The FDA also has a list of about 99 questions they are looking to consider and as far as I can tell, deeming of ecigs and compents is a done thing or they wouldn't be doing their jobs (in their mind). Congress on the other hand, has oversight. Two very different perspectives. If there were to be any change in FDA's mandate, it would need to come from Congress.
This bold part is reason why I'm waiting at all. Every organization looking out for consumers paints a picture that suggests FDA proposed regulations mean doom and gloom. They don't mince words on this. IMO, they use lots of superlatives to make sure anyone listening realizes that the deeming regulations will end vaping as we know it.
To this day, I disagree with this take. I still see proposed regulations as rather tame, and because of the amount of questions (approx. 100) asked and wording, I feel very confident that FDA is many years away from having a decent grasp on what the heck to even regulate.
If anything is needing to be submitted to FDA, it is to answer the questions in a way where FDA would have even tougher time claiming 'we just don't know' or 'there is no evidence.' Our side's experts routinely point out that they (the FDA) do know, and have been given the evidence already. Still, comments offer opportunity to make that case again, and in numbers, plus perhaps an opportunity for consumers (as stakeholders) to speak to what is reasonable going forward. I.E. - most vapers consider it reasonable to ban sales to minors, so that would be something that FDA and majority of consumers have in common.
Yet, with FTV's hype on what's at stake, and what I've heard thus far from CASAA, I would say there is ABSOLUTELY NO REASON WHATSOEVER to submit comments to the FDA as a consumer. Based entirely on the rhetoric used about the regulations, I see that as the case. If you (in general) are so certain the currently proposed regulations spell an end to vaping, then
I am very curious what you think you could submit that would change the FDA's collective mind going forward?
And again, I do disagree with this take on things, which is why I wrote the 2nd paragraph as I did. Yet, if you have the other take on things, the doom and gloom one, then I say completely ignore the FDA and only write to congress. Tell them your story or what have you. But if the doom and gloom take is accurate, then Congress is our only reasonable hope before the rule goes into full effect. If you are an expert or someone that feels differently, I am very interested in an explanation on how submitting comments to the FDA will counter the certainty of doom and gloom?
Failure to explain or even address that makes me want to ignore your CTA that suggests now is as good of time as any to submit comments to the FDA.
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