Now "fighting back" was a quote by you, and to me after what is said above, it renders the 'fighting back' part a bit moot. And you had made some disparaging remarks about those fighting back, usually by pointing out they were fear mongers, but I expect that from some, just not you. I was wrong.
And I would've expected you to call that out as well, but I was mistaken.
I don't think that the "FDA doesn't know how to regulate..." ecigs. But that's just a difference in opinion. I base that on history mainly and what I've read. But who knows maybe ecigs have them stumped.
I think they'll quickly learn ways that it could be regulated, but as long as 'everyone' is in agreement that it needs to be banned from kids, then I think they'll fail. Kids gonna vape, and thus whole, underlying purpose, for such regulations will show up, indefinitely, like they don't really know how to regulate eCigs.
I think FDA has some inklings for how regulations could work, hence the proposal. But, if they were to have gone with doomsday predictions, it would've been interpreted by vast majority of vapers as heavy handed and as outright ban. I truly believe some 'leading experts' (of vaping community) were espousing that the proposal would be in that vein. Instead, it contains lots of language with them seeking input, comments, suggestions for how to go about implementing regulations on many of the points. I see the proposal as them wanting to regulate many facets, but not sure, right now how to implement that and make it work.
Vaping community is in prime position to shape things to come. And politically aware vapers know that we have opposition that will be seeking to do the same thing. Thus commenting, in large numbers, that are to some degree organized, is best thing we can do right now, and for next 75 days.
So you see the ANTZ on one side and us on the other and the FDA as an objective referee?
I'm not seeing evidence of any objective players in this game. But FDA has set themselves up as a referee and has thus far not shown allegiance, in their proposed regulations, to ANTZ. I think they lean that way because they are charged with authority of regulation thru Tobacco Act. But, they aren't caught up, like ANTZ is, in hysteria of anti-eCigs. At least, I don't see that as entirely laden in the proposal. From our, less than objective perspective, anything that isn't saying "eCigs are awesome" will be spun by (some of) us as "FDA is anti-vaping." I'm not sure of any way around that with the existence of Tobacco Act and expressed desire for regulating eCigs.
In the part of the 'deeming' doc under "Health Risks of Products" and under #5 Ecigarettes, the FDA, to their credit, does point out it was only one carto in their 2009 study and seem to 'give' on some other substances - formaldehyde, etc. but the summary paragraph reads a bit different, imo:
"Even if such findings are applicable to many products, e-cigarette manufacturers may vary in the quality of production, as discussed in section V.B.5. with respect to contamination with DEG, and as discussed further with respect to significant variability in nicotine content, and such variation may be dangerous. As such, given the existence of toxic chemicals in at least some e-cigarettes and the fact that most contain nicotine, FDA believes that its oversight of these products (which would occur if this deeming ruling becomes final) is appropriate for the protection of the public health. (my emphasis)
And subsequent paragraphs seem to have this same 'format' - give some points that have been shown in studies but then reinforce with a they are in charge here summation.
In other places they are quoting or summarizing Glantz/ANTZ' proclamations, by putting it in the form of 'seeking research regarding' - this is a like the 'have you stopped beating your wife' question in that it inherently suggests the worst." They 'explain' what some studies have shown but then:
"FDA is also seeking research regarding the long-term effects of flavored tobacco product usage including data as to the likelihood of whether users of flavored tobacco products initiate cigarette usage and/or become dual users with cigarettes." (my emphasis)
That isn't particularly damning in and of itself, but the repeated format imo, is.[/COLOR]
I respect your opinion. I see the repetition as satisfying (or attempting to satisfy) legal types going forward and/or covering the bases on their intent and their desire for what comments, of (high) value, will entail.
I think we, of the vaping community (consumers) can speak to this. Obviously it depends on what is criteria for 'long-term' effects, but I think we have enough non-smoking current vapers in our fold that can speak to this particular talking point, and it be effective, to some degree. Cause, I don't think science, today, will be able to reasonably address that point. And so rest of us, can speak to that, in similar ways to which we've addressed similar points, i.e. that lack of scientific knowledge on a point isn't grounds for eradicating the product.
Regarding 'toxic chemicals in at least some eCigarettes' we can, collectively speak to that (citing research), and I think we can, rather easily, win.