FDA Why Isn't Vaping the FDA Center for Tobacco Product's Biggest Ally?

[Fitzie]

I'm confused. I think the FDA has shed some light on what they're looking at/for on page 20 of the IRFA etc analysis:

"The direction of the effects of electronic cigarettes on health and welfare depend on two
characteristics:
• Relative health effects. Are electronic cigarettes safer than the reference products, which
would likely be cigarettes or cigars? In other words, are there negative health effects
associated with electronic cigarettes? And, if so, are they less than, greater than, or about
the same on average as the tobacco products consumers now use?
• Relationship with other products. Are electronic cigarettes on balance substitutes,
complements, or not closely related to other tobacco products?

o Substitutes. Substitutes are competing goods. If electronic cigarettes are
substitutes for cigarettes and cigars, then consumers would use electronic
cigarettes instead of these other tobacco products. All else the same, as more
electronic cigarettes are consumed, fewer cigarettes and cigars are consumed.
o Complements. Complements are goods that are consumed together. If electronic
cigarettes are complementary to traditional tobacco products, then as more
electronic cigarettes are consumed, more cigarettes and cigars are consumed.
o Not closely related. If the consumption of electronic cigarettes has no effect on
the consumption of other tobacco products (and vice versa) then the two goods
are not related. We would think of the two activities and possibly the two groups
of consumers as independent."

etc, etc, etc

I'd hazard a guess that the questions FDA posited in the deeming regs will also shed some light on how they're going to approach the public health issue.

 

[Roger_Lafayette]

Not in my world. Vapour is recreational nicotine. And unless it's approached that way no argument in the world will get it less restricted than the TCA.

Look how well it worked for ST

Yeah I know. But there wasn't a real community behind it. We are just going to have to organize the out of ourselves and make a lotta noise. We are winning these state battles thus far, although it looks like IL is going to go down. So it shows that we can do things.

 

[Roger_Lafayette]

Sorry, Roger. I have to bow out at this point, as gracefully as I possibly can. I really don't understand the finer points of political advocacy and what needs to be said in the "public policy arena." I believe in simply telling the truth, as I know it. So I'll just wait for the CASAA lawyers to tell me what to say in my comments to the FDA. They speak the language--I don't.

And, to quote H.L. Mencken one more time:

I am strongly in favor of common sense, common honesty, and common decency. This makes me forever ineligible for public office.

It's not about the FDA comments, it was a more general point public policy arguments. And as CASAA members we should have a voice in that, I think. Who knows, maybe CASAA will not want to even mention cessation, and embrace dual use as harm reduction without saying anything else.

If cessation is irrelvant then the advantage of crowdfunding the West toolkit would be reduced.

We perhaps should be looking at least as hard at doing some other kind of study such as on the health effects for individuals.

 

[tombaker]

If we could "just sit down" with Mr. Zeller, we would. But we mere mortals do not get an audience with His Excellency. We must meet with his advisors at "listening sessions," write letters, submit comments and testify at TPSAC hearings - all of which we have done. The FDA has been provided REAMS of scientific information and survey results providing evidence of efficacy and safety. CASAA even called off the "FDA dogs" during this period and played nice, avoiding any public criticism of the FDA...until they issued the proposed rules and proved to us they had ignored everything we had presented.

If you can arrange for a one-on-one meeting with the man, please let us know how you did it.

I think certain methods, cause meetings to become harder to facilitate. The FDA was obligated to Congress to proceed to issue the Deeming. The main parts of the deeming was just establishing that E-Cigs are part of the 2009 Act, that is why its "foundational". It give a foundation for E-Cigs to be within the law.

The law was not changed. We all understood in 2011 that the FDA would issue the Deeming. No meeting would stop that eventuality. Looking for meetings with the FDA, as the message back was issuing the deeming....are wrong. Again the Deeming required upon the FDA, and demanded by the lawmakers.

