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

[Megan Kogijiki Ratchford]

It Indicates that there are 10,000 people Willing to spend 10 Minutes to Write a Comment to the FDA.

And that type of Person is the Type of Person who will Probably Also be willing to write their Congressional Reps. Or Donate to or Enjoin in Legal Litigation.

Yessss.....

 

[yzer]

Lawyers are always the big winners.

 

[zoiDman]

Also, the comments we're making are about our health derived from not smoking tobacco not a plea of leaving an actual smoking product alone.

...

This is a BIG Distinction.

One thing that I was Very Happy to see in Many Pro e-Cigarette Comments was...

"Let Science Dictate FDA Policy."

The FDA has said Repeatedly that they have a Commitment to Improving Public Health. That, to me, should Include people who Smoke.

e-Cigarettes have been, and will Continue to, be shown to be Viable Harm Reduction. Perhaps the Greatest Harm Reduction Technique in the History of Smoking.

The FDA Should be Embarrassing this. And Should be Making it More Difficult for Adults to use e-Cigarettes. Or to Diminish the Effectiveness of e-Cigarettes by Non-Science Based Fears or Agendas.

 

[Gato del Jugo]

Receiving 10,000 Forum Letters about Premium Cigars Doesn't Bring much in the way of any Personal Perspective. Or add anything New to the Consideration of Potential Rules. But it Does Demonstrate a High Level of Organization.

I strongly disagree..

If they were truly organized, they'd know better not to tell their members to submit a form letter that, in the end, will only count as just 1 comment..

At least CASAA is smart enough to have understood that.. That while some of the basic guidelines issued may have been followed in some comments, they are in effect considered & counted as unique comments...


Besides, who knows if that cigar comment was simply the work of just one person, who continously copied & pasted, submitted & refreshed.. Over & over & over again..

Stranger things have happened...

 

[zoiDman]

Lawyers are always the big winners.

All to True.

But, Unfortunately, their Does come a Time when One must Crawl into bed with One to Achieve some Level of Remedy.

The ANTZ will have Theirs. BT will have Theirs Also.

Don't Bring a Knife to Gun Fight.

 

[ColoKaren]

Thank you so very much for the succinct explanation, Alexander. Call me a McMeanie, but I do see *some* merit to the FDA outlawing Diacetyl and the other bad ingredients in e-juice. It's the inclusion of hardware in the possible ban, including disposable parts such as cartos, that really bothers me. That this is included reeks of corruption to me. Heads should roll.

We do not for know for certain what will happen as this is only a proposal and not the final rule. If they do in fact regulate hardware as is my reading of the proposal then every single piece of e-cigarette specific hardware (ie mods, tanks, cartos, rbas, etc.) that was not proved to be on the market before the 2007 date set by Congress in the tobacco control law (everything we use today) would have to go through lengthy testing costing hundreds of thousands of dollars for each specific piece and then hope the FDA then approves them as a new product. If they don't (which seems to be the norm for tobacco products) you would just be out all your research money and the fee to the FDA. If they do, there would also be annual fees that would be involved in the 5 digit figure range. Bear in mind this is for each and every design that varies at all from another. Only huge corporations could afford to do this and they would only do it for a very small number of products because they would have to recoup their costs with large sales dollars. This means that at least 99.9% of all ecig hardware would not be legal to sell in about 4 years. If regulated the future could range from regulation of any nicotine derived from tobacco taken off the market leaving only Big Tobacco tamper proof cigalikes in tobacco flavor with skull and crossbones on the packaging sitting behind the counter costing 2X to 10X what they do today without sales over the internet, to hardware not regulated unless it is sold containing nicotine and eliquid would have child proof lids and be made in an FDA approved lab.

 

[yzer]

All to True.

But, Unfortunately, their Does come a Time when One must Crawl into bed with One to Achieve some Level of Remedy.

The ANTZ will have Theirs. BT will have Theirs Also.

Don't Bring a Knife to Gun Fight.

Even better: hire a goon for the gun work.

 

[ColoKaren]

I'm married to an attorney. An honest one. So of course, we're poor.

All to True.

But, Unfortunately, their Does come a Time when One must Crawl into bed with One to Achieve some Level of Remedy.

