NYT: New Calculus on Smoking, Its Health Gained vs. Pleasure Lost
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Hmmm. It is interesting but the document which is linked is the 'impact doc' - discussed in the regulations thread started by pamdis. It's the RFA (SBA) where the FDA has to 'take it into consideration' but as far as I could find out, has no real enforcement of the intent of the RFA. The SBA can act as a friend of the court (for small businesses) but that's about it. There is not one mention of 'happiness' in the doc, although it may be in the legislation that authorized it.
And I think they overstate the case how some, evidently, those who want regulation, say that the bar is set too high, but again, imo, it's only a virtual bar and one that the FDA says in that doc and the deeming doc that basically, they've done their 'due diligence' in regards to RFA and the Executive Order 12866 (Clinton) which also deals with economic impact.
http://www.reginfo.gov/public/jsp/Utilities/EO_12866.pdf
From one of my earlier posts that shows this:
pg185:
"The agency believes that this proposed rule would be an economically significant
regulatory action as defined by Executive Order 12866."
pg186:
"The Regulatory Flexibility Act requires agencies to analyze regulatory options that would
minimize any significant impact of a rule on small entities. FDA has determined that this
proposed rule would have a significant economic impact on a substantial number of small
entities."
The FDA basically justifies all of this by:
pg187:
"The proposed deeming action differs from most public health regulations in that it is an
enabling regulation. In other words, in addition to directly applying the substantive requirements
of chapter IX of the FD&C Act and its implementing regulations to proposed deemed tobacco
products, it enables FDA to issue further public health regulations related to such products. We
expect that asserting our authority over these tobacco products will enable us to propose further
regulatory action in the future as appropriate, and those actions will have their own costs and
benefits."
--
One quote from the article - don't know the level of certainty regarding it but it's a question someone asked in another thread - when will the final rule happen?
"The economists’ assessment of the agency’s approach is part of a flood of public comments — more than 69,000 as of Wednesday — submitted to the F.D.A. on the tobacco regulations. The rules are supposed to become final by next summer, and experts anticipate that legal challenges will soon follow."
I also anticipate.. with great hope.. the legal challenges that will follow
Thanks for posting!
written clearly by people who have no idea what happiness is or how smoking might lead to such loss of pleasure.
As a math geek, the title of this article made me chuckle
The happiness quotient? Do they mean the happiness difference quotient?? Is that the "calculus" the title is referring to???
The happiness quotient? Do they mean the happiness difference quotient?? Is that the "calculus" the title is referring to???
How on earth could the agency legitimately read and honestly consider all 70,000+ comments, by next summer?Hmmm. It is interesting but the document which is linked is the 'impact doc' - discussed in the regulations thread started by pamdis. It's the RFA (SBA) where the FDA has to 'take it into consideration' but as far as I could find out, has no real enforcement of the intent of the RFA. The SBA can act as a friend of the court (for small businesses) but that's about it. There is not one mention of 'happiness' in the doc, although it may be in the legislation that authorized it.
And I think they overstate the case how some, evidently, those who want regulation, say that the bar is set too high, but again, imo, it's only a virtual bar and one that the FDA says in that doc and the deeming doc that basically, they've done their 'due diligence' in regards to RFA and the Executive Order 12866 (Clinton) which also deals with economic impact.
http://www.reginfo.gov/public/jsp/Utilities/EO_12866.pdf
From one of my earlier posts that shows this:
pg185:
"The agency believes that this proposed rule would be an economically significant
regulatory action as defined by Executive Order 12866."
pg186:
"The Regulatory Flexibility Act requires agencies to analyze regulatory options that would
minimize any significant impact of a rule on small entities. FDA has determined that this
proposed rule would have a significant economic impact on a substantial number of small
entities."
The FDA basically justifies all of this by:
pg187:
"The proposed deeming action differs from most public health regulations in that it is an
enabling regulation. In other words, in addition to directly applying the substantive requirements
of chapter IX of the FD&C Act and its implementing regulations to proposed deemed tobacco
products, it enables FDA to issue further public health regulations related to such products. We
expect that asserting our authority over these tobacco products will enable us to propose further
regulatory action in the future as appropriate, and those actions will have their own costs and
benefits."
--
One quote from the article - don't know the level of certainty regarding it but it's a question someone asked in another thread - when will the final rule happen?
"The economists assessment of the agencys approach is part of a flood of public comments more than 69,000 as of Wednesday submitted to the F.D.A. on the tobacco regulations. The rules are supposed to become final by next summer, and experts anticipate that legal challenges will soon follow."
I also anticipate.. with great hope.. the legal challenges that will follow
Thanks for posting!
Especially the ones with attachments or references to studies.
"The rules are supposed to become final by next summer, and experts anticipate that legal challenges will soon follow."
I also anticipate.. with great hope.. the legal challenges that will follow
Thanks for posting!
Our last stand.
As a math geek, the title of this article made me chuckle
The happiness quotient? Do they mean the happiness difference quotient?? Is that the "calculus" the title is referring to???
Don't ask me. I read that article twice... No clue.
I was hoping someone here would help me understand this.
That was my point... No way is it possible. But I'm convinced the FDA will find a way to make it "happen".They can't. They are supposed to read and evaluate all the attached studies...
Of course they will. They have to protect the children. Once you invoke the children, you're home free.
Like that nasty clause on the side of the submit form.
re: will be reviewed by angentcies (not by FDA only) and that some agencies might redact, or withold certain parts of submissions or the entire submissions such as rude or foul language or whatever they may think is mass mailed by groups .... Etc...
