You seem to believe that this entire thing can be approached from first principles. All we have to do is read the proposal, right? The history of the FDA's actions in the Tobacco Control context (including what they've said and done regarding vaping), Congress' clear intent in setting up this regulatory framework, and the behavior/affiliations of the people in positions of authority appear to be factors that you are entirely unwilling to consider.
It's as if you exist in some kind of analytical vacuum ... just you and the reassuring words in this PDF, off in some sort of parallel universe that has no actual connnection with the contextual reality and documented history of the world in which we exist.
The reason that these reg.s are a royal PITA to satisfy is because Congress was doing everything it possibly could when it passed the FSPTCA to make it darned near impossible for BT to introduce new cigarettes. It was assumed that BT had super-deep pockets and that any regulatory framework had to be as daunting as can be.
Now, this series of flaming hoops is being put in front of every little company that makes a glass drip tip (Trippy Tips). And it's being administered by the same folks who did everything they can to ban vaping, and who have engaged in a series of misleading and often downright fabricated series of public relations actions (including recent press releases) designed to terrify an ignorant public about vaping. Not to mention the completely irresponsible (and entirely intentional) obfuscation and/or omission of all the evidence that vaping is incomparable to cigarette smokng in terms of is potential harm to users. Oh yes, and have you forgotten about their junk '09 "study" that they left on their web site for years, which practically every cub reporter in the country has cited when writing their "vaping 101" survey pieces (you know, diethlyene glycol)? You read Bill G's letter, right? Every single syllable in there is true as written. It's not exaggerated, it's not hyperbole, it's not in any any way overstated. Finally does it matter to you that the CTP is chock-full of people with BP industry ties, such as (to pick one random example) Mitch Zeller himself?
So-o let's see ... we're supposed to focus on the text of this PDF and all the reassuring words that it provides, without looking at the background of the FSPTCA, the recent history of FDA applications, the FDA's own recent actions surrounding vaping (the outright ban attempt, the junk studiy, and the bogus press releases), Zeller's own ridiculous comments about vaping, and - oh yes - the fact that this very document treats vaping as something which could be just as dangerous as smoking tobacco cigarettes? No "proven" cessation value, long-term dangers unknnown, blah blah? And ignore Zeller's own BP lobbyist background to boot? (Hamburg's BP backround too, if my memory serves me correctly.)
This is not about the glass being half-full versus half-empty. It's as if there's one little lousy water molecule in it, and you seem to be suggesting that it's dripping over the sides. Good grief.
If you really want to look for a reason to be optimistic, think about how slow the FDA has been with so many things in the past, and/or the very real possibility that they'll never come out with these reg.s. Or that they won't do so prior to Jan '17, which is usually a death-blow for all pending agency rules, even if the presidency remains in the same party's hands.
There may be other reasons for optimism. But none that would involve the text of this document, nor the current crew of folks who are going to be responsible for implementing it (or quite likely, their successors).
I'm done. There is nothing more that I can say to you.
It's as if you exist in some kind of analytical vacuum ... just you and the reassuring words in this PDF, off in some sort of parallel universe that has no actual connnection with the contextual reality and documented history of the world in which we exist.
The reason that these reg.s are a royal PITA to satisfy is because Congress was doing everything it possibly could when it passed the FSPTCA to make it darned near impossible for BT to introduce new cigarettes. It was assumed that BT had super-deep pockets and that any regulatory framework had to be as daunting as can be.
Now, this series of flaming hoops is being put in front of every little company that makes a glass drip tip (Trippy Tips). And it's being administered by the same folks who did everything they can to ban vaping, and who have engaged in a series of misleading and often downright fabricated series of public relations actions (including recent press releases) designed to terrify an ignorant public about vaping. Not to mention the completely irresponsible (and entirely intentional) obfuscation and/or omission of all the evidence that vaping is incomparable to cigarette smokng in terms of is potential harm to users. Oh yes, and have you forgotten about their junk '09 "study" that they left on their web site for years, which practically every cub reporter in the country has cited when writing their "vaping 101" survey pieces (you know, diethlyene glycol)? You read Bill G's letter, right? Every single syllable in there is true as written. It's not exaggerated, it's not hyperbole, it's not in any any way overstated. Finally does it matter to you that the CTP is chock-full of people with BP industry ties, such as (to pick one random example) Mitch Zeller himself?
So-o let's see ... we're supposed to focus on the text of this PDF and all the reassuring words that it provides, without looking at the background of the FSPTCA, the recent history of FDA applications, the FDA's own recent actions surrounding vaping (the outright ban attempt, the junk studiy, and the bogus press releases), Zeller's own ridiculous comments about vaping, and - oh yes - the fact that this very document treats vaping as something which could be just as dangerous as smoking tobacco cigarettes? No "proven" cessation value, long-term dangers unknnown, blah blah? And ignore Zeller's own BP lobbyist background to boot? (Hamburg's BP backround too, if my memory serves me correctly.)
This is not about the glass being half-full versus half-empty. It's as if there's one little lousy water molecule in it, and you seem to be suggesting that it's dripping over the sides. Good grief.
If you really want to look for a reason to be optimistic, think about how slow the FDA has been with so many things in the past, and/or the very real possibility that they'll never come out with these reg.s. Or that they won't do so prior to Jan '17, which is usually a death-blow for all pending agency rules, even if the presidency remains in the same party's hands.
There may be other reasons for optimism. But none that would involve the text of this document, nor the current crew of folks who are going to be responsible for implementing it (or quite likely, their successors).
I'm done. There is nothing more that I can say to you.
