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I prepared the following outline for a presentation I was invited to give at SFATA's E-Cig Summit 2013 in Las Vegas two days ago.
But the presentation was never given because SFATA Executive Director Chris Venis decided to extensively edit it (including eliminating the first half of the presentation) without my permission.
E-Cig Summit 2013
January 28, 2013
Las Vegas
Presentation by
Bill Godshall
Executive Director
Smokefree Pennsylvania
1926 Monongahela Avenue
Pittsburgh, PA 15218
412-351-5880
smokefree@compuserve.com
[h=3]History of FDA tobacco Regulation [/h]
David Kessler's 1996 Final Rule, 1998 defeat of Sen. McCain’s bill to enact Global tobacco Settlement, 2000 SCOTUS strikes down 1996 tobacco regs and FDA authority, 2001/02 & 2003 Waxman/Kennedy bills, Philip Morris' 2002/03 cooption bills, 2003/04 negotiated agreement by PM/CTFK/ACS/AHA/ALA/Kennedy/Waxman for FSPTCA legislation, House & Senate bills in 2004, 2005/06, 2007/08 and 2009 (changed new product date until 2007), Amendments (graphic warnings, clove cig ban, smokeless free distribution, dissolvables report), UST/SM opposed till 2007 free distribution and PM purchase, Reynolds/Lorillard/ACSH/AAPHP/Smokefree PA opposed till 2009 enactment.
[h=1]Obama Administration Actions Against E-cigarettes[/h]
2009 FDA import ban, SE/NJOY lawsuits, July 22, 2009 press conference, Judge Leon's January 2010 opinion, 2010 amicus brief supporting SE/NJOY by health advocates and e-cigarette consumers, FDA September 10, 2010 letter to 5 e-cig companies, Appeals Courts uphold Judge Leon's ruling, FDA concedes on April 25, 2011 and states intent to propose "deeming" regulation, subsequent derogatory FDA statements about e-cigarettes and risks.
US DOT 2011 announced then proposed e-cig usage ban (regulation) on airlines, CASAA, WLF, Smokefree PA comments stating regulation unlawful, no final regulation issued yet.
E-cigarette use ban at DHHS and US military facilities.
[h=1]FDA Deeming Regulation[/h]
Section 901(b) This chapter shall apply to all cigarettes, cigarette tobacco, roll-your-own tobacco and smokeless tobacco and to any other tobacco products that the Secretary by regulation deems to be subject to this chapter.
FDA first stated intent to issue "deeming" regulation in 2010 for cigars, April 25, 2011 notice for e-cigs, Summer 2011 notice of intent to propose "deeming" regulation in 10/2011, Spring 2012 notice of intent to propose "deeming" regulation in Summer 2012, recent FDA notice of intent to propose "deeming" regulation by April 2013.
E-cigarettes can now be marketed without violating FDCA as long as manufacturer or importer doesn't make "therapeutic claim" about product. Since "smoking" is not a disease or disorder, a "smoking cessation" claim by a manufacturer shouldn't violate the FDCA, but FDA claims otherwise. Courts won’t consider issue till company challenges FDA.
FDA "deeming" regulation would apply to cigars, pipe tobacco, shisha/hookah tobacco, e-cigarettes, dissolvables, skin creams and other currently unregulated tobacco products. Large/premium cigar exemption legislation (House bill with 230 sponsors).
Proposed "deeming" regulation would include definitions for all categories of newly regulated products, including e-cigarettes; FDA may call ENDS, e-cigarettes or other.
FSPTCA Chapter IX provisions that would most negatively impact e-cigs
Sections 905(j) and 910 would ban all e-cigarette products not on the market prior to February 15, 2007. To avoid litigating/losing another lawsuit, FDA may change 2007 grandfather date to 2103 for newly regulated products, but that would/could forever ban all new e-cigs on market, as FDA hasn’t approved any "substantially equivalent" applications for cigarettes or smokeless. FDA policy basically opposes ALL new tobacco products.
Section 911 would prohibit e-cigarette manufacturers/importers from truthfully claiming products are less hazardous than cigarettes, or that products don't contain or emit a substance, as only "Modified Risk Tobacco Products" (MRTP) can make those claims. If FDA doesn’t amend Section 911(b)(2)(C) to exempt e-cigarettes (in addition to smokeless tobacco), manufacturers couldn’t even claim e-cigarettes are "smoke free" or emit "no smoke". To make MRPT claim, manufacturers must spend tens of millions of dollars on unnecessary and speculative research to submit applications, and hope for approval. PM, SM and Reynolds might submit MRTP applications for smokeless tobacco products.
