Vocalek: Here is my official comment as posted on the FDA page on dissolvables:
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Many of the responses to this topic will come from those with convictions about
tobacco usage -- those who either want to prohibit it entirely or restrict alternative nicotine delivery sources. Their objections are a matter of principle.
I bring a different perspective. I have been a daily user of Star Scientific's Stonewall dissolvable hard snuff since it came on the market in 2004. In 2007, I turned to Stonewall and Swedish snus to kick a 50-year cigarette addiction. I had smoked 30 cigarettes a day until July 17, 2007. I have not had one since that date.
In January 2008, I purchased my first electronic smoking device and have since that date used e-pipes, e-cigars and e-cigarettes to satisfy the habit part of a smoker's practice.
At age 68, my health, by every medical measure, has improved substantially since quitting smoking. Every six months, I undergo blood tests, plus physical examinations. Smoking had taken me to the brink of stroke, and surgery unclogged a 95% closed carotid artery. That became my impetus to quit smoking.
But I was and remain a nicotine addict. Truth is, I enjoyed smoking. I relished the alertness and relaxation that nicotine -- much like caffeine -- provides me. At the time I stopped cigarettes, I had no desire to quit nicotine, only to stop the harmful practice of inhaling combusted tobacco smoke into my lungs. Nicotine, after all, has known benefits. I have no reason to stop using it. I never intend to.
Many times in my life, I had tried to quit cigarettes. I have used, as directed, every one of the FDA-approved NRT products, with their abysmal success/failure ratios. None helped for long. I tried stepping down. I used the Quest nicotine-free cigarettes. I underwent hypnosis. I had a chemical concoction injected into my head -- at a cost of $400 -- that failed to help defeat the cravings for nicotine. I even went through horrible side effects while using Chantix.
They all fail for one reason: They provide nicotine but not the entire spectrum of alkaloids found in tobacco. That is a critical difference for smokers. Providing just nicotine results in a success rate not much better than a placebo. If nicotine were all a smoker needed, the NRT products would enjoy great success. They do not. Exactly the opposite happens. Smokers fail -- and pledge to never go through such agony again.
Dissolvable tobacco products provide nicotine and more. My Stonewalls have 4mg of nicotine per piece, much like the pharmaceutical lozenge. But Stonewall is a natural product, made from tobacco specially cured to create the lowest nitrosamine levels of any tobacco product. Being 100% tobacco, they provide me the full spectrum of tobacco alkaloids. I am satisfied in a way no NRT product can match.
I get the same satisfaction from Swedish snus, for the same reason.
I recently taped a YouTube video comparing the new Camel Orbs, Strips and Sticks to the older, more established Star Scientific products. The Camel products are inferior by all measures, but the one thing that struck me most was how childproof all of these dissolvable products are. Stonewalls are blister-sealed and difficult to reach. The Camel Orbs dispense one at a time -- but the plastic dispensing pack fails to yield one on many attempts. All of the packaging, for all dissolvable products, will frustrate an adult. Clearly, attempts have been made to keep these pieces from children. Also clearly, children are not the intended users -- and sales of all tobacco products should be limited to adults. No further laws on sales are needed. Enforcement is the problem.
These pellets do NOT look like candy, either. My Stonewalls look like what they are: compressed tobacco that creates a hard snuff pellet.
If the overriding goal of the FDA is to improve the health of this country's citizens, as it should be, then widely available, inexpensive, non-prescription, and far healthier alternatives must be available when a decision to quit smoking is made. Dissolvable tobacco is one such alternative.
I would encourage the FDA to fast-track alternative sources of nicotine. Every smoker who stops inhaling tobacco smoke surely adds quality time to his or her life and decreases the costs of smoking to society. Former smokers can use dissolvable tobacco products without endangering others with second-hand smoke, fire hazards or environmental litter. Those who understand harm reduction and nicotine addiction would call this a win-win situation.
Dissolvables are the most personal of nicotine products. Place one in the mouth, between cheek and gum, and absorption of nicotine and the other alkaloids begins. No bystander knows it is in use. No nuisance is created. No waste needs disposal after use.
And I can only laugh at the idea that children will desire these. No, they will still turn to the most dangerous two tobacco products -- cigarettes and chew tobacco. Focus your attention on keeping those products out of young mouths. Let adults choose far safer alternatives like dissolvables, snus, and e-cigarettes.
