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

[ddzc]

Just in time, submitted a nice comment and copied CASAA! I hope all goes well and vaping continues strong!

 

[Megan Kogijiki Ratchford]

I'm ranty this morning so fired this off just now...20 comments and going!!

I am a stakeholder in the e-cig industry as it has taken a 30 year pack a day smoking habit and with absolute ease turned that to zero. I am now not a smoker. I vape because it helps me mimic a physical addiction with very little nicotine or the other numerous horrible chemicals found in cigarettes. It is the ONLY thing I've tried when quitting cigarettes that has worked. The gum, the patch, the lozenges, hypnosis, three prescription drugs and even all combined in various levels never got me to quit. In fact as I used all those things I STILL smoked! The fact that the FDA cannot and does not support this revolution is beyond reprehensible. If the e-cig industry was allowed to continue on it's path cigarettes would be a memory and future generations would shudder with horror that anyone would have allowed cigarettes to continue while effectively ending the vaping revolution. This is in fact what this deeming is going to do to a very organized and prosperous industry whose primary goal is to get cigarette smokers to quit smoking cigarettes through using the effective tool of e-cigs.

There is a concern among those who speak against vaping that vaping is a gateway to smoking cigarettes. This is absolutely ridiculous. No one, NO ONE who has smelled a cigarette would choose a cigarette over fresh air. If people are concerned about the safety of their children I propose that they discuss addiction and the harm it causes on all fronts, not just cigarettes or vaping. Even if parents do their jobs right and keep this conversation going with their kids it is inevitable that they will rebel and do dangerous things like driving drunk and trying drugs and drinking alcohol at a young age. For most children it is far easier to drink alcohol than smoke or even vape. Will we then ban alcohol? I seem to remember that prohibition did wonders for the organized crime syndicates. Perhaps we should ban everything even remotely unhealthy to children which would include, but not limited to: video games, fast food, candy, soda pop, energy drinks, amusement parks, riding in any car ever, airplanes, sweet pastries of any kind, movies, TV, fire works, living in a city et.al. The up side is if we ban everything we can be certain that those things will be provided by the criminals that profit from any restriction to anything. A good point to this is at least those children will have jobs providing those banned items through a criminal enterprise of some sort or another.

Vaping has extensive scientific studies that show it is a harm reduction devise and none showing that it is the monster in the closet waiting to eat our children. Instead of running around like Chicken Little crying over the dangers of vaping maybe those folks would like to explain why children have to bury their parents who die too early due to smoking or how the childrens' own health is negatively affected from second hand smoke. Time for a reality check folks. If the FDA is indeed committed to harm reduction from cigarettes WHY hasn't the FDA embraced vaping? This is the single most effective way to eliminate cigarettes from our lives and from the market forever, and not by banning them but by making them simply irrelevant. As the current proposal is written with the list of actions I can only assume the FDA is in favor of continuing our addiction to cigarettes rather than helping us save ours and many millions of people's lives through vaping!

 

[DaveOno]

Done, but I have a feeling there's a ton of people who are being lazy and couldn't be bothered

I was one of the lazy.

But I got off of my duff and got it done. It really took all of 10 minutes.

If the worst case draconian measures became law, I'd never forgive myself for not doing something about it when I had the opportunity.

 

[10x sugar]

I'm ranty this morning so fired this off just now...20 comments and going!!

Wow! Nicely put Megan!
You took the words right out of my head! Thank you.

 

[niterider]

Comment submitted, but why do we need to send our comment number to CASAA?

 

[Megan Kogijiki Ratchford]

Comment submitted, but why do we need to send our comment number to CASAA?

Because it's their way to track numbers I guess? Thank you for doing this nite!!

And thank you sugar!!

 

[Robino1]

The clock is ticking on YOUR chance to have YOUR voice heard. By law, the FDA has to read EVERY comment submission. It is YOUR chance to have YOUR story read.

Please do YOUR part in making OUR voice heard....loud and proud!

 

[dragonpuff]

Still waiting for my package and the mailperson is running late today...

Please submit your comments so we can all look forward to our packages for many years to come!!!




Edit: Mailperson finally got here half an hour late, with no package perhaps afternoon delivery? One can dream...

 

[Robino1]

Comment submitted, but why do we need to send our comment number to CASAA?

