FDA Extremely well done (and not yet available) FDA comment

[Rossum]

Statistics? Just saying. Probably statistics.

Yes, "statistics" made up made up by people with an agenda.

E.g: Somebody dies of a heart attack at age 80. If there's any indication that person ever smoked, even if he quit decades ago, he's counted as one of the 480k that were "killed by smoking".

 

[Jman8]

Yes, "statistics" made up made up by people with an agenda.

E.g: Somebody dies of a heart attack at age 80. If there's any indication that person ever smoked, even if he quit decades ago, he's counted as one of the 480k that were "killed by smoking".

Exactly. The 480K figure is grossly over estimated and is based on this sort of rationale. The good news is when a vaper dies at some age, it won't count as a 'vaping death' because it is likely that person was a smoker, so will just be another statistic validating "smoking kills." The bad news is that all vapers (who once smoked, by this rationale are actually (still) smokers.

Go explore the statistics if you feel what I and/or Rossum are explaining sounds farfetched. From what I recall, it is counted as smoker if you had a cigarette anytime in last 10 years (which would currently constitute vast majority of vapers). But if person dies at 80 and quit at age 40, then I'm thinking (or perhaps hoping) that this wouldn't constitute a death "caused" by smoking. Though as long as person is vaping (nicotine), I'm guessing the people that brought you the meme "smoking kills" will have zero issue attributing the death to tobacco and determining it as premature.

 

[Jman8]

In my review of Vapor Hut's comments, I don't notice any significant flaws. They covered the bases and because they bring up black market, I appreciate what they conveyed. But my favorite part is where they say (on p.49):

If vapor products are to be defined as tobacco products, then only e-liquid containing nicotine should be considered the tobacco product and the wide array of hardware used should be treated in a similar manner to pipes used for smoking pipe tobacco. The fact that the language of the proposed rule deems “hookha tobacco” and “pipe tobacco” as tobacco products while considering hookhas and pipes themselves as components and parts, but explicitly deems “electronic cigarettes” rather than e-liquid is inconsistent. E-liquid, hookah tobacco and pipe tobacco all represent nicotine containing substances that are purchased separately and then used in a wide variety of devices. It is illogical and inconsistent to structure the definitions of nicotine containing products and the hardware used in their consumption differently for e-liquid than for pipe tobacco or hookah tobacco.!

Though the obvious criticism comes just one page earlier where they list the appropriate provisions for vapor products:

• Enforcement authority against products determined to be adulterated and misbranded
• Provision and enforcement of good manufacturing practices (GMP), if appropriately tailored to address manufacturing of vapor products and distinct from manufacturing of tobacco products
• Requiring submission of ingredient listing and reporting of harmful constituents
• Requiring registration and product listing for all vapor products
• Requiring childproof packaging and labeling, similar to other household items that pose accidental exposure risk

It is challenging to understand how requiring ingredient listing, report of harmful constituents, registration for all vapor products and labeling isn't going to be a substantial cost to vendors/manufacturers. I still haven't had anyone (anywhere) explain the $330K estimate that FDA notes, but do wonder what would be reasonable for these sort of requirements? I honestly believe $5K per product is closer to fair and reasonable, especially considering that there are tens of millions of eCig products currently on the market (or around $50 billion to be collected).

 

[Kent C]

I want to point out here that there is no such thing as a "certainty" in science. When we state something is a "fact", there is always the possibility, however remote, that it could be wrong.

Is that a fact?

 

[dragonpuff]

we also know that smoking kills 480,000 people per year in this country alone

And how do we know this, pray tell?

It's in Bill Godshall's comment

 

[ClippinWings]

I love that she broke down the number of products they carry and the financial burden of the proposed regulations... Then expands it to include the entire industry and the 100,000 jobs on the line.

We need to push that, cause killing 100k jobs in ANY industry right now is a major no no for the Obama administration

 

[pamdis]

I love that she broke down the number of products they carry and the financial burden of the proposed regulations... Then expands it to include the entire industry and the 100,000 jobs on the line.

We need to push that, cause killing 100k jobs in ANY industry right now is a major no no for the Obama administration

Yes, push it. absolutely. But I doubt it will have any impact on decision makers. Now if there were 5 major companies each laying off 20,000 people, that would make news and be a deterrent. But thousands of small companies each loosing a handful of people that adds up to same amount? That they can hide and deny.

