Deeming Regulations have been released!!!!

Lessifer

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Last night I poured over the PRIA and the RIA. I saw FRIA referenced, is it another report?

I really bothers me that cigars, pipe tobacco and RYO were lumped in with e-cigs. It makes to sense to combine data of combustable and Non-combustable products. It also bothered me that since there is much more empirical evidence on cigars it is often used to respond to comments with e-cig info buried under not having sufficient evidence.
FRIA is the Final Regulatory Impact Analysis published this month, found here http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Reports/EconomicAnalyses/UCM500254.pdf

Everything they have for "ENDS" is an estimate due to insufficient evidence, and they state that repeatedly. How do you have an analysis of impact based on assumptions that you admit are likely inaccurate? They know that the only somewhat accurate measures of the economics of vapor products that they have are based on those sold in c-stores. They know that they have no real clue about the vapor store market. They also know that the only market that will be left are the c-stores, so they don't care.
 

The Ocelot

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Do you think we can get PETA excited about the fact we use Vegetable Glycerin, so no animals are harmed in the manufacture of juice (there are no poultry or beef flavors out there, right?)?

Roast Beef - eLiquid Flavor
Roast Chicken - eLiquid Flavor

If you really want a treat, try browsing the products here:
Savory - Customizable Blends - e-Juices

I used to have a whole bbq dinner menu in a blog, but the links are all broken now and I don't feel like fixing them.

ETA: When I first wrote the blog there was song I was listening to that went so well with it, but I couldn't find it online! Well guess what? Most of the links are broken, but just picture it in your mind what was there while you listen to a great song.

Everybody Vapes Barbecue!

 
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The Ocelot

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FRIA is the Final Regulatory Impact Analysis published this month, found here http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Reports/EconomicAnalyses/UCM500254.pdf

Everything they have for "ENDS" is an estimate due to insufficient evidence, and they state that repeatedly. How do you have an analysis of impact based on assumptions that you admit are likely inaccurate? They know that the only somewhat accurate measures of the economics of vapor products that they have are based on those sold in c-stores. They know that they have no real clue about the vapor store market. They also know that the only market that will be left are the c-stores, so they don't care.

Ah, that's the same as the what I was calling the RIA. There was a Proposed Regulatory Impact Analysis published in April 2014, then the final in May 2016.

ETA: I agree that the FDA is clueless and doesn't care. As long as there is something on the market that is cigarette-shaped and emits vapor, their job is done.

"Even if considerable product consolidation were to occur, close substitutes would exist for discontinued products, which would limit the size of any ongoing impact on consumers who switch to a substitute product.”
 
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ZeroedIn

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Of course it is, he covered just about everything.(except kitchen sink at least not yet) I was referring to what the definition of a cigarette was according to the Laws on the books. You are speaking to the labeling of the ejuice.
:)

Actually, the kitchen sink may also be in scope, because I use it to wash out my DIY bottles. :rolleyes:
 
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ZeroedIn

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And what Some have asked is during Reconciliation of the House and Senate AG Appropriation Bill, could the GF Date (and just the GF Date) be removed from the House Bill leaving the Other provisions?

Apologies if someone answered already, I'm still trying to catch up after a business trip, but yes, this CAN happen.
 
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Katya

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But if teens are big concern, how could they test them?

They'll need parental consent.
proxy.php
Just leave the beagles (rats, mice, rabbits, goats, and chimps) alone.
 

Eskie

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ZeroedIn

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I realize that injecting political views into any discussion is bound to hurt feelings, but I also think we are at a point where it be hooves us all to put on our big-girl panties and focus on the peril at hand- and that peril is, unfortunately, politically driven.

I've followed all 364 pages of this thread. It is the thread, in fact, that brought me back to this site after a long hiatus.

It's no surprise that there are posters here from both sides of the aisle (and even some, like me, who think both sides are filled with traitors and claim neither).

There are, of course, the inevitable 'some who shall remain unnamed' who just want to throw unguided blows with no regard who they land on.

Then there are some who seem to be tired of the fact that it is their normal 'side' who are to blame for much of this, and appear to be resentful for the frequent reminder.

To the first, I would say that there are no reasons to throw blows here, at all. We are ALL on the same side here- the right side. Even if someone is made aware of the political leanings of their chosen party, and still choose to support them, that is ok. We don't have to be one-issue voters. As big a deal as this seems right now, there are other important issues on which to weigh your vote, and you shouldn't vilify someone who may vote a certain way even if it is in support of candidates who don't support vaping.

To the second 'group', I would just offer that this thread, more than maybe any other single point-of-contact on the internet, has been an intellectual discourse on what these new regulations mean and what we can do about them. The simple fact, that has made itself readily apparent muiltiple times, is that the Democrat party's votes have proven them to be against vaping.

This is all, of course, not to say that one can depend on R=pro and D=anti on the topic of vaping, but it is proving to be a very reliable rule of thumb. It would be a shame to ignore this fact, in a discussion about resistance to these regulations, just because it hurts some feelings.

I'd actually go one step further and say that we need a board-sticky pointing out this trend to make as many people aware of it as possible.

While the individual does not need to be a single-issue voter and/or their issue does not necessarily need to be vaping, but this community MUST be, and that issue MUST be vaping.

Flash-forward to January 2017, even if Cole-Bishop were to pass into law in 2016, if a Democrat president, and Democrat lead-house and senate are elected, it WILL be undone. That is fact.