The ANTZ will have Theirs. BT will have Theirs Also.

Don't Bring a Knife to Gun Fight.

 

[zoiDman]

I strongly disagree..

If they were truly organized, they'd know better not to tell their members to submit a form letter that, in the end, will only count as just 1 comment..

...

That's Cool. This is an Opinion Based Discussion. And what Anyone believes is Not a Definitive Truth.

But we have to be Realistic when it Comes to People in General. And that is that Most People are Very Lazy. Having someone Send in a Form Letter Comment is Better than having someone send in No Comment at All.

I'm not sure why we Can get 10,000 People to do a ECF Survey about e-Cigarettes/e-Liquids? But it is Very Difficult to get 1/2 that Many to Make a FDA Comment?

---

BTW - Of Course there were Individuals who Submitted Anonymous Premium Cigar form letters Over and Over again. I Know it. You Know it. And the FDA Knows it.

But that does Not Detract from the Fact that there was a Very Organized Effort by Cigar Trade Associations, Suppliers, and Sellers to Inform cigar users of what the FDA May Do.

 

[jward015]

Does anyone have an update on what happened

 

[Mowgli]

Scrambling/changing the numbers, Aikanae, the government is good at. The better to confuse you and me....The better to hide the truth. Does anybody believe the IRS for example? How about the employment/unemployment numbers? Lemme see....Hm-m-m-m...

The tagline to the X-Files episode "Teliko" was "Deceive Inveigle Obfuscate." The three synonyms, two of which are not commonly used words, were referenced four separate times in this episode: (1) Replacing the usual tagline at the end of the opening credit sequence; (2) spoken by Scully; (3) spoken by Mulder; (4) written by Scully in her final report. "Inveigle" means to win over by guile or persuasion, and "Obfuscate" means to make dark or obscure, to confuse.




The truth is out there

 

[Surf Monkey]

This is a BIG Distinction.

One thing that I was Very Happy to see in Many Pro e-Cigarette Comments was...

"Let Science Dictate FDA Policy."

The FDA has said Repeatedly that they have a Commitment to Improving Public Health. That, to me, should Include people who Smoke.

e-Cigarettes have been, and will Continue to, be shown to be Viable Harm Reduction. Perhaps the Greatest Harm Reduction Technique in the History of Smoking.

The FDA Should be Embarrassing this. And Should be Making it More Difficult for Adults to use e-Cigarettes. Or to Diminish the Effectiveness of e-Cigarettes by Non-Science Based Fears or Agendas.

Agree. That's where my comments focused; on the idea that tight regulation will drive people back to analogues and that PVs represent an obvious and effective risk reduction method that the FDA should be promoting, not stifling. Regulations with the goal of protecting public health are welcome (standards for liquid purity for example) but regulations that promote social engineering (banning flavors) are not.

 

[midficollege]

Does anyone have an update on what happened

Long story short, they're going to be stuck reading and categorizing our comments, the antis' and the cigar peoples' comments for the next few weeks if not months.

My gut feeling is that they're going to all-but-ignore the individual consumer stories and point at the pile of "As a pediatrician, I..." form letters, regardless of their lack of content or experience with the products, as grounds to not ease the burdens of entry where it comes to nicotine harm reduction when compared to combustible tobacco products.

Then again, I'm usually pessimistic about most things. If I were to try to solve this personal failing, though, I doubt I'd start by putting more faith in bureaucrats.

 

[zoiDman]

Agree. That's where my comments focused; on the idea that tight regulation will drive people back to analogues and that PVs represent an obvious and effective risk reduction method that the FDA should be promoting, not stifling. Regulations with the goal of protecting public health are welcome (standards for liquid purity for example) but regulations that promote social engineering (banning flavors) are not.

I think there are Very Few in the Vaping Community who would Argue that Achieving Higher Standards of e-Liquid Purity is a Bad Thing. And Many would even Concede that something like Child-Resistant Containers would Stem many of the "Save the Children Arguments"

What I believe is that we can is we Can have Regulations that Improve and Ensure that e-Liquids are as "Safe" as possible. And, to a Level of Alcohol and Cigarettes, kept out of the Hands of Minors, without having to Turn the ENTIRE Market over to BT and or BB.

