FDA TVECA post table of contents for Deeming Final Rule

[Rossum]

The great American patriot Benjamin Franklin was asked, upon his emergence from the Constitutional Convention in Philadelphia in 1787, what form of government the United States was going to have. Franklin answered succinctly, "A Republic, if you can keep it."

He knew that democracy is essentially three wolves and a sheep voting what should be on the menu for dinner.

 

[navigator2011]

Here is some Survey Information as to how the Public Views Regulations regarding e-Cigarettes .

"The survey showed specifically enthusiastic support for warning labels, a minimum purchase age, use limitations and advertising bans: 94% of respondents were in favor of labels warning e-cig consumers that the products contain nicotine, 90% supported banning e-cig sales to those under 18, 69% were against e-cig use in public places (including restaurants and workplaces), and 61% supported a government ban of television advertising.

The main area of division on the poll seemed to be the issue of flavor restrictions. When asked whether flavored e-cigs and liquids should be banned, 48% of respondents said no, while 46% were in favor of a flavor ban.

Even those conducting the poll were surprised at the firm stance the public has taken on electronic cigarettes."

Survey: Adults View Electronic Cigarettes as Harmful

E-cigarettes widely seen as harmful in STAT-Harvard poll - STAT

I think this statement, quoted from the end of the first linked article, pretty much sums up the situation:

American vaping Association president Gregory Conley said “unethical propaganda campaigns” against electronic cigarettes have led to “a confused populace” and therefore, negative poll results. “This poll is not measuring public opinion, but the effectiveness of a well-funded corporate strategy to destroy a category,” he said.

 

[MacTechVpr]

Here is some Survey Information as to how the Public Views Regulations regarding e-Cigarettes .

"The survey showed specifically enthusiastic support for warning labels, a minimum purchase age, use limitations and advertising bans: 94% of respondents were in favor of labels warning e-cig consumers that the products contain nicotine, 90% supported banning e-cig sales to those under 18, 69% were against e-cig use in public places (including restaurants and workplaces), and 61% supported a government ban of television advertising.

The main area of division on the poll seemed to be the issue of flavor restrictions. When asked whether flavored e-cigs and liquids should be banned, 48% of respondents said no, while 46% were in favor of a flavor ban.

Even those conducting the poll were surprised at the firm stance the public has taken on electronic cigarettes."

Survey: Adults View Electronic Cigarettes as Harmful

E-cigarettes widely seen as harmful in STAT-Harvard poll - STAT

American vaping Association president Gregory Conley said “unethical propaganda campaigns” against electronic cigarettes have led to “a confused populace” and therefore, negative poll results. “This poll is not measuring public opinion, but the effectiveness of a well-funded corporate strategy to destroy a category,” he said.

It's called market penetration.

Just sayin'. <shrug>



p.s. Beat me to the punchline there nav, lol.

I think this statement, quoted from the end of the first linked article, pretty much sums up the situation...

 

[Lessifer]

I know people won't like to hear this, but under point #5, where it says "And furthermore", those methods of testing are not excessive. In fact, that is how any lab anywhere would test just about anything. That's how you produce control and variable groups. It will absolutely hurt the vaping industry, which I don't want to see. I hope we can fight the need to test every liquid at all nic concentrations, but testing each juice on different mods, and each mod with different juices is not an overreach. It's how scientific studies are done.

That said, I'd like to know more about the 29 chemicals they are talking about. I'm sure there are more than 29 chemicals in e-liquid and the aerosol produced, but that doesn't mean they are the same chemicals as in cigarette smoke.

Do you mean atomizer instead of mod? Aside from TC mods, all a mod does is supply power, and can be broken down into two types: fixed voltage and variable voltage. Yes, there is a wide range in the amount of voltage that can be supplied but surely you're not suggesting that every combination of liquid would have to be tested at every possible voltage/wattage combination?