I'm not a Republican. I'm firmly independent, study the issues, and normally vote libertarian where there is an option, but this cycle is too important for me to vote for candidates that have no chance of winning. With the potential for up to 4 SCOTUS seats, serious gun control issues on the gov't radar, and, now, this threat against my (very) delicate mastery over my tobacco addiction at risk, I will be voting R, straight down the ticket.

Regardless how an individual weighs the issues and chooses to cast their vote, the community, and, to whit, this board MUST be single-issue. Failure to recognize the obvious implications of R v. D on this specific issue would just be an illustration of the lack of maturity and inability to do what is necessary to win this war that I ranted about a couple hundred pages ago.

Again, sorry for any hurt feelings, but this is coming from a veteran of a vilified industry, and, I assure you, what I am saying is not driven by emotion. It is driven ENTIRELY by combat experience and battle scars.

Vote your honest conscious and apologize to no one.

And stockpile.


I thank you, sir, for this intelligent comment; and more importantly, your service.
 
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Sugar_and_Spice

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http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Reports/EconomicAnalyses/UCM500254.pdf

According to the final Impact Analysis they even want to 'pick' our flavors.

"larger number of uniquely described flavors, recently estimated to be 7,764 (Zhu at al., 2014). The number of distinct brand-flavor variants of e-liquid could be reduced without substantially altering the variety available to consumers. For example, blueberry e-liquid might continue to be available, but the number of brands offering blueberry or the number of subtle variations of blueberry could be reduced. The majority of the compliance costs of this final rule are fixed, but a portion of the costs are variable. Most of the variable costs would be would be passed on to consumers in the form of higher prices. Any increase in prices faced by consumers as a result of this final rule could dissuade some people from using newly deemed tobacco products."

IN other words, if they pick Capella's blueberry over tpa's blueberry we have no choice if we want blueberry ejuice. So glad I DIY.

It goes on to say a whole lot more. And I agree with The Ocelot that this is how they will answer the oversight committee. This is making me sick to my stomach.
'sigh'
 

Sugar_and_Spice

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I'm am stunned and humbled.

So now Roast Beef is a tobacco product as well. Might as well deem the whole cow a tobacco product.
They had a 'Worcestershire' flavor also at tpa.....altho it was discontinued for lack of sales.. lol wonder why?
:)
 
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The Ocelot

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Actually, the kitchen sink may also be in scope, because I use it to wash out my DIY bottles. :rolleyes:

I blame you.

Many of these manufacturers, however, are believed to be smaller, informal participants in this market; in describing the current landscape in the ENDS industry, an industry survey respondent wrote, “Too many companies are making e-liquid in their kitchens/bathrooms,” (Herzog et al., 2014a).

This quote (actually part of a quote) is an outlandish example of cherry picking. Not only is it inflammatory and irrelevant, it's presented as if it was part of an accredited study. &)((%&()(^!! It's from an Equity Survey compiled by Bonnie Herzog for Wells Fargo Securities. She's an industry analyst who looks at market trends for investors!

That specific "quote" was taken from a survey on the increasing market trend of vapor/tank (open) systems. You have to look hard to find the comment among the others...that actually have relevant information.
http://www.vaporworldexpo.com/PDFs/Tobacco_Talk_Vapors_Tanks_ March 2014.pdf

It seems criminal the FDA could pull something that misleading out of the blue. Especially when they attribute it to Ms. Herzog, who is against the regulations. She just looks at the market, btw, she advises big tobacco too. The most recent quote I found for her was in the same article in which the Reynolds reps were praising the new regs:

“Our main concern is that these final deeming regulations could dramatically slow industry growth by disincentivizing consumer conversion from combustible cigarettes,” said Bonnie Herzog, an analyst with Wells Fargo Securities. “This would ultimately have a net negative impact on public health, which is clearly in direct opposition to the FDA’s goal.”
 
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The Ocelot

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It goes on to say a whole lot more. And I agree with The Ocelot that this is how they will answer the oversight committee. This is making me sick to my stomach.
'sigh'

Drop a line to the Homeland Security committee.
 

coldgin96

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Here are my recent observations of ECF in general and especially this thread most recently. I see lots of replies that have sharp edges on them. Someone makes a statement and then someone replies with a less-than-flattering comment...as if their primary goal is to prove the commenter wrong instead of exploring the topic that was raised. I generally don't get defensive. It's not my personality and I'm too old to fight with people. But over the last few months I have seen more and more of this kind of practice on ECF and especially on this thread. It's disturbing. And like a hockey fight, it isn't the perpetrator who is exposed, it is the one who retaliates defending themselves. Honestly, this happens way too much on ECF and at rates I haven't seen in my nearly four years on this forum. I'm at a point where I'm thinking my time is better spent doing other things. If I got kicked off of ECF for getting in someone's face I have to say I really wouldn't lose any sleep over it. It would seem to me when someone makes a statement there is nothing wrong with disagreeing with them but it IS wrong to be a snot about it. Yes, it is possible to disagree and be respectful at the same time. ECF needs more of this.
Hey, I remember disagreeing with Bronze on another issue and pointing out why. Some agreed with me but it was left at that. Simple. I don't remember but some may have even agreed with Bronze. Simple. Topic was brought up, Bronze disagreed, I agreed (disagreed with Bronze), a minor discussion took place and that was the end of that. Simple.
 
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