That being the case, the safety standard used for other tobacco products, and for alternative non-pharmaceutical nicotine delivery devices, should the hazard posed by cigarettes, not a pharmaceutical safety guideline". Should the 2nd sentence not read "That being the case, the safety standard used for other tobacco products, and for alternative non-pharmaceutical nicotine delivery devices, should BE the hazard posed..." ??? (add "be" before "the hazard posed" - can't get the bold or underline to work on this message window). It seems like a rather small but critical missing word.
 

KDMickey

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Mickey, there is one line in the fax that makes no sense to me - sounds like something was left out. It reads: "This bill, if passed in its current form will provide, at least on an interim basis, the FDA seal of approval on currently marketed cigarettes. That being the case, the safety standard used for other tobacco products, and for alternative non-pharmaceutical nicotine delivery devices, should the hazard posed by cigarettes, not a pharmaceutical safety guideline". Should the 2nd sentence not read "That being the case, the safety standard used for other tobacco products, and for alternative non-pharmaceutical nicotine delivery devices, should BE the hazard posed..." ??? (add "be" before "the hazard posed" - can't get the bold or underline to work on this message window). It seems like a rather small but critical missing word.

Thank you storyspinr, but I do not think we should be so worried about editing issues. I have confidence that the organization will catch those sorts of errors. What I am really looking for is content, here. What would you want the FDA to know? (i.e. the New Zealand study, TW and JC content tests, etc.) How about contacting manufacturers and asking about measures to insure against contamination with heavy metals? etc., etc.
 

deewal

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Great job Mickey and @Storyspinr..I had trouble trying to understand that very passage.
We need to address the below asap.

1. Is there any data as to the age of purchasers -- most particularly below 18 years of age.
2. What standards are in place to assure freedom from bacterial and heavy metal contamination of the product during the manufacturing process? While the Ruyan company may be responsible with regard to these issues -- what process, if any, is in place to prevent less scrupulous manufacturers from producing look-alike products that might be heavily contaminated?
3. Has any effort been made by vendors or manufacturers to detect and document adverse effects of the e-cigarette relative to both health and fire-hazard related issues.?

I know Jason at Wicked has the results of Tests he has had done on the Liquid.
His Safety measures and his Selling Methods would be a fine example of a Responsible Supplier.
How difficult would it be to get tests done on the "bacterial and heavy metal contamination of the product"?
It can't be that difficult can it ?
What can Members do to help in this matter?
Let us know.
 

Wally

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b00stzx3

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chokmah

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Is there a way to add something like this in there?

Instead of this being about us and our health I think it may be more productive to harp on the health of the general public. Non smokers can get cancer from second hand smoke and the vaporizers dont have that and therefore we that vape are helping non smokers be less likely to get cancer as we dont smoke we vape.. This is the idea we should be trying to voice to congress as not all of them smoke but may be around it.

And a suggestion to us all...

We should respect the smoking laws and smoke where its permitted but at least this way we are not causing any harm to anyone but possibly ourselves which is much better than what we did when we did smoke analogs..

Just thoughts I hope this is the correct place to add this otherwise please move it to the correct area or delete it and tell me where it should be posted.
 

StratOvation

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Excellent letter Mickey....well thought out, concise and worded well.

Do you know what type of data he is looking for re. <18 yrs. ? Preventative measures currently in place and being practiced by US suppliers? Number of <18's buying them? Avgerage age of all purchasers?

Any age related Historical type data or studies/research that would carry any real weight would probably have to come from one of the european countries with a more mature market, as the US market seems to have just recently begun see a notable growth.

I've not personally had any communication with him, But I've read several threads on these forums regarding a Chinese supplier named David Yang who owns an intrest in a China based e-liquid supplier. He may be able to share some "In House" manufacturing knowledge re. safeguards to prevent product contamination...There may be some "generally accepted standard operating procedures" that most or all of the Chinese suppliers tend to follow. It seems to me that Mr. Yangs website was called eastmall? not sure but something like that.

Also Janty has a video clip on their website touting their manufacturing facilities and high level of quality standards practiced in the manufacturing of their products. Some of their video and still photos actually resemble a "Clean Room" type of production environment. JantyShop They may be willing to share some info also, They would be a great "Global representative" as they have facilities around the world... Assuming, of course, that they are not overstating their strict adherance to the "Highest Standards in product quality".

I'm running late and need to get going, but if I think of anything to add I will revisit this thread again asap.

Best Wishes in your endeavor,
Mike
 

KDMickey

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Ok, I sent a follow up to Dr. Nitzkin.
. Nitzkin,

Sorry it has taken me so long to get back to you. I have tried to research some of the public health concerns you have mentioned.

http://www.karr-tv.com/E-smoking.pdf

This article, though long, describes some of the advantages of e-smoking. It also summarizes and provides links to some of the research that has been done to date. I have an e-mail to the manufacturer, Smoore, of the M401 model (one of the better and more popular models).

