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

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bigdancehawk

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When you run out of things to say, read the ANTZ comments and comment on them. I've written a couple of dozen of these. Here's one:


Another tobacco Control commentator spouting unsubstantiated claims. Not one single source or authority is cited.


He says: "The FDA should also regulate any other tobacco component devices and all nicotine products. The heated nicotine electronic e-cigarettes are now being widely promoted as allegedly emitting nothing but harmless water vapor. This is clearly false advertising and should be curtailed."


There’s little doubt that the FDA will regulate e-cigarettes. The question is how. Although a few random individuals have made the “water vapor” claim, I have never, EVER seen an e-cigarette advertisement claiming that they only emit "harmless water vapor." The guy simply made that up.


He says: "By having no guidelines from the FDA to limit them, nicotine addicted e-cigarette puffers are emitting their airborne chemical emissions wherever they please."


Everything is a "chemical." The question is not whether it's a chemical. It's whether it's harmful. There is no evidence showing that exhaled vapor contains significant levels of any harmful substances and substantial evidence that it does not. Addiction Journal - Press Releases BMC Public Health | Full text | Peering through the mist: systematic review of what the chemistry of contaminants in electronic cigarettes tells us about health risks


He says: "This chemical emission activity is invading our legally designated community Non-Smoking facilities. Without FDA guidelines to guide and back them, many facility managers feel helpless to prevent this."


That's absurd. "Facility managers" can prohibit whatever activity they wants to prohibit. They could prohibit the wearing of green socks.


He says: "False advertising about e-cigarettes is becoming a serious public health problem."


Where is the evidence for this hyperbole? There is none.


He says: "Despite all the claims by addictive tobacco smokers who say they have totally "quit smoking" by using e-cigarettes to achieve that distinction, I as a physician have not encountered any who make such claims who have convincingly actually 100% quit using addictive products permanently."


People who aren't smoking have quit smoking. E-cigarettes don't produce smoke. Therefore, their users are, by definition, not smoking.


He says: "Historically people were defined as true "Non-Smokers" permanently only when fully past the practice of using addictive nicotine products of any kind at any time. The definition of "former smoker" in the time period before e-cigarettes entered the market had a trustworthy meaning. This is no longer true. Many actual "former smokers" no longer using tobacco or any addictive nicotine product at all, tell me that until they truly quit smoking meaning no longer using any addictive nicotine products at any time, tell me that for them and smoking cohorts, it was e-cigarettes that actually kept them smoking, instead of quitting."


It is difficult to make sense of this garbled mess, and I pity the FDA person who is compelled to read it. It appears to be based on the "quit my way or die" mentality common among extreme Tobacco Control zealots. The notion that e-cigarettes "keep them smoking" is illogical, contrary to the life experiences of hundreds of thousands (if not millions) of real people, and unsupported by any study.


He says: "The e-cigarette ads with harmless reassurances allowed them to rationalize and keep postponing the need to ever quit smoking because of being told the cigarette ritual experience and smoking pleasure could still be enjoyed even in Non-Smoking areas where they could not legally smoke their regular cigarettes."


They're not smoking. They are dramatically reducing harm to themselves caused by smoking. They pose no threat to others. They should be applauded and encouraged by true public health advocates, not condemned. Why should they be subjected to the same bans as smokers? God forbid that anybody seen puffing on anything, however harmless to bystanders, should be allowed to enjoy it. No, instead make them as miserable as possible and kick them outside to huddle like lepers with the smokers!
 

5cardstud

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The article linked by 5cardstud is absolutely amazing for this cause. We need to bring as much attention to it as possible, IMO. I'll make it easy for you if you're feeling lazy.

Go here:

Regulations.gov

Copy and paste the contents of the article (below, with source link included) into the FDA comment and submit it. That's it. It'll take 30 seconds.

-----------------------------------------

In regards to the FDA's proposal to regulate electronic cigarettes - please read this.

Source: International review of e-cig studies shows low risk, huge potential benefits | American Council on Science and Health (ACSH)

A new study published this week in the journal Addiction,authored by five experts well-known for their expertise in tobacco issues, seems to confirm what most of us in science-based public health already knew: e-cigarettes are much less harmful than cigarettes; they have far fewer and lower levels of toxicants, for the user/vaper and for bystanders; there is no valid evidence that they attract youngsters to nicotine use; they can help addicted smokers quit; and the dangers of over-regulation include stifling the vast benefits they may confer on addicted smokers trying to quit.

<...>



(MOD NOTE: Please copy full article at link for your submission. Due to copyright laws, we cannot allow the full article to be printed here)

Done this one too. with tracking.
 

Megan Kogijiki Ratchford

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I am new to these forums, but I though this FDA regulation was only for warnings on the products and age restriction.

Welcome Rob!! :thumb:

No, it is very pervasive and as written it will destroy vaping as we know it. Instead of buying a yummy tasting juice in a 50ml bottle for $30 which is a lot of cigarettes in comparison, you will have to buy cigarette flavored pre-filled carto gear that is a lot more expensive. Everything is having to be qualified by the FDA meaning every flavor of juice in every grade of nicotine content, even zero :blink: will cost the venders $350,000 per individual item to be tested for qualification. Then after spending all that money there is a good possibility they won't pass anyway!

And that is not even getting to the argument that they should have no power to comment on the zero nicotine or the equipment used for vaping as neither of those have anything to do with tobacco so why are they now considered tobacco???

Not ranting because of you dear, just ranting in general...this whole thing makes me YELLY :facepalm:
 

dragonpuff

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I am new to these forums, but I though this FDA regulation was only for warnings on the products and age restriction.

Rob, the FDA's deeming regulations are far more complex than that. What they want to do, in essence, is require that all products go through an approval process before they can be marketed, which would effectively remove almost all electronic cigarette products from the market for an unknown length of time. There's more to it of course, but that is what's most concerning.

Here is a quick summary of some of the problems with the current deeming regulations:
http://tobaccoanalysis.blogspot.com/2013/01/top-5-reasons-why-fda-deeming.html

Also, poke around on the forum some more. There are a lot of people talking about this who have been dealing with it for months and are quite knowledgeable about what's going on. In particular check out this forum: FDA Regulations

Cheers and good luck! :D Welcome to ECF!
 

DJLEC

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This study is already being widely published :D check out the thread in the media section for links to more articles discussing it:
http://www.e-cigarette-forum.com/fo...er-good-source-published-today-addiction.html

This study was very well conducted :D if you have access to the full text of the study (you need a wiley account, or access through a university database), you can download a pdf and upload it to a comment for the FDA - this is a really good one to send to them! ;) Hint hint!

Thank you so much for this.

My wife submitted it today with Tracking 1jy-8dke-x150 and my comment previously was Tracking 1jy-8dfb-s730. Both Tracking Numbers were e-mailed to CASAA.
 
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