Also, it's only not excessive if you accept that vapor products SHOULD be regulated like tobacco products. If instead you subscribe to the thought that they are more akin to food products, you wouldn't insist that a can of condensed soup be tested by cooking it in every possible pan on any conceivable heat source.

 

[MacTechVpr]

Exactly.

 

[zoiDman]

I think this statement, quoted from the end of the first linked article, pretty much sums up the situation:

American Vaping Association president Gregory Conley said “unethical propaganda campaigns” against electronic cigarettes have led to “a confused populace” and therefore, negative poll results. “This poll is not measuring public opinion, but the effectiveness of a well-funded corporate strategy to destroy a category,” he said.

To be Honest, I'm not sure How to Evaluated the Poll Numbers? Or even if it Should be Evaluated? Some Numbers seem Reasonable. Others Don't.

And with Any Survey/Poll, Sampling methods and Question Wording is Critical.

 

[haleysdadda]

Do you mean atomizer instead of mod? Aside from TC mods, all a mod does is supply power, and can be broken down into two types: fixed voltage and variable voltage. Yes, there is a wide range in the amount of voltage that can be supplied but surely you're not suggesting that every combination of liquid would have to be tested at every possible voltage/wattage combination?

Also, it's only not excessive if you accept that vapor products SHOULD be regulated like tobacco products. If instead you subscribe to the thought that they are more akin to food products, you wouldn't insist that a can of condensed soup be tested by cooking it in every possible pan on any conceivable heat source.

I'm all for testing of e-juice randomly just to keep all in the industry honest. I personally would like to know if what I'm putting in my body is the stuff I think it is. But I think they all should be tested against 1 standard.

 

[Zabolee]

I wouldn't expect that every food product be cooked in every pan. Of course not. But at different temperatures, sure. We know not to eat chicken cooked to below 165 degrees, beef below 140, etc. With mods, I'd agree that each different chip be tested at many different voltages. So not every mod, since many mods use the same chipset.

I would agree that testing be done at, say, 2 volt intervals. When the release of toxic chemicals/aerosols is too high for user safety, you would fine-tune the settings to look at every 0.X volts. It will be a long process to look at these measurements across a wide range of resistances, but if a specific voltage is discovered to produce unfavorable results, that will help guide the industry in how powerful chips should be allowed to get.

This also means that a LD50 be tested for inhalation of those chemicals, as well as a useful confidence interval and p-values.

I understand that all the mod does is supply the power. And in the case of mech mods, that all comes down to the battery and resistance. But with regulated mods, I wouldn't be opposed to knowing that the power supplied is accurately displayed on the screen. My Invader mini varies so much between hits, that I don't use it anymore. With the same tank on it, set at 12watts, I've seen it read anywhere between 3.5-4.2 volts. Testing chips and mods will only help to ensure that the power you are expecting is the power being delivered.


As for what should be regulated as tobacco products... I think e-liquid containing nicotine should be. That's not even a question any of us should be asking ourselves. Tobacco leaves are used to produce the nicotine. But 0nic juice and the mods themselves should not be regulted as such. But in order to test nicotine juice, it should be done scientifically, which involves testing the product that supplies the power to create the vapor

 

[zoiDman]

I'm all for testing of e-juice randomly just to keep all in the industry honest. I personally would like to know if what I'm putting in my body is the stuff I think it is. But I think they all should be tested against 1 standard.

Completely Agree.

If it is left up to Individual PMTA Applicants to dream up what Standards they would like to Use, or what Yields the Best Results for their Particular Product, it can Invalidate the entire process.

 

[Jman8]

Can we have a market for those who believe extensive testing is a very good idea for consumers, and another market for those who are okay with testing as optional / not required and therefore okay obtaining non tested products?

Perhaps one day we will have that. The FDA market and the underground market.

Or perhaps we have it right now, with pre-FDA market and this post FDA market.

In the pre-FDA market I remember vapers bragging about how wonderful vaping was, how relatively safe it was and also recall seeing very few incidents of harm.

