Why should that be a Problem?
If it is Objectively True and can be shown as a Fact, why should a Regulator Agency want to Restrict it?
I see stuff like this Every Time I go to the Store.
Deeming Regulations have been released!!!!
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Why should that be a Problem?
If it is Objectively True and can be shown as a Fact, why should a Regulator Agency want to Restrict it?
I see stuff like this Every Time I go to the Store.
That wasn't the apple and oranges content, but you're probably right on the other - as to how MRTP status will be considered by the FDA. However.....:
“Modified risk tobacco product” means any tobacco product that is sold or distributed for use to reduce harm or the risk of tobacco-related disease associated with commercially marketed tobacco products. Section 911(b)(1) of the FD&C Act. Sold or distributed for use to reduce harm or the risk of tobacco-related disease associated with commercially marketed tobacco products means a tobacco product ...
1. ...that represents in its label, labeling, or advertising, either implicitly or explicitly, that: i. the tobacco product presents a lower risk of tobacco-related disease or is less harmful than one or more other commercially marketed tobacco products;
... since B.O. isn't a tobacco-related disease, any mention of diacetyl-free shouldn't apply.
http://www.fda.gov/downloads/TobaccoProducts/GuidanceComplianceRegulatoryInformation/UCM297751.pdf pg 6
And they are allowed to say 0g tans fat even if it has trans fat. They only have to have less than 0.5g trans-fat per serving to make the claim. IMO, the FDA is allowing misleading labeling here. How many people will understand what it really means? The claim also may imply the product is healthy, and often it is not (most grocery store food products have the likes of GMO soy or canola oil, both of which are far from safe).Why should that be a Problem?
If it is Objectively True and can be shown as a Fact, why should a Regulator Agency want to Restrict it?
I see stuff like this Every Time I go to the Store.
Labels of "natural" are even worse. Ingredients labeled as "natural" are anything but, without exception from what I've seen.
Sorry, I get as stirred up over the disgraceful allowances given the food industry by the FDA as I do what they are trying to do to vaping. Neither is in the interest of public health.
Not by a long shot sweetie
Hey, they don't want the Tobacco companies to look bad, be compared too, or just plain be shot down for the deadly product they make.
The tobacco products have to state "hazardous to your health" ... you don't think the guys that write the checks are going to let you point out how much healthier vaping is, ... do you ??
I Believe the thing about <0.5g per serving might be why there is an Asterisk after the words "Per Serving".
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Private citizens can't "violate" the 1st Amendment. Only government can.
Apples: Shouting "fire" in a crowded theater when there is no fire and there's an imminent threat of panic. Oranges: Shouting "dead cops now" when there is no imminent threat of violence. Speech becomes a 1st Amendment issue when government restricts it and/or when it interferes with another constitutionally protected right, e.g., freedom of the press. Thus, it has been held that when the judicial system (a branch of government) imposes common law defamation principles in such a way as to unduly restrict freedom of the press, it is a 1st Amendment violation on the part of the judiciary.
This back-and-forth has become unproductive. We share the opinion that the FDA's restrictions on vaping product advertising are unreasonable and violate of the 1st Amendment. We don't need to quibble about fire in theaters or "dead cops now." People are here to talk about vaping regulations.
You sure about that? This is the agency that is trying to remove the word "mild" from an established brand name, because it implies their product may have lower health risks. Or if your objection is specifically to diacetyl free, how about smoke free?
per their website
*Calculations:
Cigarettes (20-pack) = 24mg nicotine per pack
Nicosurge = 240 puffs x 0.2mg/puff = 48mg nicotine per canister.
So if you vape 10 ml@ 6mg a day = 60mg per day.
Or 10ml a day @3mg = 30mg
Very expensive @ $25 a canister.
Here's a "fun" thought. E-liquid is a newly deemed tobacco product. There are studies verifying the presence of diacetyl and other diketones in e-liquid. There is a suggested link between diacetyl and B.O., so, is B.O. now a tobacco related disease, even though there is no evidence of anyone developing B.O. related to tobacco use?
I think the Entire concept of how Diketones should or should be advertised/Labeled/etc is Funny.
Does Anyone really think that an e-Liquid that contains detectable levels ( >5ppm ) of Diketones will receive PMTA approval?
Does Anyone really think that an e-Liquid that contains detectable levels ( >5ppm ) of Diketones will receive PMTA approval?
They have to issue PMTA's on some e-Liquids Les. Can't Tax something that Can't be Sold.
And I don't think the Feds, or the States, would be All that Thrilled to watch such a Tax Vehicle skid off the side of the Road.
Well, when I say e-liquid, I'm referring to bottled liquid meant to be used in open system vapor devices.
Oh... Yeah, I'll go with that.
Take #2:
I think the Entire concept of how Diketones should or should be advertised/Labeled/etc is Funny.
Does Anyone really think that an e-Liquid, packaged in a Closed System - Non-Refillable - Chip Enabled Cartridge with a Proprietary Non-510 Connection, that contains detectable levels ( >5ppm ) of Diketones will receive PMTA approval?
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