The final countdown to August 8th - your FDA comments NEEDED

[Racehorse]

Okay, I think I found the correct page of comments. 53K. Gosh that's some active cigar network.

Those cigar forums are very vocal, very united by their lobby groups...a lot of people don't realize that since we tend to think of cigs are more popular. Cigar people love their cigars like wine people love their wine.

 

[MichelleOhio]

Submitted.

 

[Lessifer]

Finally got around to submitting my comments today. After browsing through the other comments, I really hope they heed their own recommendations on posting an effective comment. If 100 well thought out pro-vaping comments can drown out a few thousand anti-vaping form letter babbling, I'd be very pleased.

 

[Mortizma]

Submitted mine, & sent my comment number to CASSAA~

 

[cooladdict]

KK I am heading over there know to leave my 2 cents!

 

[MichelleOhio]

I missed the part about sending in our number…?

 

[Ryedan]

I missed the part about sending in our number…?

Email just your comment number to:

casaa.fdacommentarchive@gmail.com

 

[sonicdsl]

Bringing to the front (again!)...

Dear ECF members and visitors,

On August 8th the FDA will close the comments on its proposed deeming regulation.

This regulation will profoundly affect the future of the industry, and as it currently stands, this means 99% of available products are likely to be removed from the market.

So far, not nearly enough vapers have submitted their testimonies to the FDA, and it is essential that all who wish to see vaping remain a viable alternative for smokers.

That means you.

It needn't take long to comment, and I've put a guide on vaping.com, based on CASAA's latest call to action.

Please spend a few minutes composing your own comment. And remember, this really is your final opportunity to have your voice heard before the rule is made. Your comment is important as, by law, it has to be considered as part of the rule-making process.

Many thanks,

Oliver (SJ)

 

[pwheeler]

All done, sent

 

[zoiDman]

Please DON'T wait until the Last Minute.

Send in your Comments as soon as you can.

And ask your Friends, Family and Co-Workers to do the Same.

 

[dragonpuff]

Please wait until the Last Minute.

Send in your Comments as soon as you can.

And ask your Friends, Family and Co-Workers to do the Same.

Ahem, allow me, good sir, to make one small correction...

Please DON'T wait until the last minute!

 

[Megan Kogijiki Ratchford]

Ahem, allow me, good sir, to make one small correction...

Please DON'T wait until the last minute!

Wondered about that...



One of my students is a surgery RN and I asked if she and any other medical professionals at the hospital she works at would want to comment to support vaping. This was our conversation:

Me "Hey, would you support vaping with the FDA? As a medical professional your comment really carries weight..."
R: "Why? Is the FDA saying it's bad, or is this coming from somewhere else?"
Me: Explanes the whole mess in detail to her.
R: "WTH??? WHY would anyone think vaping is bad? It's one of the best things to come along to get people off cigarettes! All of us at the hospital often tell people who can't quit to vape!! This is incredible and horrible, how could they do this with any sense of moral obligation to the health of the country...*much more grumbling and expletives*"
Me: "So, do you think you can get people at your work to write something to support vaping?"
R: "Oh heck yes!!! What do I do, where do I do it, give me the information..."

Forwarded her the CASAA CTA last night and I'm hoping she will indeed get some backing for us.

 

[chipd]

Done!!!!!!

 

[Ceridianblu]

I chimed in with my two cents...hopefully everyone in the community will submit feedback on this before the deadline passes...there's power in numbers! I hope we crash the server...

 

[zoiDman]

Ahem, allow me, good sir, to make one small correction...

Please DON'T wait until the last minute!

Thanks Dragon.

Amazing how One Missing Word kinda Wacked that Entire Post.

 

[zoiDman]

Wondered about that...