I know that several manufacturers of e-liquid have conducted some tests on their product to ensure safety, including Janty, TotallyWicked, and Johnson's Creek.

As far as age restrictions go, I know that most web vendors require a credit card/paypal to use. I do think we need to be more regulated in some regards--but that does not support banning the product. What ever happened to free-market, anyways?

As far as safety goes, in the long-term, the effects of propylene glycol have been well documented in rats and apes.

This is a toxicology report from analysis of e-liquid: http://www.supersmokerjp.com/images/ToxicologylaboratoryTestResultsEnglishtranslatiion.pdf

Here is the famous New Zealand Health study, which pertains to Ruyan (who funded the research): http://www.healthnz.co.nz/2ndSafetyReport_9Apr08.pdf

This talks about the use of propylene glycol as an air sanitizer: Air Germicide - TIME
and is discussed further in the post: http://www.e-cigarette-forum.com/fo...king/1734-germ-killing-vapor-4.html#post28735

I wish I could address some of your concerns more directly, but unfortunately I'm a guinea pig, as are my fellow e-smokers. But the thought is this: Can it really be WORSE than tobacco?

Thank you so much for your support on this issue.

Regards,
-Kyle Mickey

Please, people, send me more answers to these concerns. It will help us all in the long run.

Cheers,
-Mickey
 

TropicalBob

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Kyle, I'm pleased you found some material I've written. That long article appeared in the October issue of SmokeShop magazine, a trade publication for the tobacco industry.

I posted some long commentary today, and you might find material toward the end useful in arguing for regulating e-smoking, not banning it. I'm going to post the lengthy commentary here, for your benefit. Use it as you see fit.

Here's the problem: A ruling will likely be all inclusive. The FDA likely -- likely -- won't issue piecemeal rulings on parts of the device, the carts, the liquids, the whole nine yards. The FDA has said these are drug-devices. The drug is NOT nicotine, but that poisonous and addictive substance -- a drug -- is in a concoction of many ingredients, all vaporized and inhaled without any scientific proof of the consequences. We call it e-liquid. This drug cocktail has not been approved for sale in this country.

Should sales be allowed to continue when this country carefully spells out how drugs can be brought to market and sold?

Let's say the FDA allows the present situation to continue. It will have, in essence, approved the manufacture and sale of unknown, untested, unproven drugs from China for U.S. consumers.

It will have approved containers that aren't childproof, but a half-thimble of e-liquid will kill a child. It will have approved containers that aren't tamperproof, so they could be easily contaminated at any point prior to sale. It will have approved liquids without proper labeling of content, danger, side effects, place of manufacture. It will have approved a device that is easily broken apart to remove a cartridge so small a three-year-old could swallow it.

It will have approved a new, cheap, unapproved, unregulated addiction system for nicotine, where approved systems delivering nicotine have already sought and been given FDA approval.

It will tacitly allow recreational use of nicotine, a drug it calls both poisonous and highly addictive.

That's if it sides with us, as we are petitioning it to. I do not see that happening. That's irresponsible on its face.

Here's the best I hope for: The FDA allows that e-cigs have done no demonstrable harm in the past year, with hundreds of thousands of users now e-smoking daily. It will realize that these e-smokers are doing what they think is best for them, and their health. It acknowledges a low success rate with existing NRT products. It knows tobacco cigarettes are hazardous. It can only make assumptions about e-cigs.

So it gets mad, to be sure, at what is now the reality. It issues demands much as Congress makes to automakers with fleet fuel efficiency standards. The demands are spelled out, with a timetable for each.

Eg. You have 30 days to childproof and tamperproof your liquid containers or they cannot be sold in the U.S. You have 30 days to prove a person under 18 cannot purchase from your site or sales location. You have 60 days to label e-liquid with all relevant information, with prominent poison warning labels for first responders.

Each step gets a timetable to be met. The final step would be for each manufacturer to submit evidence -- as should have been done last year -- that a particular device and liquid is safe and efficient when used as directed. That would be a year from now. Give this one more year.

E-smoking needs only time to become the smoking method of the future. If killed now, it will likely experience years of delay -- and needless illnesses and deaths of smokers -- until a successful marketing attempt is made. It will return. That might be too late for many.

From all this, take that the present situation is essentially indefensible, in my opinion. It is untenable. It should not have been allowed to remain as long as it has. But be open to change that brings assurances of safety. It's not your "rights" that are being stolen; it's your welfare that is being guarded by drug regulators.

It's not a game without rules. Yours don't trump the ones we've had for many years, the ones designed to protect us all from unscrupulous snake oil salesman. No matter how you phrase it, you do not have a Right to Snake Oil.

