Greg Conley gave the following presentation during the public comment period this morning..
Good morning. My name is Gregory Conley and I am the President of the American Vaping Association, a nonprofit organization that advocates on behalf of small and medium-sized businesses in the vapor market. Thank you for having me today. Before I begin, I must say that as a longtime follower of the science on vapor products, I was disappointed in the level of scientific discourse displayed yesterday by numerous anti-harm reduction and anti-vaping presenters, as well as the inability of independent researchers who have published some of the most significant work on vapor products to give full presentations.
As an organization, we agree that continued research into vapor products is necessary. We encourage this research. However, as we saw in 2009 when the FDA misled the public on the hazards of the NRT-like levels of ‘nitrosamines’ found in e-cigarette cartridges -- a study that continues to be used to this day to justify harsh actions against vapor products -- such research becomes dangerous when it is spun to create the false perception of a material level of harm. The FDA’s misrepresentation was one of the first in the U.S., but it was not the last. Hype and conjecture surrounding e-cigarette toxicity has led us to a place where in 2013, 60% of the public thought vaping was less hazardous than smoking. This is down 25% from 2010, when 80% of the public accurately believed vaping was less hazardous. This lack of understanding is not because of a lack of regulation, but because of false claims made by those seeking harsh regulation.
Even worse, this research is hazardous from the onset when it is performed by researchers with no familiarity with the products or willingness to even speak to users to understand how the products work. Unlike with cigarette smoking, at the present time there is no generally acceptable standard for testing vaping products. So we find ourselves in a situation where researchers are presenting data on the toxicity of vapor that has been produced using unrealistic device settings that no vaper would actually use. When relying on evidence in such a new and fast developing field, the FDA should critically analyze each and every study and not just assume that passing “peer review” makes the study automatically valid.
Importantly, we do not encourage more research because we fear that vaping may be more hazardous than smoking. Instead, we want to find out the relative risks of different classes of products, and in the process we believe all players should keep in mind that the hazards of these products must be compared to cigarettes. This is what the primary stakeholders in this dialogue – smokers and vapers -- deserve, but instead they are being discouraged by a small group that is using falsely-alarming language.
The greatest danger is that excessive regulatory reaction to minute risks will compromise the appeal of vaping to smokers and we end up with more smoking than we would have had without such regulation.