I will share my comment I made on the FDA web site. In order to post the comment properly please click on the link from CASAA, scroll down to " Required and Suggested Talking Points", read the requirements, click on the "submit your comment HERE" and comment as an individual consumer. Here is the comment I posted to the FDA web site after following CASAA's guidelines:
I am commenting on Electronic Cigarettes and the Public Health; Public Workshop; 79 FR 55815, September 17, 2014, Docket No. FDA-2014-N-0001 - I am a vapor (or an e cigarette user, I used to smoke cigarettes and premium cigars but I switched to e cigarettes, first ego twist e cigarettes then went onto the RDA). I am a member of CASAA. I am commenting to call attention to some of the enormous body of knowledge and expertise that exists in the consumer community.
The United States Code (Act of Congress), in this respect, the FDA regulates tobacco. In the Act it reads nicotine derived from tobacco, period. The entire argument the FDA is proposing to the e cigarette is that under its authority to regulate the e cigarette market it is able to because it regulates tobacco. E liquid (outside of tobacco extracts) is not tobacco related in any shape or form. E liquid does contain nicotine (for the most part). But the Act does not state the FDA has authority to regulate nicotine, it states the FDA has authority to regulate nicotine derived from tobacco, period. And as I stated in the other (legal) argument, there are other flowering plant sources, which contain nicotine. So the reasoning leads one to ask: does the FDA have the authority to regulate nicotine (also) from the other sources of flowering plants? And (again) the simple answer: no. To be plain about this (legal) argument, the word tobacco governs the entire United States Code Title 21Food And Drugs CHAPTER 9FEDERAL FOOD, DRUG, AND COSMETIC ACT SUBCHAPTER IX et seq, the FDA derives its power to regulate because tobacco is considered harmful to one's health; the entire Act derives its jurisdiction that it is tobacco not nicotine itself that harms or is fatal to one's health - nicotine can be a source of pleasure as a sedative or a stimulant but so is caffeine and melatonin which are over the counter "drugs"...so if the word tobacco is taken out of the Act itself the Act itself would be moot. The Act rests on tobacco not nicotine even though the Act reads that nicotine derived from tobacco etc etc etc...I just wanted to make my point clearer in case any wordage was misconstrued from the other comment I sent you. FDA or the USC/Act of Congress regulates tobacco NOT nicotine. This is the point which should be presented to the FDA on June 1.
Also I would like to add: vaping community is not just about e liquid. A person enters the vaping community to switch from a harmful smoking device (a cigarette which contains thousands of chemicals) to a less harmful device, the e cigarette; as that person progresses further into the vaping community he or she will begin to understand the mechanics of the devices, be it a RDA, RBA, RTA, regulated or unregulated box, tube mod, will understand ohm's law, chemistry of e liquids and its vapor (I will get to this in a moment), cotton or wicking properties, battery safety, wiring a RDA deck, several types of coil or wire builds, how metals and glass make up 99% of all the devices (I could go on but I will run out of characters), but I believe the point is made (and hopefully, wisely taken), the vaping community derives great pleasure not only from the e liquid vapor but from the very devices which produce the vapor. As for the e liquid itself, all it is is a liquid being heated up and vaporized. What is vaporized? VG, PG, nicotine and flavorings as opposed to:
Acetanisole
Acetic acid
Acetoin
Acetophenone
6-Acetoxydihydrotheaspirane
2-Acetyl-3-Ethylpyrazine
2-Acetyl-5-Methylfuran
Acetylpyrazine
2-Acetylpyridine
3-Acetylpyridine
2-Acetylthiazole
Aconitic Acid
dl-Alanine
Allyl Hexanoate
Allyl Ionone
Ambergris Tincture
Ammonia
And this is part of the "A's" (of additives) of what is in the cigarette from American Tobacco Company, Brown and Williamson, Liggett Group, Inc., Philip Morris Inc., R.J. Reynolds Tobacco Company etc (see link for all additives, reading is required)
wikipedia: cigarette, click on "additives"
SEC. 907. TOBACCO PRODUCT STANDARDS ``(a) In General ``(3) Limitation on power granted to the food and drug administration.--Because of the importance of a decision of the Secretary to issue a regulation ``(A) banning all cigarettes, all smokeless tobacco products, all little cigars, all cigars other than little cigars, all pipe tobacco, or all roll-your-own tobacco products; or (B) requiring the reduction of nicotine yields of a tobacco product to zero, the Secretary is prohibited from taking such actions under this Act.
According to the Act, the FDA cannot under the Law ban e cigarette devices and/or e liquid if the FDA contends that an e cigarette is tobacco related. I ask you to apply reason, truth & the Law in all final & binding decisions. "The Congress finds the following...The purposes of this division are (7) to continue to permit the sale of tobacco products to adults under FAMILY SMOKING PREVENTION AND TOBACCO CONTROL AND FEDERAL RETIREMENT REFORM"
THANKS
_____________________________________
Please take the time to submit your personal/individual consumer experience to the FDA. Thank you for permitting me to share this most valuable exchange.