Section 915 would require e-cig manufacturers to test and report constituents, ingredients, additives for each brand and subbrand, may require testing of every manufactured batch.
Section 919 would NOT require e-cigarette manufacturers to pay regulatory fees to FDA, but FDA may amend to require fees.
Section 900 defines "Tobacco Product Manufacturer" as "any person, including any repacker or relabeler, who manufactures, fabricates, assembles, processes, or labels a tobacco product" and anyone who "imports a finished tobacco product for sale or distribution in the US." Thus, "deeming" regulation likely to cause acquisitions, consolidations, disappearances of hundreds of e-cigarette companies.
Title 1, Section 101 "Tobacco Product" defined as "any product made or derived from tobacco that is intended for human consumption, including any component, part, or accessory of a tobacco product." Thus, FDA "deeming" regulation would/could result in regulations on any component, part or accessory of e-cigarette products, potentially including hardware, cartridges, batteries, rechargers, etc.
[h=1]
Potential Additional FDA Regulations for E-cigarettes[/h]
[h=1]Ban Sales to Minors, and Most Marketing to Adults[/h]
If FDA amends Section 102 Final Rule (i.e.1996 Rule) to include e-cigarettes
- e-cigarette sales to minors under 18 would be banned, FDA would conduct compliance inspections of retailers (100,000 already conducted), warning letters and subsequent fines,
- unless exempted by FDA in Section 906(d)(4)(A)(i), could ban most/all non-face-to-face-sales of e-cigarettes, perhaps ads, promotions and sponsorships on Internet. In Sept 2011, FDA issued advance notice of proposed rulemaking (ANPRM) requesting comments, data, research, or other information related to non-face-to-face sale and distribution of tobacco products; advertising, promotion, and marketing of such products; and advertising of tobacco products via the Internet, e-mail, direct mail, telephone, smart phones, other communication technologies that can be directed to specific recipients.
and
- ban self service displays of e-cigs (i.e. behind the counter) if minors are allowed in store,
- ban sale/distribution of brand-identified promotional item or service (shirts, hats, etc.),
- ban brand name sponsorship of athletic, musical, artistic, other social or cultural events,
- could ban giving free samples of e-cigs to adults, ban/restrict outdoor advertisements,
- FDA may have legal authority to also ban television and radio ads for e-cigarettes,
- could limit advertising exposed to youth to black-and-white, text-only format, but a federal judge and appeals court have already ruled this provision unconstitutional.
[h=1]Maximum Nicotine Level/Amount[/h]
FDA may propose new regulation to limit the amount and/or concentration of nicotine in e-cigarette products. If FDA proposes same or similar limits as were proposed in EU Tobacco Products Directive (i.e. no more than 4mg/ml nicotine, no more than 2mg of nicotine in any e-cigarette product sold to consumers), all e-cigarettes now marketed would be banned except no-nicotine e-cigarettes, and all e-liquid products. No known nicotine deaths, no known lethal dose, false claims, Green Tobacco Sickness. (24mg/ml = 2.4%)
[h=1]Flavoring Restrictions[/h]
FDA may propose new regulation to ban some/most/all flavorings in e-cigarette products. FSPTCA now just bans certain flavorings in cigarettes (that comprised 1% of flavored cigarettes in 2009, including clove). There is NO evidence flavored tobacco products (including e-cigarettes) are marketed to youth, but anti tobacco extremists and FDA keep claiming flavored products are target marketed to youth and they “appeal to youth”.
[h=1]Warning Labels[/h]
FDA is likely to propose require a warning stating "This product contains nicotine, which is addictive" for e-cigarette products; and may propose additional warnings, including “This product is not a safe alternative to cigarettes.”
Criteria for Establishing New Chapter IX Regulations
Section 906(d)(1) The Secretary may by regulation require restrictions on the sale and distribution of a tobacco product, including restrictions on the access to, and the advertising and promotion of, the tobacco product, if the Secretary determines that such regulation would be appropriate for the protection of the public health.
