*EXACTLY* what metric is good enough for this organization to "approve" of someone's product, specifically e-Liquid?
#5 is and should be left intentionally vague specifically because its kind of early to answer this question. The correct answer will require digging into the technical details of the manufacturing and testing process, and that is a level of digging that needs to be saved for a little later. Unless someone steps up with an existing certification, we're going to have to build it from the ground up.
While many people here have been bashing the FDA, floating conspiracy theories, asking why the FDA didn't do Apple-to-Oranges comparisons that would be wholly unscientific, etc., I have seen virtually *no* talk at ALL about what they said the *technical* problem was:
Labeling disparity/impurity/inconsistant measures in the samples they tested. As I said in another thread, to paraphrase, if 5% of the Advil on the market was tainted there would be hell to pay and I don't believe *for one second* if the FDA was to do an "alright, well test again" and bought 3 of everything they could find in the US they wouldn't find more, and worse, disparity.
The problem I have with the FDA testing is not so much their findings, but rather the conclusions they manufactured in the face of the facts. Yes, they found inconsistent levels of TRNAs among the different products--but how much of the inconsistency was from the differences in manufacturers and process and how much was the inconsistency from the testing process and how much of the inconsistency was from the actual product? Really, the ONLY thing that can be concluded from these results is that further testing is needed. But I don't think that because "more testing is needed" equates to "they are bad as cigarettes" or "they got antifreeze in them!" or "ban them until we can figure out if they're safe"....um, did you actually LOOK at the results? One of the most concerning things found was TRNA levels varying from "trace" all the way up to double digit parts per billion.
...and then this was compared to NRTs that
were not actually tested but had FDA required limits higher than the levels found in most of the carts.
Although my favorite part of the FDA report is still the Diethylene Glycol bit. DEG vaporizes at 90 degrees...they tested the vapor at 60 degrees...they didn't find any DEG in the vapor. ...and the United States Food & Drug Administration was "
surprised" by the outcome of this test. The two most likely conclusions you can make based on the FDA report is that either they intentionally lied or they have one or more dim bulbs in their drawer. I'm thinking its a little of both.
That said, what are the High Water Marks we are setting here, considering that we are talking about a mixture who's active component is highly addictive and in the most pure form can kill on contact?
Addictive, but not habit forming without the presence of MAOIs, by the way.
But your point is valid. Pure nicotine is very dangerous so the e-liquid should not be dismissed easily. Aside from the potential of TRNAs, as consumers we want some assurance about the quality of these products....but then again, as consumers of ANY product we want some quality control standards.
Considering the similarities in content, I think we could do a search and replace on standards required for other products...change some "chocolates" to "propylene glycol solutions", some "coffees" to "natural flavors", and some "caffeines" to "nicotines" and I think we'd have it.
Does a company just have to say "We're cool! People love us?"
Do they have to show that they employ a competent chemist and employ some sort of normalized laboratory safety procedures? Or just a picture of (ugh) some dude in a lab coat?
Need they produce a BoM showing where they get their supplies from to show the sources reputable? Are they using even remotely sanitary prep measure, let alone clean room-type environments? Have they ever bought a freakin' set of ISO standard verified and approved weights and measures?
All of the above? None of the above? SOME of the above. Again, this is a bigger question than we have space to answer here.
Do you really want to have a number 5 here if it isn't going to be done right, is what I'm asking. Credibility is worth more than gold and Thalium sort of reinforced that point with me.
We ABSOLUTELY should have a number 5. EVERYONE here is in favor of additional testing and quality control. Do we start with really high standards or do we start with vagaries and build from there, raising the standard whenever possible? I think I'd vote for the latter, but I don't think we're ready to call for the question quite yet.
How do we know *any* US supplier is even close to a high standard of manufacturing enough to "support" and/or "endorse" them without a *real* metric and someone (preferably "someones") qualified to weigh in on this?
Is there an industrial chemist in the house? Someone that does industrial-grade FDA approved food prep/manufacturing? A *chef*? Anyone?
-K
More than one would be better. I think this is a project for a committee--which is why I think we need to make sure to include a workspace section on the web site for this kind of work.
On the other hand, there's always the easy way out: Any manufacturer that wants our endorsement can send us whatever they feel makes them worthy of our endorsement....and we vote on it.