To that the Deeming gaving a large grace period of 2 years for applications. They did not need to do that, as their first move, they could have done no grace period, and conceded down to 2 years after comments. This is why the majority of the large players saw the Deeming as positive. That and they can still lobby with comments.

CASAA is known to the FDA, that is a fact. Post the deeming, has CASAA been in contract with their key contacts within the FDA?

 

[tombaker]

A lot of liberal Democrats, attempt to squash discussion, to the point they protest and picket with speakers come to a University from speakers that may not be goose-stepping in perfect synchronization to the Prescribed way of thinking. This is in the news every day, especially during commencement speeches.

Dead on arrival bills in California are nothing new, and correlation to items, is not a proof of causation (this is the theory of lucky hats win football games).

Surrounded by some other stuff, at its core you are attacking posters below, instead of addressing the ideas. Whether or not you specifically benefit from the dialogue in the forum is a personal choice.
Stifling discussion and reasoned exchange of ideas, is stifling.

I have repeatedly responded to your posts with one simple suggestion, which basically amounts to this sentence, which I will express in some rather blunt terms: "If your insights are so valuable, then please demonstrate this, instead of posting about it."

Your posts suggest that you apparently believe that you have unearthed some kind of as-yet-undiscovered legal loophole in the tobacco act (FSPTCA). I have made several suggestions to you about how this message could be communicated, for example by sending registered letters to the various recognized "legal eagles" in this fight (folks like Azim Chowdhury, Greg Conley, CASAA Pres. Julie Woessner, etc.). Or take out a newspaper ad if nothing else works (you did indicate at one point that you were willing to put up $10K for the cause of vaping).

All of this talk about what the FDA supposedly knows or thinks has to be examined in the context of their history, the workings of the US government in general, and so forth. I do not claim to be an expert on any of this stuff (or anything else for that matter). But it seems that there's some fairly good evidence of prior actions on the FDA's part with regard to vaping as well as ST (smokeless tobacco). Speculation about what Zeller personally knows or thinks is just that - mere conjecture. In my mind, such blather is little more valuable than wondering about what variety of floral arrangement he might prefer.

It seems that once again, the efforts of CASAA/ECF (along with other orgs) have borne fruit in California. AB 1500 appears to be dead - and I heard it myself from a legislative aide about an hour ago. Vapers have not yet lost a single state battle so far this year, although obviously that may change.

In my book, the proven track record of CASAA beats idle chatter any day of the week, no matter how many arguably plausible claims of insight, erudition, and experience are contained in the latter.

Those of you who seem to think that you can change Zeller's and/or the FDA's mind about the scope and likely effect of the proposed rule are welcome to make such an effort. Do whatever you please. But for heavens' sakes, I implore you to do us all a favor by showing us what you can do, instead of posting about it.

Once you (and that means anyone) have saved the day with your insight, your brilliance, and your experience, I will be among the first ECF denizens to warmly congratulate you. And please spare me from the trouble of reading additional arguments which effectively begin with the phrase "If I were king of the vaping world, I'd ..."

CASAA has shown what it can do..

The proof of the pudding is in the eating - not the touting.

 

[Roger_Lafayette]

So the first bullet is harm reduction, right? To what extent are individuals less harmed by vaping versus tobacco cigarette smoking? We have to win that one, obviously. That's almost taken for granted - if vaping is more dangerous than smoking for each individual, then there is little benefit to quitting smoking in favor of vaping, right? There is also the problem of never-smokers taking up vaping (you will occasionally see references to this, although the evidence for this is essentially nil among adults.)