I guess what I'm asking for is "delay of trial". I'm asking to buy time so e-smoking has a chance to prove its value. I really see no point in trying to make a senator back down. My argument would be with the FDA. We can only hope minds aren't made up there.
 

Faethe

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Thank you storyspinr, but I do not think we should be so worried about editing issues. I have confidence that the organization will catch those sorts of errors. What I am really looking for is content, here. What would you want the FDA to know? (i.e. the New Zealand study, TW and JC content tests, etc.) How about contacting manufacturers and asking about measures to insure against contamination with heavy metals? etc., etc.


Ask him if he can suggest guidelines the resellers can implement.

A list would be nice.

I would also stress that everyone is willing to co-operate with his suggestions.

Part of the problem with selling these is that no one has received positive feedback from regulatory bodies, or guidance. There are many misconceptions based on insufficient evidence.

Ask him how that can be countered.
 

KDMickey

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Dr. Nitzkin has sent the following to me and other advocates regarding tobacco policy:
Dear Executive Committee and Selected Tobacco Control Advocates:

Anticipating the possibility that these bills will come up for consideration on the House Floor early this next week, I have formulated the attached document to express our position on both these bills.

Basically, AAPHP is against both of them on the grounds that, if passed in current form, they will do more harm than good from a public health perspective. We do however, support amendment of the Waxman bill, as described in the attachment to secure major public health benefits.

Please distribute this as widely as you can to secure as much coverage of the house, and possibly news coverage as possible.

Some of you may have received a draft communication to Senator Lautenberg re e-cigarettes a few days ago. After due consideration, I have opted to send that directly to Lautenberg, and go with the attached statement for our advocacy efforts this next week.

Please feel free to contact me with any questions or comments.

Thanks for your support in this endeavor.


Joel L. Nitzkin, MD, MPH, FACPM
Chair AAPHP Tobacco Control Task Force
c/o JLN, MD Associates LLC
4939 Chestnut Street
New Orleans, LA 70115-2941

The attached document:

  • March 27, 2009
  • To: All Concerned
  • From: Joel L. Nitzkin, MD, MPH; Chair AAPHP Tobacco Control Task Force
  • Subject: Tobacco Control Legislation: H.R.1256 and H.R.1261
There are currently two bills before the House dealing with Tobacco and Health. One is Waxman’s FDA/Tobacco bill – H.R. 1256. The other is Buyer’ Tobacco Harm Reduction Act, H.R.1261. Both are so severely flawed that, if passed as currently proposed, they would be worse than no bill at all, from a public health perspective.
The public health perspective that we used as a yardstick with which to estimate the likely impact of each of these bills is the anticipated impact of the legislation on future tobacco-related illness and death.
Our surprising conclusions are based on analyses and extensive research done by our Tobacco Control Task Force of the American Association of Public Health Physicians. Our findings and conclusions are presented in detail in a series of documents on the tobacco issues page of our www.aaphp.org web site.
Waxman’s bill, as negotiated on his behalf by Campaign for Tobacco Free Kids (CTFK) and Altria/Philip Morris, so limits the authority of the FDA that Altria/Philip Morris could easily block any proposed regulation not to their liking. Even worse, however, is the fact that the bill would grant at least interim FDA approval to currently marketed cigarettes, while placing impossibly stringent barriers against the introduction of near-zero-risk tobacco and tobacco-related products.
If the summary of this bill used by CTFK and friends to recruit co-sponsors and endorsing organizations accurately reflected the content of the bill, we would enthusiastically endorse it. Unfortunately . . .
For our analysis of this bill, please see the tobacco issues page at www.aaphp.org.
Buyer’s bill (H.R.1261), while appropriately regulating lower risk tobacco products, is fatally flawed in not imposing adequate restrictions on tobacco marketing.
AAPHP therefore recommends a set of amendments to the Waxman bill that will 1) enable and encourage current smokers who are unable or unwilling to quit to switch to near-zero-risk nicotine-delivery products; 2) strengthen the regulatory authority of the federal regulatory agency; 3) provide for needed health education, surveillance and research; and 4) Reconsider FDA as the federal regulatory agency. In addition, we recommend simultaneous passage of legislation that will restrict and punish manufacture and marketing of illicit, counterfeit and otherwise contraband tobacco and tobacco-related products. The details are spelled out in the Amendments document on the tobacco issues page at www.aaphp.org.