One of my students is a surgery RN and I asked if she and any other medical professionals at the hospital she works at would want to comment to support vaping. This was our conversation:

Me "Hey, would you support vaping with the FDA? As a medical professional your comment really carries weight..."
R: "Why? Is the FDA saying it's bad, or is this coming from somewhere else?"
Me: Explanes the whole mess in detail to her.
R: "WTH??? WHY would anyone think vaping is bad? It's one of the best things to come along to get people off cigarettes! All of us at the hospital often tell people who can't quit to vape!! This is incredible and horrible, how could they do this with any sense of moral obligation to the health of the country...*much more grumbling and expletives*"
Me: "So, do you think you can get people at your work to write something to support vaping?"
R: "Oh heck yes!!! What do I do, where do I do it, give me the information..."

Forwarded her the CASAA CTA last night and I'm hoping she will indeed get some backing for us.

Think if we could get 100 people like this to make a Comment.

Or 1,000?

People need to Reach Out.

 

[5cardstud]

Come on people. This is for real so get off your backsides and let's get this done. It's easy but so very important.

 

[dragonpuff]

Bump! The comment window is still open don't forget you can submit multiple comments, and you can attach pdf's of studies for them to read!

 

[Squigly]

im highly skeptical that an unaccountable government agency has anyone's interest but their own in mind

I'm still confused as to HOW the government got this much power in the first place!

 

[E squire]

I wanted to share the comment I submitted and see what those of you who are more well-read on the subject think (yes, I'm an attorney, but no, I don't have any expertise in challenging regulatory agencies, and no, I have not read every bit of the regulations, or even most of them).

I edited it a bit to make it easier to read (I was a bit more verbose in my submission ) :

Although I am a PV user, I am also an attorney, and I find the proposed deeming provisions problematic, particularly in how the FDA proposes to consider PVs as falling within its definition of "tobacco products" and how it plans to draw distinctions between "accessories" and "components."

First, many PV users do not use any product made or derived from tobacco. Some choose to vaporize e-liquid containing no nicotine whatsoever. This means that not only would the e-liquid they vaporize not be considered a "tobacco product" as defined under Section 201(rr) of the FD Act (21 U.S.C. 321(rr)), but neither would the components or parts intended for use in the consumption of zero-nicotine liquids. Furthermore, it would appear that the proposed regulations would not cover liquids containing synthetic nicotine, as synthetic nicotine is not derived from tobacco. The components or parts intended for use in the consumption of synthetic-nicotine liquids would not be covered by the proposed regulations, either.

Second, assuming for the sake of argument that all e-liquid (including no-nicotine or synthetic-nicotine e-liquid) may be considered a "tobacco product," it will prove difficult--if not impossible--to draw distinctions between unregulated "accessories" and regulated "components" and "parts." For example, the regulations refer to lighters as "accessories." However, lighters are intended for consumer use in the consumption of tobacco products (namely, for lighting cigarettes). By analogy, the batteries and heating elements of PVs, while intended for consumer use in the consumption of e-liquid, should also be treated as "accessories." This problem becomes even more complex when considering to variety of materials that are "included as part of a finished" PV: Which batteries will be considered "intended for consumer use in the consumption of tobacco products"? Which wires? Which switches? Which tubes? Which cotton? Which screws? Does it depend on the manufacturer? The marketing? The actual use by consumers? It should be noted that some of the first advanced PVs were simply modified flashlights, and that today's advanced PVs vary mainly in their form rather than function.

I do feel that regulation of PVs and e-liquid is important and that further studies should be done to determine how vaporizing can be made as safe and as enjoyable as possible. However, it is inappropriate and simply untenable to do so under "tobacco product" regulations. To try to fit PVs into the same category as cigarettes is forcing a square peg into a round hole and will lead to confusion, inconsistency, and (as I suspect many others have noted in their comments) the crippling of a quickly-growing, innovative industry made up of small businesses. The FDA should reconsider regulating PVs and e-liquid under the proposed rule and wait to regulate this area until our elected representatives in Congress have expressly granted the FDA the authority to do so by legislative enactment.

These proposed rules are just a mess. Cheers to fighting the good fight .