Gonna humor me when we get to the FDA market and incidents of harm go up, rather than down. Gonna humor me much, really.

 

[Lessifer]

I wouldn't expect that every food product be cooked in every pan. Of course not. But at different temperatures, sure. We know not to eat chicken cooked to below 165 degrees, beef below 140, etc. With mods, I'd agree that each different chip be tested at many different voltages. So not every mod, since many mods use the same chipset.

I would agree that testing be done at, say, 2 volt intervals. When the release of toxic chemicals/aerosols is too high for user safety, you would fine-tune the settings to look at every 0.X volts. It will be a long process to look at these measurements across a wide range of resistances, but if a specific voltage is discovered to produce unfavorable results, that will help guide the industry in how powerful chips should be allowed to get.

This also means that a LD50 be tested for inhalation of those chemicals, as well as a useful confidence interval and p-values.

I understand that all the mod does is supply the power. And in the case of mech mods, that all comes down to the battery and resistance. But with regulated mods, I wouldn't be opposed to knowing that the power supplied is accurately displayed on the screen. My Invader mini varies so much between hits, that I don't use it anymore. With the same tank on it, set at 12watts, I've seen it read anywhere between 3.5-4.2 volts. Testing chips and mods will only help to ensure that the power you are expecting is the power being delivered.


As for what should be regulated as tobacco products... I think e-liquid containing nicotine should be. That's not even a question any of us should be asking ourselves. Tobacco leaves are used to produce the nicotine. But 0nic juice and the mods themselves should not be regulted as such. But in order to test nicotine juice, it should be done scientifically, which involves testing the product that supplies the power to create the vapor

I'm not sure where to start...

First, the voltage we use typically runs between 3-6 volts, so a 2 volt interval would give you two readings, that wouldn't actually be indicative of 90% of the voltages used by common vapers unless you chose the correct 2 settings.

Second, voltage/wattage are only a small part of the equation. As has been shown a number of times, the wattage supplied is less important than a lack of "dry hit." Yes, wattage can contribute, as does wicking/juice flow and air flow. Does this deserve further investigation? Yes. Does it need to be tested for every product? No.

Third, a mod supplying the actual voltage/wattage it says it is providing is a consumer electronics issue, not one that should be of concern to the FDA.

Fourth, as tobacco regulations were ostensibly put in place to protect consumers from the harms of tobacco, not nicotine, and the use of vapor products have not been shown to expose the user to any of the harms associated with tobacco use, yes, it is most definitely a question we should be asking.

 

[haleysdadda]

Can we have a market for those who believe extensive testing is a very good idea for consumers, and another market for those who are okay with testing as optional / not required and therefore okay obtaining non tested products?

Perhaps one day we will have that. The FDA market and the underground market.

Or perhaps we have it right now, with pre-FDA market and this post FDA market.

Sounds like the opioid market. Script opioids or street drugs? I for one am not for extensive testing for ever, just in the begining so we kind find a standard for future products to be judged by. We absolutely have to have set standards for watts, voltage, Ohms, and coil configuration that all things have to meet initially.

 

[Alexander Mundy]

We absolutely have to have set standards for watts, voltage, Ohms, and coil configuration that all things have to meet initially.

That's a tough cookie right there. Even a slight variation in wicking, airflow, PG / VG / water / flavoring mix can produce wildly different results with the same voltage, coil, and atty. Under that assumption all we would be looking at is closed systems that are prefilled....aka cigalikes.

 

[Jman8]

Sounds like the opioid market. Script opioids or street drugs? I for one am not for extensive testing for ever, just in the begining so we kind find a standard for future products to be judged by. We absolutely have to have set standards for watts, voltage, Ohms, and coil configuration that all things have to meet initially.

If we absolutely have to have set standards, then how is it that vaping industry right now is able to exist without it? Is this current market without the absolute set standard doing poorly in your opinion?

