ewwww. This sounds like a brush-off. There is no way the FDA could sort through that many comments and give them any weight.
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FDA So where is the outcry from the vendors?
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ewwww. This sounds like a brush-off. There is no way the FDA could sort through that many comments and give them any weight.
In the deeming document:
XIII. Request for Comments
A. General Information About Submitting Comments
Interested persons may submit either electronic comments regarding this document to Regulations.gov or written comments to the Division of Dockets Management (seeADDRESSES). It is only necessary to send one set of comments. Identify comments with the docket number found in brackets in the heading of this document.
.... this looks like a 'suggestion', probably so as not to get overwhelmed, but the 'it is only necessary to send one' doesn't mean one couldn't send more. This is likely the source of the 'you can only send one' - ie. a misreading of the text.
They have exactly one member: Active Members List | Vista Truth Inc.
None of their board members have C.V.s or anything remotely resembling same.
Their "lobbyist map" is empty.
Your probably right about misreading the text. I just know that it isn't humanly possible to sort through all the comments that they will get. So then what?
I suspect there's a different path for comments to be taken more seriously.
I suspect there's a different path for comments to be taken more seriously.
Well, here's their official policy on that. Probably took them more time to compose it than they'd spend reading comments. No sign of what the actual procedure is in reading comments, how many involved, etc. All comments are posted though.
http://www.regulations.gov/docs/FactSheet_Public_Comments_Make_a_Difference.pdf
I was thinking of writing a Wikipedia type note in the future, with 'citations needed' and all
- say 50 years, where ecigs are legal and the deaths from smoking have been reduced to nil and percentage of smokers are at, say, 1.5%. And note that there was a period around 2014 where the FDA (naming names) and the Congress (naming names) imposed severe restrictions on ecigarettes and an estimate of how many millions of people died as a result of not having a safer alternative to smoking at that time. That there was a 'Hall of Shame' created naming names on the Federal, State and Local levels of government officials and employees who were instrumental in getting those insane regulations passed into laws, where a person could see exactly who these tyrants and idiots were, etc. etc. That the FDA was abolished in the aftermath, and that people began taking more responsibility for their own health and have done quite well. More 'refined' of course 
Why would it not be possible to sort thru all the comments? They can take as long as they please. Do keyword searches to target in on 'comments of value.' IOW, separate rants from comments that actually address questions asked in the proposal. Or ones that actually mention science. Sort further to those that actually cite science.
You can go read some of the comments that have been submitted so far to see how, rather easy, the comments could be sorted.
Plus, the review process (or sorting) has likely already begun. Site says 3400 or so comments submitted so far. I'm guessing most, if not all, of those have been sorted. And I believe all of them will be reviewed. A comment like, "stay out of my business" will likely be read and dismissed as not seriously addressing the proposal.
The kind of comments us politically (and scientifically) aware vapers will produce, likely will have them sit up and take notice. I (like to) imagine ANTZ will have its share of comments that are sorted to the 'easy to dismiss' pile.
That's not true, unfortunately.
Last time we commented they received 5,364 comments, and only 99 are posted...
Regulations.gov
well, again, so they say.....
I think I'll just send them this video and let them fill in the blanks.....
My experience has been with health regulations. There have been time when there's been lots of comments about a proposed change and a handful of inside organizations got priority. The rest were ignored and never addressed. Those organizations were "invited" to comment. Honestly, I don't know how to get around that. It doesn't always happen either. It's frustrating when it does. I'm typing out loud here. I just suspect a red flag when they don't seem to care how many comments they get.
Hi all,
Not sure if I can make an "official" post here about VISTA, but I will for now. I'm sure the mods will correct me if I'm mistaken.
As one of the members of the board for the Vaping Industry Strategic Truth Alliance is a very young organization. We just recently formed, and like many, had not anticipated the timing of the FDA deeming regs. While the timing is less than ideal, the intent and mission could not come at a more critical time.
Our primary goal right now is to secure and maintain a lobbyist for every state, funded by retailers, wholesalers, and/or online distributors. Some may suggest that lobbyists are "part of the problem," but there is also a great benefit to having one on our side. Lobbyists already have the connections to state, local, and federal legislators that the average vendor or vaper simply does not have. Through these connections, we are looking to gain influence and advanced notice to new regulations as well as adding our voice wherever detrimental actions are being proposed. Being in Minnesota, I have seen first-hand the difference a lobbyist can make in our efforts to fight bans and unjust restrictions.
While we are in the very early stages, the results of VISTA's work in Florida have already made a difference. We were able to get the proposed legislation altered in the favor of vapers. FL legislators attempted to pass a provision that would have effectively outlawed online sales. Because of the lobbyist we secured, we had the clout with the right people to get the bill amended.