 

[ClippinWings]

Yes, push it. absolutely. But I doubt it will have any impact on decision makers. Now if there were 5 major companies each laying off 20,000 people, that would make news and be a deterrent. But thousands of small companies each loosing a handful of people that adds up to same amount? That they can hide and deny.

Not if we make everyone; media and public, aware of it.

 

[seminolewind]

I think it was an excellently written proposal. Most of our letters don't even touch on those who may sell vape products which can harm people. Toxic liquids, etc. I do think the vaping industry needs some guidelines to protect ITSELF from those who manufacture faulty products and toxic liquids.

I think that it's a fairly written piece in that it shows the underhanded tobacco industry, which is allowed to sell cigarettes and kill a large amount of people, and it also brings up the need for the vaping community to have some protection. If we are concerned about our health, we do need some protection for our vaping products. Evil does lurk out there, money is a strong motivator, and carelessness is always within a group of people. I'd like some regulations to assure me that I'm getting the product that I am buying.

 

[Rossum]

I do think the vaping industry needs some guidelines to protect ITSELF from those who manufacture faulty products and toxic liquids.

Where are these faulty products and toxic liquids and who have they harmed?

I'd like some regulations to assure me that I'm getting the product that I am buying.

You have that now. Fraud is already illegal.

The way I see it, the industry looks to be doing an excellent job of regulating itself.

As a consumer, I have zero desired to have government issue "guidelines" that make innovations illegal or subject them to a lengthy, outrageously expensive "approval" process.

 

[seminolewind]

Rossum,

I don't know of anyone who has sold faulty or toxic products. The vape industry has done a remarkable job regulating itself AA++++++.
But The FDA is not going to say "hey you guys are doing so well at policing yourselves that we're not going to interfere."

My point was that instead of the FDA putting controls on us, the table can also be turned to requiring the FDA to protect us as well. Pretty funny if you ask me.

5 years ago, we were trustingly buying liquid from China , just the words on the bottle without anyone regulating it. And vaping self regulation has improved with leaps and bounds thanks to many of the members (mad scientists) here. Anyone remember when the "Chuck" was a really big deal? And we were all the ones who quit smoking ourselves with vaping. And we can all appreciate ourselves and others here for taking that big step-and it was a very big step to stop smoking. I think it will take years, unfortunately, for us to live down the stigma of a lowly smoker actually helping themselves.


We WILL win this legally or maybe sortof legally, or not legal at all. But no one is going to take my personal vaporizer away!

And you and I both know that there is lots of room under the radar.

 

[zoiDman]

Ya Know. There is a Reason why sometimes something like a Cigarette Related Death Statistic can be Overinflated.

And the Reasoning Isn't Always such an Evil.

Just Say'n.

 

[nomore stinkies]

I read the entire article. I agree with Stefan-well written article. The FDA is going to regulate and their plea is to be reasonable. Only Big Tobacco can afford to join their club. We will all suffer.

 

[GunMonkeyINTL]

Ya Know. There is a Reason why sometimes something like a Cigarette Related Death Statistic can be Overinflated.

And the Reasoning Isn't Always such an Evil.

Just Say'n.

This statement tells me that you are part of the problem that we are facing as a community. The logic you point to is that inflation of the tobacco-related-death statistics is benign because it is for the good of the people that the statistics are being misrepresented to.

We all know that tobacco is bad for you, but the statistics are what give the viewer a frame of reference in which to make their decision to use or not us the product. The logic that allows the statistics to be inflated steal away the right of the individual to make an informed choice. Of course, this is all done for their "own good".

We've determined that tobacco is bad for you, and, even after we informed people of that, they failed to yield to our caution, so they couldn't possibly know what is best for them. We gave them the opportunity to make a choice and they chose incorrectly, so now we have no choice but to force their hand.

It starts with "benign" lies, and ends with out-right bans. Michael Bloomberg tried telling the people of New York that large sodas were bad for their health, but they failed to yield to his superior wisdom.

These lies are not without their consequences. We decided as a culture that cigarettes are bad for you. Exactly how bad, I don't think any of us can say at this point because of how the facts and statistics have been twisted. Still, we know they are "bad", and, still, people like them, so we've had to twist the facts in an attempt to convince the sheep how serious we are when we say they are bad.

