Fsusa to start spectro-analysis of e-juice?
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Great post, Zen.
I think that the conversation can devolve into bickering because people read messages with a certain tone. When I first jumped into the discussion on diacetyl, I didnt understand the hysterical comments, or at least I didnt think they pertained to me. I felt completely rational when I was responding and wasnt worked up. But then someone takes it the wrong way (or personally) and responds to you with that tone, so you do the same, etc. etc (insert loud explosion here). I dont think anyone here has wanted all of the drama surrounding this vendor, or the discussion on safety, but thats just how it ended up. Now people have pegged who they think the instigators, or hystericals are and its tough to come back from.
If everyone here agrees with the IDEA of testing, and the fact that we are now having a conversation about what that might mean, they should thank everyone who has participated in these discussions None of this would be happening if the discussions never took place however angry you may have been about an opposing view.
That being said, testing would be a huge step for the industry. And we are now dealing with a massive claim in that respect. So I dont believe its wise to pat everyone on the back without getting more information about the process. If we remove all of the drama, there are still some excellent questions that have been left unanswered. Important questions. Among them:
I think that the conversation can devolve into bickering because people read messages with a certain tone. When I first jumped into the discussion on diacetyl, I didnt understand the hysterical comments, or at least I didnt think they pertained to me. I felt completely rational when I was responding and wasnt worked up. But then someone takes it the wrong way (or personally) and responds to you with that tone, so you do the same, etc. etc (insert loud explosion here). I dont think anyone here has wanted all of the drama surrounding this vendor, or the discussion on safety, but thats just how it ended up. Now people have pegged who they think the instigators, or hystericals are and its tough to come back from.
If everyone here agrees with the IDEA of testing, and the fact that we are now having a conversation about what that might mean, they should thank everyone who has participated in these discussions None of this would be happening if the discussions never took place however angry you may have been about an opposing view.
That being said, testing would be a huge step for the industry. And we are now dealing with a massive claim in that respect. So I dont believe its wise to pat everyone on the back without getting more information about the process. If we remove all of the drama, there are still some excellent questions that have been left unanswered. Important questions. Among them:
- What is the name of the lab being used? This is important because it is directly related to the legitimacy of the testing.
- What is the actual type of analysis being done? This is important because it will tell us how the process is conducted and reassure us that it will be as accurate as possible.
- Will the liquid and vapor will be tested or just one or the other? This is important because the application of heat could alter or have some type of impact on the ingredients. We need to know that this testing will actually be useful.
- What will happen with the results? Will we see the full lab reports? What purpose will they serve at that point? Will we then be able to speak openly about risks associated with each substance, or will we be told that a certain ingredient is nothing to worry about?
- Why is known information still not being disclosed? The FA diacetyl list is updated and available for anyone who uses their flavorings. Since much of the outcry pertains to diacetyl, it would be a great step to disclose which premixes contain it. As of now, the only response we have to go on comes from a locked thread on the vendors sub forum which pretty clearly tells us that they will not disclose this information.
Why does this happen to me? Several times especially if I am on a FSUSA post?
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Maybe your getting signed out, they system tends to time out and log you out after a few minutes of inactivity unless you select the "remember me" tab.
Nah, an admin has locked me out due to my posts. (not saying it is true just no answer to my emails regarding this)
I agree Panini. These are but a few basics that should have been provided upon announcment, otherwise you would think they would have forseen this very discussion. This is another thing I find very odd.
This is exactly what we want to know. Thank you for condensing several members concerns Panini. The answer to all of these questions are, (supposedly), already known. The answers should be quite simple and would be greatly appreciated.
If you think about it, from a PR standpoint it is well played. I'm not saying this is the case in this instance as nobody but he knows what's really going on with his testing, but assume Company A has taken some heat lately because of their cavalier attitude about customer safety. What better way to silence the critics than to tell them you're giving them what they want? Sure there are no specifics, but if anybody pushes for facts, Company A or any of its "officers" can talk about it obviously being the work of 'haters', FDA plants, hysterics, or rival vendors. The best part is that the the wait for test results could easily be drawn out six months- by which time they can either hope that the issue has been swept under the rug (again) or they can start some lame-brained story about the lab screwing up the test results so gosh-golly-gee they're going to have to find another testing site (take a few months to do that) and then another six month wait for the test results again. It's a perfect gimmick, and I'm hoping that enough of people have learned to be at least cynical enough to take all claims with a grain of salt.
