@Vape360 How many people does ProVape employ? You are the perfect example of the kind of small business the US should be proud of. I'm focusing a lot of my letters on the economic impact the regulations are vague about.
Also, does your logo appear on any trade association websites? In the FDA's Regulatory Impact Analysis they specifically chose to ignore industry estimates of the number of manufacturers impacted (claiming it "did not provide concrete data sources"), but instead went with their own estimates based on "logo counts from trade association websites and FDA listening sessions...."
I haven't been on the ProVape threads lately, since I have been reviewing regulations the members of congress may be unaware of. This is a fun one:
"Under the FFDCA [Federal Food, Drug & Cosmetic Act]
, drug and device manufacturers must demonstrate that their products are both safe and effective in order to gain FDA marketing approval. The safety and effectiveness standard poses a difficult challenge for regulating tobacco products, which are manifestly unsafe when used as intended.
"Critics of FDA’s 1996 rule argued that in asserting regulatory authority over tobacco products, the agency would have no choice but to ban them because of their harmful and addictive effects.
"In commenting on the rule, the FDA conceded that tobacco products are “unsafe” as that term is generally understood, but concluded that banning tobacco products was not a realistic option because the health care system would be overwhelmed by more than 40 million nicotine addicts seeking assistance for withdrawal symptoms. Moreover, the agency argued, banning cigarettes would create an enormous black market, which might lead to the use of unregulated and potentially even more harmful products."
I didn't find the report itself all that interesting, but I liked the quote.
FDA Final Rule Restricting the Sale andDistribution of Cigarettes and Smokeless Tobacco (June 24, 2010)
http://www.nacsonline.com/Advocacy/Issues//Tobacco/Documents/CRSReport.pdf
So, in 2010 the FDA was worried that 4 million nicotine addicts would overwhelm the healthcare system, yet 6 years later, after we found something that works, they are regulating it out of existence. Are they ...... that we didn't get their permission to save ourselves?