 

[tj99959]

Long story short, they're going to be stuck reading and categorizing our comments, the antis' and the cigar peoples' comments for the next few weeks if not months.

My gut feeling is that they're going to all-but-ignore the individual consumer stories and point at the pile of "As a pediatrician, I..." form letters, regardless of their lack of content or experience with the products, as grounds to not ease the burdens of entry where it comes to nicotine harm reduction when compared to combustible tobacco products.

Then again, I'm usually pessimistic about most things. If I were to try to solve this personal failing, though, I doubt I'd start by putting more faith in bureaucrats.

We did however have the need to show proof that their decisions effect individual lives.

So I included this in my comments:
" If the e-cig industry had lost the 2009 FDA lawsuit I would more than likely be dead by now. This! The effect the FDA has on peoples lives"

I also pointed out that:
"Now at the age of 73, I just might get to hang around for another decade or two"

 

[Gato del Jugo]

But that does Not Detract from the Fact that there was a Very Organized Effort by Cigar Trade Associations, Suppliers, and Sellers to Inform cigar users of what the FDA May Do.

Again, we have no idea if all or even a just a bulk of those form letters were sent by 10K unique individuals, or by just one..

It's not much of a stretch to envision an older retired gentleman who really enjoys and is passionate about his cigars & who has a lot of free time on his hands, perhaps with a touch of OCD or something..


Anyway, what we may lack in numbers is more than made up for it with quality..

I know for a fact that there is a lot going on behind the scenes at the industry level & the advocacy organization level, and I'm no "insider" by a long shot, and I'm sure what I do know about all that is only the tip of the iceberg..

We've got some smart, dedicated, passionate, organized people with a few bucks in their pockets & a lot of energy who have a sizeable stake in this game, and they're not about to get steamrolled by any entity..

Just because most of us don't see/hear all of it doesn't mean it's not going on...

 

[marlight]

We also had to counter the allegation that e-cigarettes don't help people quit smoking. Each one of the personal stories that I read stated that the author quit smoking because of e-cigarettes--even when all other methods failed. They can't ignore that fact or write that off. I believe it's facts like that that helps to counter the pediatricians' statements, who don't have science or facts on the efficacy of e-cigarettes on their side.

 

[zoiDman]

Again, we have no idea if all or even a just a bulk of those form letters were sent by 10K unique individuals, or by just one..

It's not much of a stretch to envision an older retired gentleman who really enjoys and is passionate about his cigars & who has a lot of free time on his hands, perhaps with a touch of OCD or something..

...

Not to Darken this Thread. But in the Interest of Fairness. The Same can be said about Anonymous Submissions using a CASAA Forum Comment.

The Long and the Short of it is the FDA Comment Period is Over.

And we should be Formulating a Organized Game Plan as to how to Proceed in this Next Phase of the FDA Rule Making Process.

 

[Surf Monkey]

I think there are Very Few in the Vaping Community who would Argue that Achieving Higher Standards of e-Liquid Purity is a Bad Thing. And Many would even Concede that something like Child-Resistant Containers would Stem many of the "Save the Children Arguments"

What I believe is that we can is we Can have Regulations that Improve and Ensure that e-Liquids are as "Safe" as possible. And, to a Level of Alcohol and Cigarettes, kept out of the Hands of Minors, without having to Turn the ENTIRE Market over to BT and or BB.

... which was also an element of my commentary. That there is a vibrant DOMESTIC market of manufacturers building and distributing popular mods that savvy vapers use when they "graduate" from the low quality, un-satisfying corporate BT products and that killing that burgeoning industry will effectively drive many thousands of vapers back to cigarettes, effectively delivering them a death sentence while also delivering an economic death sentence to a sector that is growing in a damaged economy that needs growth.

 

[tA71ana]

There is also an International trade issue here and I wish I was privy to the crowd noise going on there.
I wonder what manufacturers such as Innokin, Joyetech,Sigelei, KSD and the like are doing to insure that their massive business is not affected or impeded.
they are making BIG money from this industry.
Not only that, I would imagine that if BT wants to get into the ecig biz they are going to have to import their batts.
Not a good idea to upset people who will quite possibly be your source for hardware.