The finding as to whether such regulation would be appropriate for the protection of the public health shall be determined with respect to the risks and benefits to the population as a whole, including users and nonusers of the tobacco product, and taking into account--
(A) the increased or decreased likelihood that existing users of tobacco products will stop using such products; and
(B) the increased or decreased likelihood that those who do not use tobacco products will start using such products.
Deeming regulation for e-cigarettes threatens, doesn’t protect, public health
E-cigarettes are far less hazardous than cigarettes, are used almost exclusively by adult smokers, have eliminated or reduced cigarette consumption and disease risks for several million consumers, pose no risks to nonusers, aren’t known to have caused nicotine addiction in any non tobacco user, and are used by very few youth or non tobacco users.
[h=1]Actions to prevent/delay/amend FDA "deeming" regulation[/h]
Previous testimony/comments to FDA since 2009, to IOM MRTP Cmte, to TPSAC on dissolvables, to FDA on MRTP, discussions with FDA officials.
FDA 12/17/12 hearing and 5,000 comments from vapers on Section 918 (GSK clause in FSPTCA), FDA report to Congress.
Expose and oppose "deeming" regulation in tobacco trade publications, news articles, op/eds, letters to editors, letters to Congress, comments to FDA.
Mobilize >100,000 comments from consumers opposing FDA “deeming” regulation.
Coalesce many e-cig companies and consumers. Avoid cannibalism in industry. Don’t throw mods and e-liquids under the bus as they are most cost effective alternatives and are the e-cig consumer advocacy base.
Coalesce with cigar, pipe tobacco, hookah, dissolvable companies and consumers, tobacco distributors and retailers (NATO, NACS).
Advocate state laws to ban e-cigarette sales to minors (so no need for FDA youth ban).
Urge Congress (especially Republicans, and especially House E&C Cmte Republicans) to not let FDA ban or impose unwarranted regulations on e-cigarette products.
Urge House E&C Cmte Chairs to hold hearing, request info from FDA.
Potential legislation to prevent/delay "deeming" regulation
- Bill to ban FDA from regulating e-cigarettes under Chapter IX (similar to cigar bill).
- Bill to require FDA to conduct comprehensive health/safety risk/benefit analysis for all different types of tobacco products before agency can impose "deeming" regulation, and require FDA to consider “the relative and comparable risks and benefits of different tobacco products,” as additional factor in Section 906(d)(1) when evaluating regs.
Potential litigation against FDA if agency gives final approval to "deeming" regulation.
[h=1]Other Legislation/Laws to Restrict E-cigarettes[/h]
2009-2012 state and local legislation to ban e-cigarettes to adults (including CA, UT, NY, MD, IL, WA, TN, several towns in MA). CA warnings mandatory. CA and OR AG retaliatory lawsuits against SE/NJOY, Flavoring sales ban in Providence, RI.
E-cigarette tax bills sponsored by US Senate Dems in 2011/2012 (probably 2013) to hike cigarette tax to $2, tax OTP & e-cigs at equivalent rate. Little chance of passage in 2013.
2010 MN only state to tax e-cigarettes (70%), 2012 HI tax bill defeated, 2012 Omaha bill amended to exempt e-cigs; future battles likely in Democrat and/or ad valorem tax states.
About 15 states now ban e-cigarette sales to youth; CTFK/ACS/AHA/ALA opposed sales bans to youth (while claiming products are marketed to youth) till 2011, still don’t support.
State/local legislation/laws banning e-cigarette use in workplaces (NJ - 2009, UT – 2012), 2010 Seattle/King County, 2011 Boston, 2012 Indianapolis, several dozen smaller municipalities. No known citations or warnings for violations. Few stand-alone e-cig usage bans expected in 2013, but many bills that falsely define “smoking” to include e-cig use, primarily in states/municipalities that haven’t enacted a workplace smoking ban.
[h=1]E-Cigarette and THR Opponents[/h]
Abstinence-only prohibitionists and drug companies, Tobacco Use vs Disease Risk,
CDC grants, some State/Local Health Depts, some local BOHs in MA, WA, KY, WV;
GSK, J&J, Pfizer and funded groups Pinney Assoc., CTFK, ACS, AHA, ALA, ATTUD; Legacy, UCSF, ANR, GASP; funding by Bloomberg & Gates; Liberal Democrats.
[h=1]E-Cigarette and THR Advocates[/h]
[h=2]CASAA, NVC, local vapers clubs, ECF, E-CigAdvanced, ACSH, AAPHP, Smokefree PA,[/h]Mike Siegel, Jeff Stier, Brad Rodu, Carl Phillips.
