UK MLX 364 Proposal

[westcoast2]

Nictoine is regulated under the Poisons act (I don't have the ref to hand). Which allows nicotine upto 7.5% I believe.

Packaging for ejuice comes under the CHIP regulations. --> HSE - Chemicals (hazard information and packaging for supply)

The regulations below already apply under the General Product Safety Regulations 2005 but they're not being enforced:

abd Courtesy of UK Vapers...

Meaning of a Safe Product
3.1 A “safe product” is any product which under normal or reasonably foreseeable conditions of use presents no risk or only the minimum risk compatible with the product’s use and which is consistent with a high level of protection for consumers.
3.2 While the Regulations do not apply to the safety of services per se, the safety of some products (e.g. certain machinery and gas appliances etc) is dependent on how they have been installed and maintained. These services are an essential feature of the safety of the product and may form part of the contract to supply the product. As such they will be taken into account when judging whether the product is a safe product.
3.3 The safety of a product will be assessed having regard to a number of matters and, in particular:
l the product’s characteristics;
l packaging;
l instructions for assembly and maintenance, use and disposal;
l the effect on other products with which it might be used;
l labelling and other information provided for the consumer; and
l the categories of consumers at risk when using the product, particularly children and the elderly.
3.4 The existence of higher levels of safety, or availability of products presenting lesser risk, will not in itself mean that a product is unsafe.

Minimum risk compatible with the product’s use which is
consistent with a high level of protection for consumers

9. It must be recognised that it is not always possible to eliminate all risk from products. Certain products, by the very nature of their intended purpose, carry an inherent safety risk and consumers must accept that they have a responsibility to exercise due care in using such products. Examples are knives and scissors, which must have sharp edges to perform their function but where reasonable precautions can be taken to ensure that handles are sturdy and hands are kept away from the functional edges when such items are in use. In other cases, it could be argued that consumers should be aware of the potential risks of misuse through general knowledge, education and experience. Thus, a balanced view must be taken based on the nature of the product and the acceptability of the risk to consumers based on the characteristics of the product and its use. The range of potential hazards which may need to be drawn to consumers’ attention will depend on a number of factors (referred to in the section above on ”Labelling”)...

http://www.berr.gov.uk/files/file22713.pdf

So as you can see they are a number of regulations in place to protect quality and safety already.
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[westcoast2]

Deewal, I was refering to ASH(UK)'s postion on the MHRA consultation.

I take your point about FSC though I do not think we should get involved.

Wrt to the ASH statement. Many take this as support for the e-cigarette that we have today. It is very cleverly worded.

I suggest you research the ASH(UK) postion which is 'Harm Reduction' through the use of Medicinal Nicotine. They support control of Nicotine Products through a framework on nicotine control. This comes directly from the Royal College of Physicians position on the use of Reduced Harm medicinal nicotine products.

The apparent support for the e-cig is not support for the e-cig as of today. It is a Medicalised version. Hence my assertion that they would support Option 1 and only at a stretch possibly option 2.

ASH(UK) do not support the current regulatory framework e-cigs operate under. This is an incorrect understanding of their position and unless ASH(UK) come flat out and support a Non-medicalised e-cigarette, then the position they are taking is that e-cigs need regulating as a medicine (NRT). The document only points out that they 'may be safer' and that they are regulated as general consumer products.

Note they have not updated their document as the document still supports the medicalisation of the e-cig while apparently lending support to the status quo. It is consistent with thier stated postions on NRT/a Framework for Nicotine control and the FDAs stance.

(The fact they support FSC is not the issue)
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