Possibly to keep the FDA under scrutiny. If our comments do not get put up, they can have accountability toward the FDA? Just guessing here.

That's what I would do

 

[DPLongo22]

{sent to CASAA}

"Your Comment Tracking Number: 1jy-8dnp-l7n8"

Comment:
That this is even a conversation is absurd, and shows the ineptitude that permeates our elected officials.

1. People are quitting smoking.
2. Scientific evidence keeps mounting, by landslide proportions, that vaping is immeasurably better for us than smoking.
3. Doctors from all over the world continue to weigh in, heavily supporting society's transition from smoking to vaping.

If you numb-skulls eventually decide to make it more difficult to switch, it will be completely obvious that is was done to support your contributing lobbyists, and nothing more.

Seriously people. This might be the easiest issue you've ever had to dismiss. Common sense, anyone?

Sincerely,
David Longo
Stamford, CT

 

[Robino1]

{sent to CASAA}

"Your Comment Tracking Number: 1jy-8dnp-l7n8"

Comment:
That this is even a conversation is absurd, and shows the ineptitude that permeates our elected officials.

1. People are quitting smoking.
2. Scientific evidence keeps mounting, by landslide proportions, that vaping is immeasurably better for us than smoking.
3. Doctors from all over the world continue to weigh in, heavily supporting society's transition from smoking to vaping.

If you numb-skulls eventually decide to make it more difficult to switch, it will be completely obvious that is was done to support your contributing lobbyists, and nothing more.

Seriously people. This might be the easiest issue you've ever had to dismiss. Common sense, anyone?

Sincerely,
David Longo
Stamford, CT

Love it!!!

*sitting here with a huge grin*

Simple and to the point. All true also!

 

[midficollege]

Another day late to work. The reason:

Since my previous comment (1jy-8dme-a7jg), I have become a member of the Consumer Advocates for Smoke-free Alternatives Association (CASAA).

In my last comment, I talked about specifically the result that the proposed regulations will have on me. Now, let's talk about each part of an electronic cigarette in depth.

The first part is obviously the battery tube. This is just what it sounds like, a tube that holds a battery and either simply acts to send current from a battery to to a resistor of some form. In some cases, in setups referred to as hybrids, there is no proprietary connector, but rather threading along the exterior of the battery tube itself to connect it to its resistor of choice. This tube simply acts as a means for transferring power, either raw or transformed, from the battery to said resistor.

That the resistor in question may happen to be an atomizer for an electronic cigarette should in no way be seen as grounds to restrict them.

Now let's talk about the atomizer, which purely acts as a heating element to vaporize vegetable glycerine or propylene glycol, similar to that in a commercial fog machine.

Now, we come to the meat of the issue- eliquid. Eliquid is made of water, propylene glycol and/or vegetable glycerine (glycerol) into which is dissolved laboratory-grade nicotine and flavor concentrates. The flavor concentrates are sourced from candy-making businesses along the lines of The Perfumer's Apprentice: https://shop.perfumersapprentice.com/c-209-new-flavors.aspx . Propylene Glycol and Vegetable Glycerine have many other uses, such as vegetable glycerol's use as a skin ointment or internal application as a laxative. Many vapers (of whom I am sadly not yet one) use eliquid containing no nicotine whatsoever.

Flavors are likely the place where many trace impurities come into the picture, but at the same time they are the very driving force behind the industry. Not because they, as some imply, target children. Believe me, nobody in the Western-Hemisphere electronic cigarette industry wants to get young children addicted to something that has adversely affected their lives for so long. Instead, it drives the industry purely based on the tastes of adult consumers varying so widely. Fortunately, like I stated in my previous comment, e-liquid vendors have been proactive about ceasing the use of any flavor additives that might prove harmful, including diacetyl and acetyl propionyl. Unfortunately, with the 5000 man-hours required to get any flavor approved by the FDA, any such self-regulation will cease, as nobody will be producing flavors expressly for use in electronic cigarettes. The barrier to entry will be insurmountable even for medium-sized businesses.