But the presentation was never given because SFATA Executive Director Chris Venis decided to extensively edit it (including eliminating the first half of the presentation) without my permission.
E-Cig Summit 2013
January 28, 2013
Las Vegas
Presentation by
Bill Godshall
Executive Director
Smokefree Pennsylvania
1926 Monongahela Avenue
Pittsburgh, PA 15218
412-351-5880
smokefree@compuserve.com
[h=3]History of FDA tobacco Regulation [/h]
David Kessler's 1996 Final Rule, 1998 defeat of Sen. McCain’s bill to enact Global tobacco Settlement, 2000 SCOTUS strikes down 1996 tobacco regs and FDA authority, 2001/02 & 2003 Waxman/Kennedy bills, Philip Morris' 2002/03 cooption bills, 2003/04 negotiated agreement by PM/CTFK/ACS/AHA/ALA/Kennedy/Waxman for FSPTCA legislation, House & Senate bills in 2004, 2005/06, 2007/08 and 2009 (changed new product date until 2007), Amendments (graphic warnings, clove cig ban, smokeless free distribution, dissolvables report), UST/SM opposed till 2007 free distribution and PM purchase, Reynolds/Lorillard/ACSH/AAPHP/Smokefree PA opposed till 2009 enactment.
[h=1]Obama Administration Actions Against E-cigarettes[/h]
2009 FDA import ban, SE/NJOY lawsuits, July 22, 2009 press conference, Judge Leon's January 2010 opinion, 2010 amicus brief supporting SE/NJOY by health advocates and e-cigarette consumers, FDA September 10, 2010 letter to 5 e-cig companies, Appeals Courts uphold Judge Leon's ruling, FDA concedes on April 25, 2011 and states intent to propose "deeming" regulation, subsequent derogatory FDA statements about e-cigarettes and risks.
US DOT 2011 announced then proposed e-cig usage ban (regulation) on airlines, CASAA, WLF, Smokefree PA comments stating regulation unlawful, no final regulation issued yet.
E-cigarette use ban at DHHS and US military facilities.
[h=1]FDA Deeming Regulation[/h]
Section 901(b) This chapter shall apply to all cigarettes, cigarette tobacco, roll-your-own tobacco and smokeless tobacco and to any other tobacco products that the Secretary by regulation deems to be subject to this chapter.
FDA first stated intent to issue "deeming" regulation in 2010 for cigars, April 25, 2011 notice for e-cigs, Summer 2011 notice of intent to propose "deeming" regulation in 10/2011, Spring 2012 notice of intent to propose "deeming" regulation in Summer 2012, recent FDA notice of intent to propose "deeming" regulation by April 2013.
E-cigarettes can now be marketed without violating FDCA as long as manufacturer or importer doesn't make "therapeutic claim" about product. Since "smoking" is not a disease or disorder, a "smoking cessation" claim by a manufacturer shouldn't violate the FDCA, but FDA claims otherwise. Courts won’t consider issue till company challenges FDA.
FDA "deeming" regulation would apply to cigars, pipe tobacco, shisha/hookah tobacco, e-cigarettes, dissolvables, skin creams and other currently unregulated tobacco products. Large/premium cigar exemption legislation (House bill with 230 sponsors).
Proposed "deeming" regulation would include definitions for all categories of newly regulated products, including e-cigarettes; FDA may call ENDS, e-cigarettes or other.
FSPTCA Chapter IX provisions that would most negatively impact e-cigs
Sections 905(j) and 910 would ban all e-cigarette products not on the market prior to February 15, 2007. To avoid litigating/losing another lawsuit, FDA may change 2007 grandfather date to 2103 for newly regulated products, but that would/could forever ban all new e-cigs on market, as FDA hasn’t approved any "substantially equivalent" applications for cigarettes or smokeless. FDA policy basically opposes ALL new tobacco products.
Section 911 would prohibit e-cigarette manufacturers/importers from truthfully claiming products are less hazardous than cigarettes, or that products don't contain or emit a substance, as only "Modified Risk Tobacco Products" (MRTP) can make those claims. If FDA doesn’t amend Section 911(b)(2)(C) to exempt e-cigarettes (in addition to smokeless tobacco), manufacturers couldn’t even claim e-cigarettes are "smoke free" or emit "no smoke". To make MRPT claim, manufacturers must spend tens of millions of dollars on unnecessary and speculative research to submit applications, and hope for approval. PM, SM and Reynolds might submit MRTP applications for smokeless tobacco products.
