Thank you! I consider my fellow residents of North, Central and South America to all be Americans.
The final countdown to August 8th - your FDA comments NEEDED
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Thank you! I consider my fellow residents of North, Central and South America to all be Americans.
Anyone seen an estimate where we are at? site says 31,222 comments...but thats mixed with anti's and procigar folks.
It's hard to say, the FDA is taking their sweet time reading these and posting them to the public docket. People are saying anywhere from 3 days to two weeks from the time they comment to the time they can find their comment by searching
so many more of us have posted just in the last couple weeks that an exact count is impossible right now. I don't think we'll know the true number until at least a month after the comment window closes.Also, keep in mind that a lot of people are submitting attachments with very few words in the text box, and those attachments are not searchable. So whatever the final searchable count ends up being, we can estimate another couple hundred comments at least.
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I'm still busily commenting on comments. I've even corrected a few pro-vaping comments, stating that, unlike Tobacco Control, most vapers have an ethical affinity for the truth.
I'm focusing mainly on the hysteria surrounding the chilllldreeen, as that seems to be the predominant ANTZ talking point. For example:
I am just an ordinary user of a personal vaporizer, a former pack a day cigarette smoker with no connection to any of the so-called "stakeholders." Cig-a-likes did not work for me. NRT (gum, patches) did not work for me, nor did hypnotism, cold turkey, Wellbutrin, inspirational books, prayer, and seeing my father die prematurely of lung cancer. The currently proposed regulations will kill off the innovative companies that devised and sell the products that worked for me, are working for millions of others, and will work for many more millions and significantly prolong their lives if you will just please, I beg you, give them a chance. Tread cautiously. The precautionary principle works both ways.
It is inappropriate to require that every product submission be supported by elaborate and expensive scientific studies. YOU HAVE NOT ESTABLISHED STANDARDS for these products. A company submitting a product for approval would be navigating through a dark maze without so much as a flashlight to guide them. Obviously, at some point you will have to set standards. Otherwise, how will you determine what products to approve? So why not do that first? Why not confer with industry representatives (not just the cig-a-like purveyors) and with objective scientists to help you draw up a list of acceptable ingredients with purity standards for each. For example, USP pharmaceutical grade propylene glycol, USP food grade vegetable glycerin, pure water, pharmaceutical grade nicotine with purity standards similar to those already approved by the FDA for inhalers, gum, etc.
That brings us to flavors. That's not insurmountably complicated either. You already approve flavorings for food products. (Notably, you don't pre-approve each food product incorporating these flavorings, so why would you need to separately approve each e-liquid?) You already approve flavors for gum and at least two for nicotine inhalers. There has already been at least one series of scientific tests done focusing on flavors. Here: http://gfn.net.co/downloads/2014/posters/122 Farsalinos - DA_AP.pdf Knowledgeable commentary about it and follow up clarification are here, beginning with post #120: http://www.e-cigarette-forum.com/fo.../517858-donate-dr-farsalinos-new-study-3.html
The Cliff's Notes version is that two potentially harmful substances were detected in some e-cigarette vapor, diacetyl and acetyl propionyl. The source was certain flavorings that contained these substances, notably some of the buttery flavors. The scientists who performed the study have stated that it would be a relatively simple matter to produce similar flavors which do not contain these substances. A number of liquid purveyors already routinely test for these substances. For example: Premium USA Made E-Liquid & E-juice, Manufactured in Tennessee at Mountain Oak Vapors A U.S. industry group has already set standards for safety, ingredients, preparation, labeling and packaging. STANDARDS | AEMSA
t serves no purpose to establish standards for any hardware that is not pre-filled. These are just simple devices for heating the liquid. Like a teapot. If they heat the liquid too much they will produce a nasty vapor that nobody will willingly inhale--much like lighting a cigarette filter. Consumers will avoid doing that, just like they avoid eating burned food. It's self-regulating.
The comment I am responding to is yet another cut and paste job from Tobacco Control ("TC"). Unable to cite any convincing evidence to show that e-cigarettes are significantly harmful to (or have ever harmed) any users or bystanders, they resort to the shop worn mantra, "But think of the chillldreen!"
In support of this "concern," these commentators all invariably echo the claim, "E-cigarettes are also being sold in a wide-variety of kid-friendly flavors, including bubble gum, cotton candy and gummy bear. It’s not surprising that the percentage of middle and high school students who reported ever using e-cigarettes doubled from 2011 to 2012, according to the CDC."
These are the same three flavors we've heard about over and over. I imagine you're sick of hearing about them. I know I am. So, just to shut up TC, why not just ban all three and left the rest alone? Of course, there is no actual evidence that kids are attracted to e-cigarettes by these flavors or are "vaping" them, but TC can't allow either contrary evidence or the absence of supporting evidence to get in their way when they're on a holy mission, now can they?
Finally, these references to the CDC study are simply lies. Yes, it would be more polite and diplomatic to call them "distortions," or inaccuracies" or "misinterpretations," but it would not be accurate to do so. It is fear mongering at its worst. This particular lie doesn't come from any study or report; rather, it comes from a press release about a study. The press release is propaganda and lies about the results of the study, as will become abundantly clear if you will simply read this: CDC lies about kids using e-cigarettes | Anti-THR Lies and related topics
God help us if the FDA is going to issue regulations based on TC's spin on a false press release.