Panini, I agree with your view on how to proceed....
I spent a part of this afternoon reading the full warning letter that was sent to Johnson Creek from the FDA, and I was able to glean a fair amount of knowledge about what the FDA expects from a vendor in this industry, if the industry is ever to seek approval of the FDA.
Of particular interest to me is the following paragraph: "3. Your firm has not conducted specific identification testing when components are accepted based on the supplier's report of analysis (21 C.F.R. § 211.84(d)(2)). For example, your firm accepts a Certificate of Analysis (COA) from the supplier of components. However, your firm does not conduct identity testing on your components or appropriate verification of the supplier's test results."
Any company that wishes to be in the commercial business of manufacturing vaping liquid with the intention of seeking FDA approval to sell these products to the public has no choice but to perform testing on the core components that go into the finished product, and they mast additionally test the finished product as well. The FDA has clearly stated that the manufacturer cannot rely on the suppliers COA and must perform these tests to be certain the COA is correct.
I will repeat that the ABOVE comment is about Johnson Creek, and their own particular issues, HOWEVER, it is important to realize that FSUSA must ALSO comply with the same rules, and since to date they have not performed these tests, they have been selling product to the public that MAY be unsafe... AND BASED ON INFORMATION AND BELIEF, SO IS EVERYBODY ELSE that is making eJuice in America.
I am also sensitive to the needs of FSUSA in keeping their formulations secret... the "recipes" are the exclusive intellectual property of FSUSA, and I will NEVER ask them to divulge the actual flavors in an explanation of "what's in their juice" and it is unreasonable to ask them to do so... It is NOT unreasonable to ask them if their product contains flavors which are known to contain hazardous compounds. I feel no need to even know which flavorants contain these compounds. I only need to know that they are not present in the juice I use. A simple "yes or no" will suffice... assuming the yes or no came from a federal lab, and shy of that, I will not believe them because after all, they are probably trusting the COA that comes with the raw materials.
So, back to Panini... We need answers to the questions you have outlined, framed within the context of the LACK of need for FULL recipe disclosure. It is absolutely unfair to ask FSUSA to disclose that which is proprietary.
The answer to the question "Is this stuff safe" is NOT a proprietary answer.
By the way... the A students have suggested that we never asked the tobacco companies to provide us with the same level of disclosure, and wonder why we suddenly care... The answer to that is simple...
Fool me once, shame on you... fool me TWICE... shame on ME... Personally, I am older and wiser now... I quit smoking for my health... I took up vaping for my sanity... I want to make sure I am not making myself sick by trying to be more healthy... it seems like a good plan to me.
I spent a part of this afternoon reading the full warning letter that was sent to Johnson Creek from the FDA, and I was able to glean a fair amount of knowledge about what the FDA expects from a vendor in this industry, if the industry is ever to seek approval of the FDA.
Of particular interest to me is the following paragraph: "3. Your firm has not conducted specific identification testing when components are accepted based on the supplier's report of analysis (21 C.F.R. § 211.84(d)(2)). For example, your firm accepts a Certificate of Analysis (COA) from the supplier of components. However, your firm does not conduct identity testing on your components or appropriate verification of the supplier's test results."
Any company that wishes to be in the commercial business of manufacturing vaping liquid with the intention of seeking FDA approval to sell these products to the public has no choice but to perform testing on the core components that go into the finished product, and they mast additionally test the finished product as well. The FDA has clearly stated that the manufacturer cannot rely on the suppliers COA and must perform these tests to be certain the COA is correct.