If you ask the average person, smoker or non, why cigarettes are so bad for you, they'll say "because they contain nicotine". And, if you ask them why nicotine is so bad, they'll say "it causes cancer". This, of course, is not true, but the goal of the benevolent liars was to goad people into staying away from tobacco products for their own good. The unintended consequence is that people who still wish to use nicotine continue using cigarettes, instead of one of smokeless alternatives, because they don't think they're any safer.

How many fewer smokers would there be if we had been honest about chew, or, even better, snus? Forget how many people actually die from smoking, I want to know how many people have died because they never switched to a smokeless nicotine vehicle because of the lies they were told. Their blood is on the hands of the benevolent liars.

That is evil in my book.

 

[zoiDman]

This statement tells me that you are part of the problem that we are facing as a community. The logic you point to is that inflation of the tobacco-related-death statistics is benign because it is for the good of the people that the statistics are being misrepresented to.

...

I'm Not Saying that Inflating Cigarette Related Deaths is 100% Justified. But I do Understand what One Rational is for Doing It.

And that is to Maintain Cancer Research Funding.

Making Strives is Cancer Treatments benefits the Entire Society, And not Just Smokers. And Federal Cancer Research Funding is Tied to the Amount of "Smoking Related" Deaths.

So you Might Not Like the Fact that the Numbers are Being Manipulated. And Might Only see them as being Done So to Only Harm you or a Specific Segment of the Population.

But as Most Things in Life, it Isn't all Black and White.

 

[Kent C]

I'm Not Saying that Inflating Cigarette Related Deaths is 100% Justified. But I do Understand what One Rational is for Doing It.

And that is to Maintain Cancer Research Funding.

Making Strives is Cancer Treatments benefits the Entire Society, And not Just Smokers. And Federal Cancer Research Funding is Tied to the Amount of "Smoking Related" Deaths.

So you Might Not Like the Fact that the Numbers are Being Manipulated. And Might Only see them as being Done So to Only Harm you or a Specific Segment of the Population.

But as Most Things in Life, it Isn't all Black and White.

What can cause cancer in cigarettes is the tar, not the nicotine. That's pretty 'black and white'. And that was his point - part of it.

 

[GunMonkeyINTL]

I'm Not Saying that Inflating Cigarette Related Deaths is 100% Justified.

It is exactly 0% justified.

But as Most Things in Life, it Isn't all Black and White.

Lying to people to manipulate them into supporting your agenda is ALWAYS wrong - regardless how magnanimous your agenda may be. If you want to increase funding for cancer research, then make an case for increased funding based on the merits of your position.

I think we both agree that funding cancer research is a good thing, but what if we didn't? When you lie to me to get me to support it, you take away my right to form a sovereign opinion. When you lie to people to get them on your side, you're telling them that their opinion matters until they decide to disagree with them, and you're just going to have to manipulate them into making the "right" choice.

Heated kanthal vapors cause cancer. I have evidence to support it, so you should just take my word for it, quit vaping and donate to Susan B Komen.

 

[zoiDman]

What can cause cancer in cigarettes is the tar, not the nicotine. That's pretty 'black and white'. And that was his point - part of it.

No Arguments with the Tar and Combustibles of Burning Tobacco. As to the Nicotine?

Also Causing Cancer and Hampering the Bodies Ability to Fight Off a Cancer are Two Different Things.

Some Believe that Smoking Cigarettes is a 1 to 2 Punch. That the Buring of the Tobacco Increases the Likelihood that you Will Develop Cancer. And then the Burring of the tobacco, And the Nicotine, reduces the Bodies ability to Fight Off the Growing Cancer.

 

[zoiDman]

Lying to people to manipulate them into supporting your agenda is ALWAYS wrong ...

Wrong is a Funny Word.

And arguments can be made that a Wrong can be Justified by a Greater Good.

 

[seminolewind]

I do agree that people confuse the fact that nicotine does not cause cancer. They say, Okay, it's addicting. I say so is caffeine.

Outside of vapers, there's a large percentage of people that think that vapors are smokers who have discovered a sneaky way to cheat with their smoking. " E-cig" does not help. They think that smokers can't possibly be capable of doing something good for themselves. They think that only non smokers can come up with something that works- like gum or lozenges.

The article also touches on the totem pole theory. If the smoker has removed himself from the low position on the totem pole, it makes every one else drop closer to the bottom. Unless of course vaping is no better than smoking.