I think the second one is where the rubber meets the road as far as cessation goes. (And hiding in the background is the gateway argument - which is also generally of little interst to the ANTZ these days, for adults. Few of them wil still argue with a straight face that adult never-smokers begin to vape, and then "graduate" to tobacco cigarettes. But there is still very much of a minors argument there, due to Dutra & Glantz's "seven times more likely" and some other junk studies like that Korean one. You'll see those collected in the latest Grana, Benowitz & Glantz Circulation jrnl article: http://tobaccoanalysis.blogspot.com/2014/05/glantz-review-article-is-little-more.html

ANyway I wasn't talking about the FDA as such. My bottom line is this - unless we can convince the public and policy makers that there will be fewer deaths, we lose. I don't see a way around that, except perhaps to argue that vaping will not increase deaths and that it will improve the quality of life for dual users. But even there, we have to show that vaping has at least as much cessation as "no vaping."

One more triviality ... if you look at the public health literature on smoking, you don't have to read very many papers before you see this argument made over and over again - the harder and/or more inconvenient and/or more unpleasant it is to smoke, the more people will quit. This is the argument made in support of "de-normalizing" smoking - although a better word for this might be "demonizing." I think this is why perhaps we vapers react so strongly to the idea of promoting cessation. (It's a "sell out." We are trying to - if you will - "pass" by the standards of the majority that oppresses us.) This idea about making it harder to smoke in terms of taxation and regulation and even social discrimination is everywhere in the public health literature. In that sense smoking is treated differently than other types of addiction, so far as I can tell.

So vaping is viewed as a step backwards insofar as it interferes with this process of reducing smoking prevalence. Mortality functions as a surrogate for this argument. But it works as messaging. "Vaping means more (prematurely) dead people" is a hard message to beat. Unless vaping actually means fewer (prematurely) dead people And the only way vaping means fewer prematurely dead people is via cessation, (again, if we believe the argument that reduced smoking does not increase expected lifespan.).

I'm confused. I think the FDA has shed some light on what they're looking at/for on page 20 of the IRFA etc analysis:

"The direction of the effects of electronic cigarettes on health and welfare depend on two
characteristics:
• Relative health effects. Are electronic cigarettes safer than the reference products, which
would likely be cigarettes or cigars? In other words, are there negative health effects
associated with electronic cigarettes? And, if so, are they less than, greater than, or about
the same on average as the tobacco products consumers now use?
• Relationship with other products. Are electronic cigarettes on balance substitutes,
complements, or not closely related to other tobacco products?

o Substitutes. Substitutes are competing goods. If electronic cigarettes are
substitutes for cigarettes and cigars, then consumers would use electronic
cigarettes instead of these other tobacco products. All else the same, as more
electronic cigarettes are consumed, fewer cigarettes and cigars are consumed.
o Complements. Complements are goods that are consumed together. If electronic
cigarettes are complementary to traditional tobacco products, then as more
electronic cigarettes are consumed, more cigarettes and cigars are consumed.
o Not closely related. If the consumption of electronic cigarettes has no effect on
the consumption of other tobacco products (and vice versa) then the two goods
are not related. We would think of the two activities and possibly the two groups
of consumers as independent."

etc, etc, etc

I'd hazard a guess that the questions FDA posited in the deeming regs will also shed some light on how they're going to approach the public health issue.

 

[tombaker]

Excellent commentary.
First where I disagree. The cost of E-Liquid could go down in price more as the market expands. You have companies like MBV who are selling 236ML fresh brewed for $41 in plastic. If large players come in like NJOY these prices could become more of the norm, rather than today's prices.

Today I bought 60ml total of Johnson Creek Red Oak line in Glass from a local store with taxes at $35 even. Which I thought was excellent deal, especially because I tasted all the flavors, first. That shop was literally 2 months old, first time I found it. Told them they needed to update their Google words because Vape Shop did not find it, but Vapor Shop did. Johnston Creek the oldest Juice Maker in the US, is alright with the Regulations so far. Johnston Creek I believe would be the Samual Adams to the MBV Budweiser.

(FWIW, the Johnson Creek, which is pre-steeped is very very much worth it compared to the Brewed to Order MBV)

Where I agree, is with your assessment of Nicotine....because when you read the FDA's Lawyers arguments in the appeal you see them give lots of open doors, to what you are saying for Nicotine as a classification.

