To respond to the questions previously asked:
1. What can I do to help?
You can submit a written comment. The original deadline was Jan. 2, but they have extended this to Jan 16. The CASAA Call to Awareness page contains the link to take you to the item on Regulations.gov. Click the "Comment Now" button on the right side of the page, near the top.
If your comment will be longer than 2,000 characters, we suggest that you prepare a document and submit that as an attachment. When you get to the Comment page, Section 3 (right under the comment field) there are buttons to upload a file from your computer. In the comment field, you can type, "See attachment."
Here's the link to the CASAA Call to Awareness:
CASAA: Call to Awareness - FDA Public Hearing on Nicotine Reduction Therapy Products
2. What's going to happen after this meeting?
Understand that the purpose of the meeting is for the FDA to gather information to write a report to congress, as required in Section 918 of the Family Smoking Prevention and Tobacco Control Act.
They are gathering information for the report. They already held a workshop on Risks and Benefits of Long-Term Use of NRTs back in 2010. Bill Godshall and I spoke at that meeting as well.
More information will be collected from the speakers and the questions and answers at this meeting, and then from the written comments are are submitted for this meeting, and that were collected in 2010 for the first meeting.
Those who write the report are supposed to review all of this information and then write the report to Congress making recommendations on how the FDA should regulate long-term use of NRT's and Innovative Products and Therapies for Treatment of Tobacco Dependence. Over half of the speakers we have lined up are going to be recommending that instead of treating "tobacco dependence" as an addiction that requires complete abstinence from nicotine, the FDA should pursue Tobacco Harm Reduction (THR). THR is the practice of substituting low risk products that deliver nicotine such as snus, dissolvables, and e-cigarettes in place of taking in nicotine via smoking cigarettes.
The tricky thing is that two different divisions regulate these products. The Center for Drug Research and Evaluation (CDER) regulate NRTs, Zyban, and Chantix -- the products that are considered treatment for a disease. This is the division charged with producing the required report.
The FDA's Center for Tobacco Products (CTP) currently regulates tobacco cigarettes and smokeless tobacco. But smokeless tobacco refers to chewing tobacco, snuff, and snus. The newer dissolvable tobacco orbs -- which are essentially the same thing as Nicorette lozenges -- may not be regulated as of yet. The FDA has announced that it will issue a "deeming" regulation that brings all other products made of or derived from tobacco under the auspices of the CTP (except for the products regulated by CDER as "smoking cessation" (actually really nicotine cessation) products.)
For more information on the questions that FDA seeks answers for during this meeting and in the written comments, see:
http://www.fda.gov/downloads/Drugs/NewsEvents/UCM329739.pdf
Under the heading
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
21 CFR Part 15
[Docket No. FDA–2012–N–1148]
See the SUPPLEMENTARY INFORMATION section.
We feel that this question opens the door for our discussion of THR:
4.1. What kinds of innovative products and treatments designed to achieve any of the above three purposes—abstinence from tobacco use, reduction in tobacco consumption, and reduction in the harm associated with continued use—might be developed to meet the criteria for marketing under applicable legal authorities?
Even though theoretically it will be the Center for Tobacco Products, not CDER, that will regulate e-cigarettes, the division is capricious and arbitrary, in my opinion. I have this to say about the separation of regulation w/i FDA, as the commentary for a slide that displays a table with the Lung Cancer Mortality Rates for Sweden and the US. In Sweden, many smokers have switched to snus, and the smoking rate for males is now something like 12%. The mortality rates for the US are more than double those of Sweden.
If CDER can implement a fast track process for previously unknown, unproven, innovative smoking cessation pharmaceutical products, the Center for Tobacco Products should be implementing a fast-track “modified risk tobacco product” approval process for the smokeless tobacco products that have a proven beneficial effect at the population level.
Instead, the CTP has issued guidance for achieving MRTP approval that will cost millions and take years.
If cutting lung cancer mortality in half isn’t considered modifying risk, I’d like to know what is. Products that are proven to be less hazardous at the population level should not be forced to start at the most basic level of research. How many lives will be lost before the FDA tells smokers the truth?
P.S. The CASAA Call to Awareness page (see link above) has a section that provides help for what to say in written comments. You have to scroll down a ways to find it. The section title is "What you can say."