The facts are these:
  1. Conventional cigarettes kill about 400,000 adult American Smokers each year from cigarette-related illness. Over the next 20 years this will total 8 million deaths among current adult smokers, most of which are now over 35 years of age.
  2. These deaths are all due to cigarettes, with death rates from all other tobacco products too few for such ready tabulation. The problem is not tobacco. The problem is cigarettes.
  3. Smokers smoke because they are addicted to nicotine. The illness and deaths, however, are not due to the nicotine. They are due to unrelated products of combustion, and, to a much lesser degree, toxins inherent in tobacco leaf.
  4. Smoking cessation rates among smokers are abysmal –about 3% per year. Pharmaceutical products with counseling, quit lines, etc, are little better – resulting in quit rates no greater than 5% (as measured at 12 months post-intervention) among those willing to try these modalities. In other words, current approaches fail 95% of smokers using them. The only feasible way to reduce illness and death in this 95% of current adult smokers will be to enable and encourage them to switch from cigarettes to near-zero-risk nicotine delivery products
  5. Adult American smokers are health conscious, as evidenced by the fact that about half use light and low-tar cigarettes, most believing (incorrectly) that they pose less health risk.
  6. Substantial research has already been done and published to demonstrate the comparative risk of cigarettes and a variety of other tobacco products – at least one of which (snus) is near-zero-risk. (see Harm Reduction Paper on tobacco issues page, www.aaphp.org)
  7. A variety of non-pharmaceutical alternative nicotine delivery products are already on the market or in various stages of development and market testing. These include sticks, strips, orbs, lozenges and e-cigarettes. The information available suggests risk and benefit profiles similar to widely accepted pharmaceutical nicotine replacement products.
  8. Holding the snus and alternative nicotine delivery to the research standards of pharmaceutical products would cost the manufacturers millions of dollars per product and would deny current smokers the benefits of these products for a decade or more. Furthermore, such studies probably could not be conducted at current American academic centers because Institutional Review Board (IRB) guidelines would likely prohibit case/control studies on products with no therapeutic benefit. Thus, the seemingly reasonable research standards in the Waxman bill would likely result in a de-facto ban on all such products. AAPHP therefore favors the research guidelines from the Buyer bill.
  9. Since both the Waxman and the Buyer bills would approve currently marketed cigarettes – the most hazardous of all tobacco products, the standard for lower risk products for use by current smokers should be the hazard posed by cigarettes, not a pharmaceutical safety standard.
Given these facts, the legislative challenge then becomes how to encourage and enable current smokers to switch to near-zero-risk products without increasing the numbers of teens who initiate tobacco use. AAPHP believes this can be done by imposing a marketing restriction beyond those included in the Waxman bill, as described in our Amendments document on the tobacco issues page at www.aaphp.org.
Joel L. Nitzkin, MD

Anyways, I feel like we do have some powerful support here.

Dr. Nitzkin also explained how the FDA has authority over e-cigarettes:
FDA authority is based on the claims of the manufacturers, not the content of the product. Under current law, if a product claims health benefits but has no acceptably scientific studies to back them up FDA can either force the product off the market or force the manufacturer to amend its labeling and marketing.
The studies needed are studies in human subjects that demonstrate both the safety and efficacy of the product. Lab analysis of the product -- while pertinent to the quality and sanitation of the manufacturing process are simply not sufficient from an FDA perspective.

So it seems to me we need to address some of these issues.

Cheers,
-Mickey
 

KDMickey

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Easily the most knowledgeable and logical argument I've read anywhere. That is just brilliant. Let's hope for a delay while details that should have been addressed before any product was marketed are indeed completed to regulatory agency satisfaction.

Thats why we pay these guys the big bucks :D

But I could not agree more. I feel Dr. Nitzkin deserves our appreciation.

I am also thinking it is time to petition to support Dr. Nitzkin's recommendations. Please send your reps and senators a copy of this release and a statement of your support for these recommendations.

Cheers,
-Mickey
 

lordmage

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well worded and concesice
my humble suggestion is a call to all current manufactuers and suppliers to remove the current claims of health and safety benefits. unless from a personal side. example my own experenice with E-smoking is... not is a benfit to your health. possible a re wording of the safer alternative some sites list i think the word safer needs removed till studies can be concluded. that could actually help in the interm from FDA control
 

Steph2323

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Thats why we pay these guys the big bucks :D

But I could not agree more. I feel Dr. Nitzkin deserves our appreciation.

I am also thinking it is time to petition to support Dr. Nitzkin's recommendations. Please send your reps and senators a copy of this release and a statement of your support for these recommendations.

Cheers,
-Mickey

Mickey, Thank you so much for advocating for all of us. I will be forwarding a copy of this along with a personal note from me to my reps and Pa Senators tomorrow.
Stephanie
 

Steph2323

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I would love to see Smokey replace the petition suggestion with your suggestion.
It was actually Mickey who made the suggestion to forward this to our legislators. I think the petition is ok, but we need to add to our effort. This work done by Mickey is a great place to start.
Stephanie
 
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