I'm focusing mainly on the hysteria surrounding the chilllldreeen, as that seems to be the predominant ANTZ talking point. For example:
I am just an ordinary user of a personal vaporizer, a former pack a day cigarette smoker with no connection to any of the so-called "stakeholders." Cig-a-likes did not work for me. NRT (gum, patches) did not work for me, nor did hypnotism, cold turkey, Wellbutrin, inspirational books, prayer, and seeing my father die prematurely of lung cancer. The currently proposed regulations will kill off the innovative companies that devised and sell the products that worked for me, are working for millions of others, and will work for many more millions and significantly prolong their lives if you will just please, I beg you, give them a chance. Tread cautiously. The precautionary principle works both ways.
It is inappropriate to require that every product submission be supported by elaborate and expensive scientific studies. YOU HAVE NOT ESTABLISHED STANDARDS for these products. A company submitting a product for approval would be navigating through a dark maze without so much as a flashlight to guide them. Obviously, at some point you will have to set standards. Otherwise, how will you determine what products to approve? So why not do that first? Why not confer with industry representatives (not just the cig-a-like purveyors) and with objective scientists to help you draw up a list of acceptable ingredients with purity standards for each. For example, USP pharmaceutical grade propylene glycol, USP food grade vegetable glycerin, pure water, pharmaceutical grade nicotine with purity standards similar to those already approved by the FDA for inhalers, gum, etc.
That brings us to flavors. That's not insurmountably complicated either. You already approve flavorings for food products. (Notably, you don't pre-approve each food product incorporating these flavorings, so why would you need to separately approve each e-liquid?) You already approve flavors for gum and at least two for nicotine inhalers. There has already been at least one series of scientific tests done focusing on flavors. Here: http://gfn.net.co/downloads/2014/posters/122 Farsalinos - DA_AP.pdf Knowledgeable commentary about it and follow up clarification are here, beginning with post #120: http://www.e-cigarette-forum.com/fo.../517858-donate-dr-farsalinos-new-study-3.html
The Cliff's Notes version is that two potentially harmful substances were detected in some e-cigarette vapor, diacetyl and acetyl propionyl. The source was certain flavorings that contained these substances, notably some of the buttery flavors. The scientists who performed the study have stated that it would be a relatively simple matter to produce similar flavors which do not contain these substances. A number of liquid purveyors already routinely test for these substances. For example: Premium USA Made E-Liquid & E-juice, Manufactured in Tennessee at Mountain Oak Vapors A U.S. industry group has already set standards for safety, ingredients, preparation, labeling and packaging. STANDARDS | AEMSA
t serves no purpose to establish standards for any hardware that is not pre-filled. These are just simple devices for heating the liquid. Like a teapot. If they heat the liquid too much they will produce a nasty vapor that nobody will willingly inhale--much like lighting a cigarette filter. Consumers will avoid doing that, just like they avoid eating burned food. It's self-regulating.
The comment I am responding to is yet another cut and paste job from Tobacco Control ("TC"). Unable to cite any convincing evidence to show that e-cigarettes are significantly harmful to (or have ever harmed) any users or bystanders, they resort to the shop worn mantra, "But think of the chillldreen!"
In support of this "concern," these commentators all invariably echo the claim, "E-cigarettes are also being sold in a wide-variety of kid-friendly flavors, including bubble gum, cotton candy and gummy bear. It’s not surprising that the percentage of middle and high school students who reported ever using e-cigarettes doubled from 2011 to 2012, according to the CDC."
These are the same three flavors we've heard about over and over. I imagine you're sick of hearing about them. I know I am. So, just to shut up TC, why not just ban all three and left the rest alone? Of course, there is no actual evidence that kids are attracted to e-cigarettes by these flavors or are "vaping" them, but TC can't allow either contrary evidence or the absence of supporting evidence to get in their way when they're on a holy mission, now can they?
Finally, these references to the CDC study are simply lies. Yes, it would be more polite and diplomatic to call them "distortions," or inaccuracies" or "misinterpretations," but it would not be accurate to do so. It is fear mongering at its worst. This particular lie doesn't come from any study or report; rather, it comes from a press release about a study. The press release is propaganda and lies about the results of the study, as will become abundantly clear if you will simply read this: CDC lies about kids using e-cigarettes | Anti-THR Lies and related topics
God help us if the FDA is going to issue regulations based on TC's spin on a false press release.
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I am hoping that being at my 5 year quit date and vaping 0 nic holds some weight. I am feeling no ill effects from vaping so far. They release meds with less testing then I have done! 
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bigdancehawk that ROCKS!!!! Thank you, that is a beautiful statement and well referenced. *applauds*
You guys, your comments from all ranges from just quit cigarettes to 5 years smober ALL have weight. All of you are the BEST!!! THANK YOU!!! 
That's what's missing from my comments! They need more cowbell.
Yes! Even if you don't think it'll make much of a difference, comment anyway!
Well done and thank you
I've been fantasizing about a DC mall take over where we all tell our stories 24/7 through a microphone....a real loud microphone...
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