 

[haleysdadda]

That's a tough cookie right there. Even a slight variation in wicking, airflow, PG / VG / water / flavoring mix can produce wildly different results with the same voltage, coil, and atty. Under that assumption all we would be looking at is closed systems that are prefilled....aka cigalikes.

I mean something like calories per serving. At this setting on this build or better yet according to FDA/VSS(Vaping Safety Standard) VS- umptysquat125 this vape product produces this much A,B,C,D,....! THE SETTING OF THE STANDARD IS THE HARD PART! And with a standard other companies could be certified by such a standard to test products under that standard. I am a Machinist and my precision instruments have to be calibrated under things seamingly as silly as what temperature the room is, how long an item has to stay in that room per inch of max thickness, ect.... Then your supposed to measure parts in a similar fashion. this is because things change size the hotter or colder they get depending on many variables. That way when somebody in Russia makes a rocket part the mating part from China works together as designed. That way when somebody makes a juice somewere we have a baseline to compare it to!

 

[haleysdadda]

If we absolutely have to have set standards, then how is it that vaping industry right now is able to exist without it? Is this current market without the absolute set standard doing poorly in your opinion?

Unfortunately I couldn't accurately answer that question because I don't really Know what's in my juices. I don't DIY! At this point all I can do is TRUST that the juice vendors aren't poisoning me with some kind of filler to make more money! By the way is that Five Pawns "Premium" Juice thing settled yet?

 

[Kent C]

At this point all I can do is TRUST that the juice vendors aren't poisoning me with some kind of filler to make more money!

How do they make more money if you die? Hopefully none are reading your posts.

 

[Lessifer]

If you broil a steak at 500 degrees for 9 minutes, you'll get a nice medium well steak. If you broil it at 500 degrees for 30 minutes, you'll get a charred mess. This is what has been shown by the e-liquid testing done so far. There are no magic settings. It requires a person, in a situation, using their senses to determine what is and is not acceptable. Luckily, it is incredibly apparent when a certain configuration is not working properly.

The problem with a standard is, it assumes uniformity.

 

[Zabolee]

I apologize, I meant to say every .2 volts. That way you get a curve that can be measured.

And I agree, not every product needs to be tested. Just the different brands of chips. So every mod using a DNA40 doesn't need testing. Just the DNA40 (any mod will do). Same with the different Yihi chips, etc...

I also agree that it is not the nicotine that is the health problem, but the associated chemicals produced from any type of combustion. And vaping is not combustion. But is is also not technically vapor, either. It is aerosol. But since nicotine is derived from tobacco, and all other nicotine supplying products (ie. patches and gum) are regulated, what argument can you give to say e juice shouldn't be too? Patches and gum aren't tobacco leaves either. I know that e-cigs have a much better success rate than other methods, but that isn't enough of an argument. I would really like to know what these arguments are (no sarcasm. Not trying t be a no-it-all. I just haven't come across any that meet scientific standards).

I don't think that FDA should regulate how much power it supplied by any mod. But you do need to test the vapor that is produced from a variety of sources. That's simple scientific method. Trying to say that because my Mod X, using a tank Y, at Z watts doesn't produce harmful chemicals is not the same as saying all mods and tanks perform the same way at all power settings with all juices.

That's why there is always a debate about what new mods and chips are accurate and consistent. They don't all perform the same under different situations.

 

[haleysdadda]

If you broil a steak at 500 degrees for 9 minutes, you'll get a nice medium well steak. If you broil it at 500 degrees for 30 minutes, you'll get a charred mess. This is what has been shown by the e-liquid testing done so far. There are no magic settings. It requires a person, in a situation, using their senses to determine what is and is not acceptable. Luckily, it is incredibly apparent when a certain configuration is not working properly.

The problem with a standard is, it assumes uniformity.

You're absolutely right about burning the steaks! But I bet those steaks were processed under the same FDA maybe standard!