SmokeyJoe posted this in the Evolv thread in APV Discussions and I got ok to post it here as well.
http://vaping.com/news/exclusive-in...rom-evolv?_ga=1.67047788.375002566.1413519349
Most here will know about the new dna 40 board that has 'temperature protection'. This isn't to promote it or discuss all the technical aspects of such an innovation, but to show how it relates and how the creators see it relating to regulations.
Here's part of what I relayed to SJ: (John and Brandon, of course from Evolv)
John: ...So, were attacking the vapor integrity in the DNA40, and really were doing this much earlier because we were kind of pushed into it by the FDA. We need to come up with a regulatory framework where we can guarantee that we know whats in the vapor stream, or were never going to see an approvable product. But, we see theres a finite number of things to solve before the e-cigarette is as good or better than a tobacco cigarette.
Brandon: Lets talk a little bit about the open system too. One of the things that this does is it facilitates an open system. Johns belief, and I tend to stand behind it, is that, we can regulate these on a component by component basis saying, Okay, flavour in A, flavour in B, flavour in C, dont break down below this temperature. We need to remember that big tobacco are pushing for this to be regulated as a complete closed system. because if you have a closed system you can control everything and then you have to buy your cartridges from Vuse or whoever. So, if we have devices which can control accurately, then juice makers can have a list of ingredients they can use, and still be able to make their 250 juices from those ingredients.
Me:
... it might be interesting to have it posted in the 'Regulations' subforum, as well. I still have hope that something along the lines of Azim Chowdhury's 'baseline predicate product' as an alternative for a grandfathered product, could possibly interest the FDA (esp. if they lose another court case
where it is these type of 'improvements' that would fit into their public health orientation when vaping is looked at as either an inevitability or in the highly improbable result, that they actually consider it a true harm reducer. AND, it will show them that perhaps, unlike the tobacco companies (although I don't buy into that completely) that the vaping community actually 'thinks' more about these things than just getting our next nicotine hit. lol
I'm uncertain if this is worthy of discussion or just worth posting this part - as such innovations would seem to point to Azim's idea of the FDA establishing a baseline predicate product. Azim on that idea: "Rather than requiring that companies find a specific predicate product on their own, the FDA could establish threshold specifications (e.g., product standards) for a baseline e-cigarette against which companies could make the case that their products are substantially equivalent."
http://www.khlaw.com/webfiles/What_To_Expect.pdf
And from SJ's piece it seems there is more to come from Evolv and no doubt from other innovators as well, of course. It would be a shame to 'freeze' the industry at this point with the final rule on deeming and smokers, and ex-smokers and to an extent 'bystanders' will be the worse off because of it. Regulations, as Senator Burr said in the HELP committee hearing, shouldn't squash innovation.
Sen. Burr: If we kill technology and innovation, which is, in essence, what some are attempting to do at the beginning, its not going to play a role in reducing the amount of Americans who smoke, he said. I can remember when opportunities for harm reduction were the goal, but the technology wasnt there well now, the technology is there, and how quickly weve moved to the point where harm reduction is no longer a goal.
http://vaping.com/news/exclusive-in...rom-evolv?_ga=1.67047788.375002566.1413519349
Most here will know about the new dna 40 board that has 'temperature protection'. This isn't to promote it or discuss all the technical aspects of such an innovation, but to show how it relates and how the creators see it relating to regulations.
Here's part of what I relayed to SJ: (John and Brandon, of course from Evolv)
John: ...So, were attacking the vapor integrity in the DNA40, and really were doing this much earlier because we were kind of pushed into it by the FDA. We need to come up with a regulatory framework where we can guarantee that we know whats in the vapor stream, or were never going to see an approvable product. But, we see theres a finite number of things to solve before the e-cigarette is as good or better than a tobacco cigarette.
Brandon: Lets talk a little bit about the open system too. One of the things that this does is it facilitates an open system. Johns belief, and I tend to stand behind it, is that, we can regulate these on a component by component basis saying, Okay, flavour in A, flavour in B, flavour in C, dont break down below this temperature. We need to remember that big tobacco are pushing for this to be regulated as a complete closed system. because if you have a closed system you can control everything and then you have to buy your cartridges from Vuse or whoever. So, if we have devices which can control accurately, then juice makers can have a list of ingredients they can use, and still be able to make their 250 juices from those ingredients.
Me:
... it might be interesting to have it posted in the 'Regulations' subforum, as well. I still have hope that something along the lines of Azim Chowdhury's 'baseline predicate product' as an alternative for a grandfathered product, could possibly interest the FDA (esp. if they lose another court case
where it is these type of 'improvements' that would fit into their public health orientation when vaping is looked at as either an inevitability or in the highly improbable result, that they actually consider it a true harm reducer. AND, it will show them that perhaps, unlike the tobacco companies (although I don't buy into that completely) that the vaping community actually 'thinks' more about these things than just getting our next nicotine hit. lol I'm uncertain if this is worthy of discussion or just worth posting this part - as such innovations would seem to point to Azim's idea of the FDA establishing a baseline predicate product. Azim on that idea: "Rather than requiring that companies find a specific predicate product on their own, the FDA could establish threshold specifications (e.g., product standards) for a baseline e-cigarette against which companies could make the case that their products are substantially equivalent."
http://www.khlaw.com/webfiles/What_To_Expect.pdf
And from SJ's piece it seems there is more to come from Evolv and no doubt from other innovators as well, of course. It would be a shame to 'freeze' the industry at this point with the final rule on deeming and smokers, and ex-smokers and to an extent 'bystanders' will be the worse off because of it. Regulations, as Senator Burr said in the HELP committee hearing, shouldn't squash innovation.
Sen. Burr: If we kill technology and innovation, which is, in essence, what some are attempting to do at the beginning, its not going to play a role in reducing the amount of Americans who smoke, he said. I can remember when opportunities for harm reduction were the goal, but the technology wasnt there well now, the technology is there, and how quickly weve moved to the point where harm reduction is no longer a goal.