In this early stage, we are looking for members across the US (or internationally) who are interested in joining our cause. At this critical juncture, any ally we can win over quickly is of the utmost importance, whether it be at the local, state, or federal levels. A lobbyist is one of the simplest ways to make that happen, as they already have many of these connections established.
Should you know a vendor that may be interested, please direct them to us. They can visit the site or contact a member of the board directly. If you're a vendor and want to know more, the same goes for you!
If by some chance, it's still not clear, take a look at our published mission statement:
Vaping Industry Strategic Truth Alliance (VISTA Truth, Inc.) is a nationwide non-profit corporation formed in April 2014 that supports and advocates, on a state by state level, for the rights of retailers and wholesalers (both online and traditional) in the United States who offer less harmful alternative nicotine delivery devices to adult consumers instead of proven lethal tobacco products. Our goal is to have a professional lobbying firm in every state capitol by May 2015; we will accomplish this by an alliance of vendor members.
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Would major state tax increases affect the price of liquid online? That's my main concern as a consumer. I also wonder if there will be federal taxes that would increase the price of liquid online.
If online purchases require signed receipts, add on the cost of Fed-Ex or UPS shipping. Taxes if the liquid is deemed a tobacco product could be extreme, If they look at a cigarette and decide it contains 1 mg of nicotine, and tax our liquids at the same rate, 2 mL or 10 mg/mL liquid would be taxed at the same rate as a pack of cigs, a 20 ml bottle would be a carton...(not saying this makes sense, it's government sense not common sense...
)
I do not have an issue w/ lobbyists, I think they're a good thing.
All of our opponents like the ALA, CFTFK, and the like have them (or the equivalent). Government officials such as health dep't personell are acting for all intents and purposes as lobbyists - and probably illegally, I might add. For ex., when a state health dep't official appears to testify in front of a city council that's considering an ordinance, that counts as lobbying to me.
Even worse, we know that lobbyists for BT and Big Vapor are operating behind the scenes (as in CA, apparently), and they are most certainly not nec'ly always doing so in the interest of the average vaper.
The fight in MN is not over yet, but I believe Cap O'Rourke was very effective.
We need all the help we can get.
Bring on the lobbyists!!
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I keep falling behind. Just finished reading through the rest of the thread that I missed while I was away from the computer again. You guys are awesome. Just wanted to pop back in and post Clark's/nicoticket's reply. Seems that the one comment thing is likely a myth. :
{MODERATED}
I can't find any information concerning a post limit anywhere either. I have been waiting for CASAA, and hadn't looked around, but now I'm thinking that the comment limit thing may indeed be a myth...
{MODERATED}
I can't find any information concerning a post limit anywhere either. I have been waiting for CASAA, and hadn't looked around, but now I'm thinking that the comment limit thing may indeed be a myth...
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With sealed carts being the only option for obtaining eliquid with the vast majority being sold at gas stations and Wally world, I don't think you will have that concern in a couple of years or less.
Unless Pat from the FDA was lying to me, it is a myth. As far as the bold... I'm pretty sure I found that and you're right - well meaning but misunderstood. There is a comment on a link in the post to one of the FDA docs that says this:
"A single, well-supported comment may carry more weight than a thousand form letters."
While likely true, it doesn't limit comments to one, and suggests that 'a thousand form letters' could be submitted.
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i would like to mention that the vendors are in a delicate political situation.
using there store fronts and websites to actively and aggressively urge their customers to oppose
the proposed FDA regulations might be interpreted as being against the chillin'.
thus this would support the ANTZ propaganda that the flavors,devices,et-al
are to get the chillin' hooked and on the road to combustible tobacco.
the media and the ANTZ would have a field day with that.
just saying.
regards
mike
using there store fronts and websites to actively and aggressively urge their customers to oppose
the proposed FDA regulations might be interpreted as being against the chillin'.
thus this would support the ANTZ propaganda that the flavors,devices,et-al
are to get the chillin' hooked and on the road to combustible tobacco.
the media and the ANTZ would have a field day with that.
just saying.
regards
mike
Nonsense. Children have nothing to do with their willful ignorance. If anything, most of the retail locations are just fearful of mentioning that their products are under FDA scrutiny which doesn't help sales. That and I suspect the staff on duty at any given time is just clueless about all of this and aren't equipped to handle questions so they simply don't bring it up. I can understand this behavior at their retail locations but not providing a few helpful web links for all the traffic that hits their site is just inexcusable. (Some do now and it's getting better).
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