Section 915 would require e-cig manufacturers to test and report constituents, ingredients, additives for each brand and subbrand, may require testing of every manufactured batch.
Section 919 would NOT require e-cigarette manufacturers to pay regulatory fees to FDA, but FDA may amend to require fees.
Section 900 defines "Tobacco Product Manufacturer" as "any person, including any repacker or relabeler, who manufactures, fabricates, assembles, processes, or labels a tobacco product" and anyone who "imports a finished tobacco product for sale or distribution in the US." Thus, "deeming" regulation likely to cause acquisitions, consolidations, disappearances of hundreds of e-cigarette companies.
Title 1, Section 101 "Tobacco Product" defined as "any product made or derived from tobacco that is intended for human consumption, including any component, part, or accessory of a tobacco product." Thus, FDA "deeming" regulation would/could result in regulations on any component, part or accessory of e-cigarette products, potentially including hardware, cartridges, batteries, rechargers, etc.
[h=1]
Potential Additional FDA Regulations for E-cigarettes[/h]
[h=1]Ban Sales to Minors, and Most Marketing to Adults[/h]
If FDA amends Section 102 Final Rule (i.e.1996 Rule) to include e-cigarettes
- e-cigarette sales to minors under 18 would be banned, FDA would conduct compliance inspections of retailers (100,000 already conducted), warning letters and subsequent fines,
- unless exempted by FDA in Section 906(d)(4)(A)(i), could ban most/all non-face-to-face-sales of e-cigarettes, perhaps ads, promotions and sponsorships on Internet. In Sept 2011, FDA issued advance notice of proposed rulemaking (ANPRM) requesting comments, data, research, or other information related to non-face-to-face sale and distribution of tobacco products; advertising, promotion, and marketing of such products; and advertising of tobacco products via the Internet, e-mail, direct mail, telephone, smart phones, other communication technologies that can be directed to specific recipients.
and
- ban self service displays of e-cigs (i.e. behind the counter) if minors are allowed in store,
- ban sale/distribution of brand-identified promotional item or service (shirts, hats, etc.),
- ban brand name sponsorship of athletic, musical, artistic, other social or cultural events,
- could ban giving free samples of e-cigs to adults, ban/restrict outdoor advertisements,
- FDA may have legal authority to also ban television and radio ads for e-cigarettes,
- could limit advertising exposed to youth to black-and-white, text-only format, but a federal judge and appeals court have already ruled this provision unconstitutional.
[h=1]Maximum Nicotine Level/Amount[/h]
FDA may propose new regulation to limit the amount and/or concentration of nicotine in e-cigarette products. If FDA proposes same or similar limits as were proposed in EU Tobacco Products Directive (i.e. no more than 4mg/ml nicotine, no more than 2mg of nicotine in any e-cigarette product sold to consumers), all e-cigarettes now marketed would be banned except no-nicotine e-cigarettes, and all e-liquid products. No known nicotine deaths, no known lethal dose, false claims, Green Tobacco Sickness. (24mg/ml = 2.4%)
[h=1]Flavoring Restrictions[/h]
FDA may propose new regulation to ban some/most/all flavorings in e-cigarette products. FSPTCA now just bans certain flavorings in cigarettes (that comprised 1% of flavored cigarettes in 2009, including clove). There is NO evidence flavored tobacco products (including e-cigarettes) are marketed to youth, but anti tobacco extremists and FDA keep claiming flavored products are target marketed to youth and they “appeal to youth”.
[h=1]Warning Labels[/h]
FDA is likely to propose require a warning stating "This product contains nicotine, which is addictive" for e-cigarette products; and may propose additional warnings, including “This product is not a safe alternative to cigarettes.”
Criteria for Establishing New Chapter IX Regulations
Section 906(d)(1) The Secretary may by regulation require restrictions on the sale and distribution of a tobacco product, including restrictions on the access to, and the advertising and promotion of, the tobacco product, if the Secretary determines that such regulation would be appropriate for the protection of the public health.
The finding as to whether such regulation would be appropriate for the protection of the public health shall be determined with respect to the risks and benefits to the population as a whole, including users and nonusers of the tobacco product, and taking into account--
(A) the increased or decreased likelihood that existing users of tobacco products will stop using such products; and
(B) the increased or decreased likelihood that those who do not use tobacco products will start using such products.
