Sent this to FDA and tracking no. to CAASA:
I am a consumer of electronic cigarette products and in this comment I can speak only for myself, although I trust you have read many comments that are similar to mine.
I smoked over a pack per day of tobacco cigarettes for 42 years. It was a vicious and filthy habit, but, nevertheless, I became thoroughly addicted. During this time, I developed chronic bronchitis and suffered several bouts of pneumonia. I am convinced that if my smoking was not the primary cause of these afflictions, it was at the very least, a seriously aggravating factor.
I tried many methods of smoking cessation including “cold-turkey” abstinence, hypnosis, laser acupuncture therapy, Nicotine Replacement Therapy (nicotine gum) and pharmaceutical methods (Zyban®/Welbutrin®). None of these therapies were effective.
In late 2007, I tried the first generation of electronic cigarettes. These were the small models that resembled cigarettes. They proved to be somewhat effective as I was able to cut down my consumption of tobacco cigarettes considerably but not completely.
After years of this dual-use, I discovered a new generation of vaporizers with more powerful and longer-lasting replaceable
batteries and more effective
tanks and atomizers. It was only then that I was able to quit consumption of tobacco completely. These more advanced e-cigarettes also enabled me to cut my nicotine consumption in half.
A further benefit I have noticed is that I no longer suffer my annual severe bronchitis and my daily “smoker’s cough”. My improved respiratory function is such that I can now commute daily to work by bicycle.
I have observed with particular attention a negative media spin concerning the supposed risks involved in e-cigarette consumption. Many of these risks are speculative and cannot be considered proven at this time. I would urge you to consult the study published by the National Center for Biotechnology Information, U.S. National Library of Medicine entitled
Safety evaluation and risk assessment of electronic cigarettes as tobacco cigarette substitutes: a systematic review. This well-documented report exposes the misleading and disingenuous statements pronounced in many slanted articles and even in public hearings.
As for the deeming regulations themselves, a particular concern is the expensive approval process and the “substantial equivalency” clause. As proposed, e-cigarette manufacturers would be required to prove substantial equivalency to products on the market in 2007. The only products available at that time were the first generation products that were vastly inferior to what is currently available and were ineffective as a smoking cessation product.
In addition, the expense involved in submitting the improved products currently marketed and future innovative products would be impossible to assume by most vendors since they are largely small or medium-size businesses. This would effectively hand over the entire market to only those companies that could afford the expense (Big Tobacco companies).
If the FDA deeming regulations are adopted in their current form, I fear that many current users (including myself) would return to the infinitely more dangerous habit of tobacco smoking. In the interest of Public Health, please do not let this happen.