So now we come to the question on everyone's mind, regulating the nicotine itself. Nicotine is a very addictive substance, as well you know, and many people in the process of quitting need some source of nicotine for the sake of bringing their quit into fruition. For some, this may involve nicotine gum or patches, and for others it may involve actual tobacco products such as Snus, which include all of the same non-nicotine chemicals as found in other combusted tobacco products. For many others, such as myself, electronic cigarettes are the answer, providing a means for satisfying both the physiological demand for nicotine but also any of the various mental cues along the lines of "First cup of coffee in the morning, time for my smoke break".

If nicotine itself (the basis for the FDA's interest in electronic cigarettes as a "tobacco product") were heavily restricted, the result would be many former smokers either continuing to smoke or using other means, such as smokeless tobacco products, to satisfy their nicotine demands, possibly while using 0mg/mL e-liquid to satisfy his or her psychological cravings and enjoy the flavor of the vapor, which would be the worst of both worlds.

Harm reduction is the name of the game, and, while not perfectly safe, they are far ahead of combustible tobacco in terms of their safety and freedom from contamination. Only one study, featuring an extremely early sample of eliquid, detected ethylene glycol as a contaminant. Only one study, conducted by a less-than-impartial source while using experimental procedures far different than those that would be used by an actual consumer, has shown formaldehyde approaching the levels found in cigarette smoke. Even then, other contaminants were found in much lower concentrations than found in actual tobacco products. Even if formaldehyde was the same concentration, that says nothing about the huge impact of other carcinogens found in cigarettes, as well as the effects of tar buildup and carbon monoxide from the combustion process itself.

Please do not take steps to drive people back to the product driving the tobacco public health crisis. It's far more harmful to both them and people within the same environments as them.

Thank you again.

Burstyn Study Attached.
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ms08.pdf: success

I'm actually fairly proud of myself for not getting over-defensive about "If that's your concern, why can I buy 'For Tobacco Use Only' products at my local gas station?", since that would only be inflammatory and not helpful.

 

[SolRayz]

So the FDA wants to ban ecigs, yet many of us wouldn't even be here if it weren't for cigarrettes and the addiction they cause to begin with, yet the FDA does NOTHING to combat cigarrettes which are EVERYWHERE. The hypocrisy is loud and deafening.

 

[Katmar]

Another day late to work. The reason:


I'm actually fairly proud of myself for not getting over-defensive about "If that's your concern, why can I buy 'For Tobacco Use Only' products at my local gas station?", since that would only be inflammatory and not helpful.

Excellent job, mid. Kudos and thank you for all your thoughts and hard work on this!! Outstanding.

 

[Surf Monkey]

Another day late to work. The reason:


I'm actually fairly proud of myself for not getting over-defensive about "If that's your concern, why can I buy 'For Tobacco Use Only' products at my local gas station?", since that would only be inflammatory and not helpful.

Nice work. Remember: the idea isn't to flame them. As tempting as it is, chewing them out is counter productive. They'll ignore that. The aim here is to give reasonable, level headed feedback that they can't ignore.

 

[Surf Monkey]

So the FDA wants to ban ecigs, yet many of us wouldn't even be here if it weren't for cigarrettes and the addiction they cause to begin with, yet the FDA does NOTHING to combat cigarrettes which are EVERYWHERE. The hypocrisy is loud and deafening.

The FDA does "nothing" to combat cigarettes? That's not an accurate statement.

We're all frustrated by the situation, but don't let emtion carry you away.

 

[Megan Kogijiki Ratchford]

Excellent job, mid. Kudos and thank you for all your thoughts and hard work on this!! Outstanding.

Agreed! Thank you mid, awesome post!

 

[SolRayz]

The FDA does "nothing" to combat cigarettes? That's not an accurate statement.

We're all frustrated by the situation, but don't let emtion carry you away.

No they do NOTHING...cigarrettes are everywhere, like I said, yet they want to focus on ecigs...

 

[Surf Monkey]

No they do NOTHING...cigarrettes are everywhere, like I said, yet they want to focus on ecigs...

Okay. Well, that's not true. You're frustrated. Understandable.

 

[SolRayz]

Sorry yes, I'm frustrated. I watched Phil Busardo's two part series at Evolv and the interviews contained yesterday evening, and all I see happening is the FDA stepping in, killing off grass roots business, and in a sick twisted way, promoting the use of traditional cigarrettes as the only alternative. I mean, really, tobacco flavored ejuice, menthol?!?...Who the hell is the FDA working for, not us!