First, e-cigarettes contain and deliver nicotine—a well-recognized addictive chemical—in amounts comparable to traditional cigarettes. Accordingly, e-cigarettes should be assumed to be both harmful and addictive. Second, youth are “particularly vulnerable” to nicotine’s adverse effects on the central nervous system. As recently determined by the Surgeon General in the latest Report, nicotine exposure during adolescence adversely affects cognitive function and development, potentially resulting in “lasting deficits in cognitive function.” As a result, “the potential long-term cognitive effects of exposure to nicotine in this age group are of great concern.”
Other harms relating to the use of e-cigarettes are also likely to exist beyond their growing use by youth. For example, the vapor from e-cigarettes has been found to contain formaldehyde and propylene glycol. Formaldehyde is a known human carcinogen. Propylene glycol when heated and vaporized can form propylene oxide, also a known human carcinogen.
E-cigarettes have furthermore been found to deliver particulate matter, in the same number and size as traditional cigarettes. The inhalation of such particles—e.g., through tobacco smoke or air pollution—has been found to contribute to pulmonary and systemic inflammatory processes and increase the risk of cardiovascular and respiratory disease and death. The particles from e-cigarettes have also been found to contain metals, such as tin and nickel, in amounts two to 100 times higher than those found in a traditional Marlboro cigarette smoke. These metal nanoparticles can deposit into the lungs, causing adverse respiratory effects.
The liquid nicotine used in e-cigarettes also presents increasing dangers. The number of phone calls made to poison centers involving e-cigarette liquids, has increased dramatically over the past four years—from one per month to 215 per month nationwide. As CDC Director Tom Frieden has explained, “[e]-cigarette liquids as currently sold are a threat to small children because they are not required to be childproof, and they come in candy and fruit flavors that are appealing to children.” Indeed, over half of the phone calls made to poison centers during the past four years regarding e-cigarettes involved young children under the age of five.
Finally, there is a widespread misperception among youth about the safety of e-cigarettes. As the FDA has already noted, young adults often “mistakenly think non-cigarette tobacco products are safe alternatives to cigarettes.” Indeed, although no manufacturer of e-cigarettes has yet applied to have its product considered a nicotine replacement therapy, over 85 percent of e-cigarette users reported in an international survey that they assumed such products would help them quit smoking. For additional discussion regarding the harmful effects of nicotine, see Section III.C.2, infra.
Given these facts and those set forth in the Proposed Rule, we agree with the FDA’s conclusion that regulation of e-cigarettes is appropriate for the protection of the public health.
]. I am so glad I've had this opportunity to "self-medicate" with vapor -- I asked my doc about the Nicotrol inhaler when they first came out, thought it might have potential, and he told me couldn't prescribe it to me, because I have asthma. I said, how is it better if I just keep smoking? He just shrugged, said that's the law. Total freaking lunatics.