Attachments
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Which is why I didn't understand FTV. Or the "I am an adult consumer of premium cigars..."
Interesting link, Katya.
Hm.... can somebody please jog my memory... I have seen this before....
..and I have seen that a large part of the so-called "cost of smoking" - which is written up in dollars and cents by the health taliban - is, in fact, a mysterious "cost to society" such as lost free babysitting by a grandparent (uhm.. do all grandparents do that, with all our forced mobility nowadays? Is there a law forcing grandparents to offer free babysitting? And when did "society" start to pick up the tab for babysitting?) or as grief by relatives when a smoker falls ill or dies. At whatever age. Like when aunt Nora dies peacefully in her bed at 103 and her death is "diagnosed" as '"smoking-related" because she smoked a few packs of cigarettes once, in her youth.
Of course, when it is pointed out to the health taliban that smoking actually SAVES money in old-age pension and medical care (due to smokers dying earlier), they whine and cry that you cannot put a price tag on a human life. Although they do precisely that when calculating their mysterious "cost to society".
I have seen this before. This subject has been discussed here before. Can somebody please point me to that place?
..
And yes, I do agree that being ostracized and treated like crap, yes, that does come with a cost. Happiness usually translates into motivation and productivity. Whereas unhappiness translates into the exact opposite. There you have your "cost to society".
/edit:
Auntie Nora - courtesy of Christopher Snowdon : The EU's 'lifestyle policy' (caution: reading this blogpost will make your hair stand on end... )
Hm.... can somebody please jog my memory... I have seen this before....
..and I have seen that a large part of the so-called "cost of smoking" - which is written up in dollars and cents by the health taliban - is, in fact, a mysterious "cost to society" such as lost free babysitting by a grandparent (uhm.. do all grandparents do that, with all our forced mobility nowadays? Is there a law forcing grandparents to offer free babysitting? And when did "society" start to pick up the tab for babysitting?) or as grief by relatives when a smoker falls ill or dies. At whatever age. Like when aunt Nora dies peacefully in her bed at 103 and her death is "diagnosed" as '"smoking-related" because she smoked a few packs of cigarettes once, in her youth.
Of course, when it is pointed out to the health taliban that smoking actually SAVES money in old-age pension and medical care (due to smokers dying earlier), they whine and cry that you cannot put a price tag on a human life. Although they do precisely that when calculating their mysterious "cost to society".
I have seen this before. This subject has been discussed here before. Can somebody please point me to that place?
..
And yes, I do agree that being ostracized and treated like crap, yes, that does come with a cost. Happiness usually translates into motivation and productivity. Whereas unhappiness translates into the exact opposite. There you have your "cost to society".
/edit:
Auntie Nora - courtesy of Christopher Snowdon : The EU's 'lifestyle policy' (caution: reading this blogpost will make your hair stand on end... )
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Th difference is that FTV's comments each have an individual's story within them, whereas the "I am an adult cigar smoker.." comments are almost identical to each other. Thus, they have just cause to disregard all but one of those cigar smoker comments, but they have to treat the FTV comments as individuals because they're each fundamentally different. I'm not sure the maker of those cigar petitions was aware they would be disregarded if they are identical, I know I wasn't aware of that before...
Sure they can read them all. There's no accountability mechanism in place to prove they didn't.They can't. They are supposed to read and evaluate all the attached studies...
It's like all the nonsensical emails I get forwarded from my boss that are addressed to him. You bet, I read each and every one of them.
I'm totally creeped out by the idea of the FDA taking measurements on their notion of my "happiness". Maybe it's just me but it sounds Orwellian.
They seem to be having difficulty grasping the several simple and very tangible variables related to ecigs and my health - I really don't want their fingers in my joy.
They seem to be having difficulty grasping the several simple and very tangible variables related to ecigs and my health - I really don't want their fingers in my joy.
As a math geek, the title of this article made me chuckle
The happiness quotient? Do they mean the happiness difference quotient?? Is that the "calculus" the title is referring to???
Math geek here as well (as you can see from the avatar!), and I assumed it was about smoking and kidney stones. I guess we'll never know...
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An update:
www. nytimes.com /2014/08/09/opinion/a-misguided-tobacco-proposal.html?mabReward=RI%3A18&module=WelcomeBackModal&contentCollection=Middle%20East®ion=FixedCenter&action=click&src=recg&pgtype=article&_r=0
So, clearly, according to NYT, virtue is its own reward. We're not supposed to be happy. Quit or die.
Way to go, NYT.
www. nytimes.com /2014/08/09/opinion/a-misguided-tobacco-proposal.html?mabReward=RI%3A18&module=WelcomeBackModal&contentCollection=Middle%20East®ion=FixedCenter&action=click&src=recg&pgtype=article&_r=0
So, clearly, according to NYT, virtue is its own reward. We're not supposed to be happy. Quit or die.
Way to go, NYT.
An update:
www. nytimes.com /2014/08/09/opinion/a-misguided-tobacco-proposal.html?mabReward=RI%3A18&module=WelcomeBackModal&contentCollection=Middle%20East®ion=FixedCenter&action=click&src=recg&pgtype=article&_r=0
So, clearly, according to NYT, virtue is its own reward. We're not supposed to be happy. Quit or die.
Way to go, NYT.
Note how they said "probably" - which is code for "we really have no idea what we're talking about so we'll just take a stab in the dark here..."
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