I will repeat that the ABOVE comment is about Johnson Creek, and their own particular issues, HOWEVER, it is important to realize that FSUSA must ALSO comply with the same rules, and since to date they have not performed these tests, they have been selling product to the public that MAY be unsafe... AND BASED ON INFORMATION AND BELIEF, SO IS EVERYBODY ELSE that is making eJuice in America.
I am also sensitive to the needs of FSUSA in keeping their formulations secret... the "recipes" are the exclusive intellectual property of FSUSA, and I will NEVER ask them to divulge the actual flavors in an explanation of "what's in their juice" and it is unreasonable to ask them to do so... It is NOT unreasonable to ask them if their product contains flavors which are known to contain hazardous compounds. I feel no need to even know which flavorants contain these compounds. I only need to know that they are not present in the juice I use. A simple "yes or no" will suffice... assuming the yes or no came from a federal lab, and shy of that, I will not believe them because after all, they are probably trusting the COA that comes with the raw materials.
So, back to Panini... We need answers to the questions you have outlined, framed within the context of the LACK of need for FULL recipe disclosure. It is absolutely unfair to ask FSUSA to disclose that which is proprietary.
The answer to the question "Is this stuff safe" is NOT a proprietary answer.
By the way... the A students have suggested that we never asked the tobacco companies to provide us with the same level of disclosure, and wonder why we suddenly care... The answer to that is simple...
Fool me once, shame on you... fool me TWICE... shame on ME... Personally, I am older and wiser now... I quit smoking for my health... I took up vaping for my sanity... I want to make sure I am not making myself sick by trying to be more healthy... it seems like a good plan to me.
The fact that OSHA was there and didn't find anything wrong is a good start. I think we should call them or contact them through their site and thank them for their open-mindedness regarding this industry. Perhaps we can get them to release their approval faster than the several weeks David mentioned it would take. Then he could give that to the FDA.
Here's the info for OSHA
Tuscon OSHA office
520-628-5478
Here's the info for OSHA
Tuscon OSHA office
520-628-5478
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I agree. The "full lab report" thing stemmed from what I understood to be part of the announcement.
Why would the FDA care what OSHA has to say about his business? OSHA cares if he has a safe workplace for his employees, and absolutely, positively, nothing more.
What a great idea!! We're quick to dash of a letter when they're doing something wrong. It might be a great thing to call or a send an email thanking them for their open-minded attitude and making vaping safer for the customers with their inspection, and that agencies with that kind of affirmative behavior are well worth whatever was spent in OSHA inspection fees.
With the exception of #2 and perhaps to some degree #4, all of Panini's questions have been answered in previous posts. They're not hard to find.
#2 is a good question and there may be exceptions, but I doubt the typical ECF member would have enough scientific or chemical knowledge to know if "testing process A" was more effective or accurate than "testing process B".
As for #4, since it's published on the FSUSA's site that they use FlavorArt flavorings and there is a prominent link to the FA site where they openly disclose flavors containing diacetyl and their percentages, I don't understand why people think it would be necessary for FSUSA to re-publish these details on the FSUSA site.
Why is none of this outrage and demands for disclosure directed toward any of the other 50+ registered suppliers like Mrs. T's, Johnson Creek, Backwoods Brew, Tasty Vapor, Pure Vapes, Gourmet Vapor, etc.
Since nobody's bashing them or demanding their disclosure, only one word comes to mind: witch-hunt.
Bottom line is, anyone concerned about the safety of any vendor's product should buy elsewhere.
#2 is a good question and there may be exceptions, but I doubt the typical ECF member would have enough scientific or chemical knowledge to know if "testing process A" was more effective or accurate than "testing process B".
As for #4, since it's published on the FSUSA's site that they use FlavorArt flavorings and there is a prominent link to the FA site where they openly disclose flavors containing diacetyl and their percentages, I don't understand why people think it would be necessary for FSUSA to re-publish these details on the FSUSA site.
Why is none of this outrage and demands for disclosure directed toward any of the other 50+ registered suppliers like Mrs. T's, Johnson Creek, Backwoods Brew, Tasty Vapor, Pure Vapes, Gourmet Vapor, etc.
Since nobody's bashing them or demanding their disclosure, only one word comes to mind: witch-hunt.
