FDA Prevent Cancer Foundation's comment on FDA Deeming Regulation

[midficollege]

http://cqrcengage.com/preventcancer...CancerFoundation FDA Comments August 2014.pdf

They seem mostly focused on preventing the availability of nicotine-containing products to minors, which is something which most of us favor, as well as child-proof packaging on said products. However, they also push for the prohibition of characterizing flavors in eliquid and for making the "substantially equivalent to existing products" framework stricter.

I'm still making up my mind about whether or not I'm willing to personally donate, since I'm in favor of the majority of their global work and only disagree in this one (granted, important) instance.

I can understand their desire to present a united front against tobacco/nicotine products in general, especially with the way Washington works, for fear of introducing precedent that will remain on the books for decades.

But at the same time, I would hope that they would realize that cancer is also greatly prevented by reducing the intensity of one's carcinogen/mutagen intake in individual cases.

I'm just leaving this here for others to make up their own minds.

 

[DrMA]

I recommend against donating to any organized health charity. They are ALL nothing but Pharmafia mouthpieces masquerading as public health.
http://journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1001020

And patients do better when docs are away at their sponsored conferences
http://www.eurekalert.org/pub_releases/2014-12/tjnj-pow121814.php

 

[HMav]

With the definition of characterizing flavors, that would leave us with unflavored, and unflavored with menthol.

I also can't stomach the idea that PVs could be deemed as "substantially equivalent". It would be like saying Monopoly money is substantially equivalent to real money.

 

[caramel]

We're going nowhere unless we have a consistent definition of "e-cigarette". The term is used too loosely. If someone wants to regulate something then that something should be first well defined.

Here's another question for FDA:

tobacco leaves also contain water. Should high purity water be considered a "tobacco derivative product" and regulated as tobacco? If yes, would that apply only to water extracted from tobacco, or water in general? If only the first, then which characteristic of tobacco-extracted-water makes it "substantially dissimilar" to water extracted from the river as to warrant a different treatment?

 

[Bill Godshall]

I suggest midficollege read up on FDA's proposed deeming regulation, which would ban >99% of all vapor products now on the market (including all PVs and all bottles of e-liquid) and give the e-cig industry to Big Tobacco companies.

The comments to FDA by Prevent Cancer Foundation (which I never heard of during my 3 decades campaigning to prevent and reduce cancer) include the same false and misleading talking points about vaping made by other e-cig prohibitionists (urging FDA to amend the deeming regulation to ban all vapor products 6 months after the agency issues the Final Rule, ban flavorings, ban internet sales, and mandate false fear mongering product warnings).

Don't understand why any vaper would ever consider giving ANTZ money, but I suspect that many naive vapers do so without even knowing the ANTZ will use the money to demonize and campaign against vaping.

 

[midficollege]

Just for the sake of context, there's a large charity event currently ongoing, known as "Awesome Games Done Quick". Each January, they run a game speedrun marathon for a week to try to raise money through donations for the Prevent Cancer Foundation. http://www.twitch.tv/gamesdonequick

Last year, they raised over $1M. This year, they look set to double that.

Because of the FDA Deeming Regulation, which I have read a large part of, I decided to do my due diligence and research the position of the group as far as vaping is concerned. When I discovered that it was negative, and based on the "dual-use" fallacy, I decided to leave information about such here so that others could make up their own, respective, minds.

It struck me that it would be petty to demand "Don't give money to this thing", but I figured that people should know to what they're donating, and made it easier for them to find that information without having to spend the 30 seconds it would take to Google it for themselves, since there seems to be a significant overlap between the vaping and gaming communities.

 

[DC2]

However, they also push for the prohibition of characterizing flavors in eliquid and for making the "substantially equivalent to existing products" framework stricter.

Making it stricter? Seriously?
That's like trying to make water more wet.

http://www.e-cigarette-forum.com/fo...ing-why-deeming-reg-would-ban-all-e-cigs.html

 

[Jman8]

Don't understand why any vaper would ever consider giving ANTZ money, but I suspect that many naive vapers do so without even knowing the ANTZ will use the money to demonize and campaign against vaping.

I agree. I don't know why any politically aware vaper would vocally support age restrictions knowing that ANTZ supports this and will forever have an inroad into challenging distribution of vaping products (including flavors) by vocally supporting such rhetoric. I suspect that many naive vapers do so without fully understanding that they just agreed with ANTZ on a core political position and are now likely to be swayed by ANTZ rhetoric going forward.

 

[sofarsogood]

It would be like saying Monopoly money is substantially equivalent to real money.

You were close but got it backwards. Real money is substantially equivalent to Monopoly money.

What these groups want to do is demonize vaping to justify taxing it to preserve the tobacco tax revenues. Taxes can sererely disrupt the American vape market but can never collect a fraction of what they got from tobacco.

 

[caramel]

They seem mostly focused on preventing the availability of nicotine-containing products [...]

One may have expected that a group with "Cancer Foundation" in their title may be aware that nicotine is not a carcinogen.
On the other hand, combustion products ARE known to contain carcinogens yet the "Cancer Foundation" is obsessing over nicotine instead of addressing them.

Prohibitionists?

 

[NorthOfAtlanta]

One may have expected that a group with "Cancer Foundation" in their title may be aware that nicotine is not a carcinogen.
On the other hand, combustion products ARE known to contain carcinogens yet the "Cancer Foundation" is obsessing over nicotine instead of addressing them.

Prohibitionists?

Yes.

Going to be fun to watch them and the Alzheimer's and Dementia crowd have a fight over it when the studies they are working on prove it can help people with those diseases. Somewhere on ECF there's a thread that brought up a study that found smokers are 30% less likely to die of Alzheimer's than non smokers.

 

[HecticEnergy]

I vote you donate your money to CASAA... assuming I have a vote on where you spend your money.. lol

 

[WhiteHighlights]

I think this is the thread NorthOfAtlanta was referring to: http://www.e-cigarette-forum.com/fo...rticle-possible-health-benefits-nicotine.html

The article is very interesting!

 

[NorthOfAtlanta]

I missed that one somehow, it's even better than the one I was thinking about. Going to read it tonight and follow some of the links in it, thanks.

 

[VBdev]

The "Prevent cancer foundation" is against vaping? Does not compute. They need a new name.

 

[Jman8]

The "Prevent cancer foundation" is against vaping? Does not compute. They need a new name.

How about, "Increase Cancer Funding (via ANTZ rhetoric) Foundation"

or

ANTZ Puppets

as short way of saying the name, and sticking to accuracy.