Deeming regulation for e-cigarettes threatens, doesn’t protect, public health
E-cigarettes are far less hazardous than cigarettes, are used almost exclusively by adult smokers, have eliminated or reduced cigarette consumption and disease risks for several million consumers, pose no risks to nonusers, aren’t known to have caused nicotine addiction in any non tobacco user, and are used by very few youth or non tobacco users.
[h=1]Actions to prevent/delay/amend FDA "deeming" regulation[/h]
Previous testimony/comments to FDA since 2009, to IOM MRTP Cmte, to TPSAC on dissolvables, to FDA on MRTP, discussions with FDA officials.
FDA 12/17/12 hearing and 5,000 comments from vapers on Section 918 (GSK clause in FSPTCA), FDA report to Congress.
Expose and oppose "deeming" regulation in tobacco trade publications, news articles, op/eds, letters to editors, letters to Congress, comments to FDA.
Mobilize >100,000 comments from consumers opposing FDA “deeming” regulation.
Coalesce many e-cig companies and consumers. Avoid cannibalism in industry. Don’t throw mods and e-liquids under the bus as they are most cost effective alternatives and are the e-cig consumer advocacy base.
Coalesce with cigar, pipe tobacco, hookah, dissolvable companies and consumers, tobacco distributors and retailers (NATO, NACS).
Advocate state laws to ban e-cigarette sales to minors (so no need for FDA youth ban).
Urge Congress (especially Republicans, and especially House E&C Cmte Republicans) to not let FDA ban or impose unwarranted regulations on e-cigarette products.
Urge House E&C Cmte Chairs to hold hearing, request info from FDA.
Potential legislation to prevent/delay "deeming" regulation
- Bill to ban FDA from regulating e-cigarettes under Chapter IX (similar to cigar bill).
- Bill to require FDA to conduct comprehensive health/safety risk/benefit analysis for all different types of tobacco products before agency can impose "deeming" regulation, and require FDA to consider “the relative and comparable risks and benefits of different tobacco products,” as additional factor in Section 906(d)(1) when evaluating regs.
Potential litigation against FDA if agency gives final approval to "deeming" regulation.
[h=1]Other Legislation/Laws to Restrict E-cigarettes[/h]
2009-2012 state and local legislation to ban e-cigarettes to adults (including CA, UT, NY, MD, IL, WA, TN, several towns in MA). CA warnings mandatory. CA and OR AG retaliatory lawsuits against SE/NJOY, Flavoring sales ban in Providence, RI.
E-cigarette tax bills sponsored by US Senate Dems in 2011/2012 (probably 2013) to hike cigarette tax to $2, tax OTP & e-cigs at equivalent rate. Little chance of passage in 2013.
2010 MN only state to tax e-cigarettes (70%), 2012 HI tax bill defeated, 2012 Omaha bill amended to exempt e-cigs; future battles likely in Democrat and/or ad valorem tax states.
About 15 states now ban e-cigarette sales to youth; CTFK/ACS/AHA/ALA opposed sales bans to youth (while claiming products are marketed to youth) till 2011, still don’t support.
State/local legislation/laws banning e-cigarette use in workplaces (NJ - 2009, UT – 2012), 2010 Seattle/King County, 2011 Boston, 2012 Indianapolis, several dozen smaller municipalities. No known citations or warnings for violations. Few stand-alone e-cig usage bans expected in 2013, but many bills that falsely define “smoking” to include e-cig use, primarily in states/municipalities that haven’t enacted a workplace smoking ban.
[h=1]E-Cigarette and THR Opponents[/h]
Abstinence-only prohibitionists and drug companies, Tobacco Use vs Disease Risk,
CDC grants, some State/Local Health Depts, some local BOHs in MA, WA, KY, WV;
GSK, J&J, Pfizer and funded groups Pinney Assoc., CTFK, ACS, AHA, ALA, ATTUD; Legacy, UCSF, ANR, GASP; funding by Bloomberg & Gates; Liberal Democrats.
[h=1]E-Cigarette and THR Advocates[/h]
[h=2]CASAA, NVC, local vapers clubs, ECF, E-CigAdvanced, ACSH, AAPHP, Smokefree PA,[/h]Mike Siegel, Jeff Stier, Brad Rodu, Carl Phillips.
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