Bottom line is, anyone concerned about the safety of any vendor's product should buy elsewhere.
Well, I used to work in the health field and we had "surprise" OSHA inspections at least once per year, (depending if we passed our inspections or not). These inspections weren't voluntary...they were required. OSHA expected certain things to be in place:
- We had MSDS sheets of all chemicals being used in our facilities, (i.e. cleaning solutions, hand soap, etc.)
- We had procedures\supplies in place to protect our employees, (i.e. glove, face masks, etc.)
- We had signed safety\training documentation in place
There are others but the point is...OSHA inspections had everything to do with the safety of our employees and nothing else.
In my example. I managed several facilities in the health field. OSHA never came in and said "Your nurses aren't giving the incorrect medications" or "This medication is detrimental to the clients health." They came in and said, "You don't have an MSDS sheet for the Alcohol bottle in the nursing station" or "There are no gloves available for staff." They are a governmental department put in place for ONE aspect...in this case...Occupational Safety and Health Administration...period. There were other governmental agencies who followed up with the nurses giving incorrect medications or medications detrimental to the clients health.
My point is...OSHA means nothing when it comes to safety for the consumer. They are trained to ensure that workers have a safe working environment.
Let's not confuse reuired OSHA inspections with the safety of E-Juice...it's just wrong.
- We had MSDS sheets of all chemicals being used in our facilities, (i.e. cleaning solutions, hand soap, etc.)
- We had procedures\supplies in place to protect our employees, (i.e. glove, face masks, etc.)
- We had signed safety\training documentation in place
There are others but the point is...OSHA inspections had everything to do with the safety of our employees and nothing else.
In my example. I managed several facilities in the health field. OSHA never came in and said "Your nurses aren't giving the incorrect medications" or "This medication is detrimental to the clients health." They came in and said, "You don't have an MSDS sheet for the Alcohol bottle in the nursing station" or "There are no gloves available for staff." They are a governmental department put in place for ONE aspect...in this case...Occupational Safety and Health Administration...period. There were other governmental agencies who followed up with the nurses giving incorrect medications or medications detrimental to the clients health.
My point is...OSHA means nothing when it comes to safety for the consumer. They are trained to ensure that workers have a safe working environment.
Let's not confuse reuired OSHA inspections with the safety of E-Juice...it's just wrong.
Actually, several of those you mentioned do disclose. Pure Vapes has it on the ordering page which flavors. In addition, nobody should have to memorize FA's diacetyl list when an asterisk beside a flavor could easily be used. Plus it doesn't tell you about the blends. For example, does Hopscotch contain diacetyl? There is no FA flavoring with that name so how is someone supposed to know unless it is disclosed?
Scott, David is the one that spoke up and said diacetyl isn't worth worrying about. He's the one that said he was going to change the industry with his new standards. He's the one that chose to be in the limelight, so he's the one we'll be looking to for correct industry standards.
Looking at FlavourArt's site doesn't tell us anything when we don't know which flavorings he uses in his mixes. He needs to tell his customers which ones contain it. Even an * would be a move in the right direction and at least show some honesty when he says he wants to offer safe eLiquid (fluid).
Looking at FlavourArt's site doesn't tell us anything when we don't know which flavorings he uses in his mixes. He needs to tell his customers which ones contain it. Even an * would be a move in the right direction and at least show some honesty when he says he wants to offer safe eLiquid (fluid).
WOW... just plain wow... I'm sorry, but you should read my long-winded post. OSHA is about OCCUPATIONAL safety in the work place. OSHA doesn't care if vaping is safe or deadly... they don't care if the company being inspected makes e-juice, or cleans septic tanks. An approval by OSHA means that the employees are not at risk of a work place related accident. Ask YOUR employer about OSHA... ALL businesses with employees must be in full compliance. In short, they care if the ladder that is used to change a light bulb is safe.
And OSHA doesn't charge fees to inspect a business... they FINE companies that don't pass inspections...
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Golly, I think I must have trusted in the wrong pairing in a truthiness sandwich read in another thread. Shocking!
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