I am commenting on Electronic Cigarettes and the Public Health; Public Workshop; 79 FR 55815, September 17, 2014, Docket No. FDA-2014-N-0001 - I am a vapor (or an e cigarette user, I used to smoke cigarettes and premium cigars but I switched to e cigarettes, first ego twist e cigarettes then went onto the RDA). I am a member of CASAA. I am commenting to call attention to some of the enormous body of knowledge and expertise that exists in the consumer community.
The United States Code (Act of Congress), in this respect, the FDA regulates tobacco. In the Act it reads nicotine derived from tobacco, period. The entire argument the FDA is proposing to the e cigarette is that under its authority to regulate the e cigarette market it is able to because it regulates tobacco. E liquid (outside of tobacco extracts) is not tobacco related in any shape or form. E liquid does contain nicotine (for the most part). But the Act does not state the FDA has authority to regulate nicotine, it states the FDA has authority to regulate nicotine derived from tobacco, period. And as I stated in the other (legal) argument, there are other flowering plant sources, which contain nicotine. So the reasoning leads one to ask: does the FDA have the authority to regulate nicotine (also) from the other sources of flowering plants? And (again) the simple answer: no. To be plain about this (legal) argument, the word tobacco governs the entire United States Code Title 21Food And Drugs CHAPTER 9FEDERAL FOOD, DRUG, AND COSMETIC ACT SUBCHAPTER IX et seq, the FDA derives its power to regulate because tobacco is considered harmful to one's health; the entire Act derives its jurisdiction that it is tobacco not nicotine itself that harms or is fatal to one's health - nicotine can be a source of pleasure as a sedative or a stimulant but so is caffeine and melatonin which are over the counter "drugs"...so if the word tobacco is taken out of the Act itself the Act itself would be moot. The Act rests on tobacco not nicotine even though the Act reads that nicotine derived from tobacco etc etc etc...I just wanted to make my point clearer in case any wordage was misconstrued from the other comment I sent you. FDA or the USC/Act of Congress regulates tobacco NOT nicotine. This is the point which should be presented to the FDA on June 1.
Also I would like to add: vaping community is not just about e liquid. A person enters the vaping community to switch from a harmful smoking device (a cigarette which contains thousands of chemicals) to a less harmful device, the e cigarette; as that person progresses further into the vaping community he or she will begin to understand the mechanics of the devices, be it a RDA, RBA, RTA, regulated or unregulated box, tube mod, will understand ohm's law, chemistry of e liquids and its vapor (I will get to this in a moment), cotton or wicking properties, battery safety, wiring a RDA deck, several types of coil or wire builds, how metals and glass make up 99% of all the devices (I could go on but I will run out of characters), but I believe the point is made (and hopefully, wisely taken), the vaping community derives great pleasure not only from the e liquid vapor but from the very devices which produce the vapor. As for the e liquid itself, all it is is a liquid being heated up and vaporized. What is vaporized? VG, PG, nicotine and flavorings as opposed to:
Acetanisole
Acetic acid
Acetoin
Acetophenone
6-Acetoxydihydrotheaspirane
2-Acetyl-3-Ethylpyrazine
2-Acetyl-5-Methylfuran
Acetylpyrazine
2-Acetylpyridine
3-Acetylpyridine
2-Acetylthiazole
Aconitic Acid
dl-Alanine
Allyl Hexanoate
Allyl Ionone
Ambergris Tincture
Ammonia
And this is part of the "A's" (of additives) of what is in the cigarette from American Tobacco Company, Brown and Williamson, Liggett Group, Inc., Philip Morris Inc., R.J. Reynolds Tobacco Company etc (see link for all additives, reading is required)
wikipedia: cigarette, click on "additives"
SEC. 907. TOBACCO PRODUCT STANDARDS ``(a) In General ``(3) Limitation on power granted to the food and drug administration.--Because of the importance of a decision of the Secretary to issue a regulation ``(A) banning all cigarettes, all smokeless tobacco products, all little cigars, all cigars other than little cigars, all pipe tobacco, or all roll-your-own tobacco products; or (B) requiring the reduction of nicotine yields of a tobacco product to zero, the Secretary is prohibited from taking such actions under this Act.
According to the Act, the FDA cannot under the Law ban e cigarette devices and/or e liquid if the FDA contends that an e cigarette is tobacco related. I ask you to apply reason, truth & the Law in all final & binding decisions. "The Congress finds the following...The purposes of this division are (7) to continue to permit the sale of tobacco products to adults under FAMILY SMOKING PREVENTION AND TOBACCO CONTROL AND FEDERAL RETIREMENT REFORM"
THANKS
_____________________________________
Please take the time to submit your personal/individual consumer experience to the FDA. Thank you for permitting me to share this most valuable exchange.