For the Big 10 of Vaping, I would not be surprised if one or more of them do not launch an attack on the Nicotine aspect of the Deeming, WHILE at the same time, doing all the necessary work for paperwork compliance. If the FDA goes too far in its application of the Deeming, this challenge to Nicotine could be more useful.

As I said before I think the FDA could likely get the Congress to do the necessary law changes to fix the exposure.....They would say just lost this challenge, we need to have the power to regulate, but not ban....and Congress would go along.

All that said, I think one of the big guys will file the lawsuit to assert your assessments point....just to have it concurrency running in the courts while the final rules are actually played out.
Your post is an excellent resource

From my perspective (to bobbilly's point) nicotine is

A) not covered by any tobacco act because its part of the National Formulary (google "nicotine USP Formulary")

B) if extracted from tobacco may still contain various components that could be traced back to tobacco (99.7% pure is not sufficient) making it potentially subject to regulation.

C) easily made on a variety scales chemically or biologically but may contain unsuitable components to be filtered out ($$'s).

D) A botanical under the vitamin laws because its in much of the plant food we eat. No one is addicted there.

E) Not addictive according the FDA web site associated with gum and patches.

Nicotine from "other sources" is currently expensive relative tobacco nicotine - duh - so is wind or solar energy relative to gasoline.

Why? Manufacturing and distribution infrastructure.

We know that every ex-smoker here can and did spend up to $5-$7 a day on cigarettes - maybe $1500/year.

We know that vaping costs maybe 20% of that today, maybe $300/year (excluding fancy equipment).

So nicotine from other sources can add up to about $1200/year in cost and everyone here will still pay it to vape instead of smoke because it will still be cheaper.

Once it crosses the cigarette cost people will again start to smoke.

Say there are a million vapers (low estimate) x $1199/year on non-tobacco nicotine = instant $1.2 BILLION dollar industry (hockey stick growth).

So I could spend $100 million to develop this source, wait for Zeller to crush tobacco nicotine, and bingo - you're a billion dollar business.

Sure people will complain - but there will be no choice because it will cost less than tobacco.

Of course, as more and more vapers appear the numbers become even more attractive.

But no, let's ignore all this and simply rely on what? Waiting for Zeller to return our calls?

Bet your bottom dollar vaping will never be this cheap again and you can rest assured that these kinds of products will magically appear as soon as he drives a nail into nicSelect and friends vaping products.

Little wonder SFATA has their own organization...

 

[tombaker]

The methods of appraising the health benefits of E-cigs are defined by the FDA already.
Cessation is not an objective, that is to say, the goal is a benefit from the status quo. If a product reduces the consumption by individuals of Analogs, that is already determined to be a showing of proof of public health benefit. Glantz has his newest Meta-Analysis, as having a measure of 100% Cessation as the only goal.

Glantz is out of line with the FDA already. Glantz is measuring "quit attempts" and is not quantifying the reduction of Analogs via E-Cigs, when in the oh so horrible dual use mode of transitioning.

And then there is "Dr Benowitz is a consultant to several pharmaceutical companies that market smoking cessation medications and has been a paid expert witness in litigation against tobacco companies.", who is Glantz's co-author.

Yes, cessation is important. I have quit and am happy to have. Cessation studies should certainly be pointed out as rebuttal.

But, it sounds like you are trying to take a position that cessation is the only purpose for e-cigs, when it is really only one of several and mis-represents a lot of real-life vapers. It sounds a little like 'twisting the truth' in order to make a point, a road I don't think we should go down.

The argument should be more like:
1. It's most likely harmless (here's the studies)
2. It's legal
3. It's certainly less harmful than smoking (here's the studies), and therefore an excellent alternative
4. Many people quit smoking (here's the studies)
5. Many people cut down on their smoking (here's the studies)

These are all truths, and arguments worth making in tandem.

Instead of
1. It's a smoking cessation product

This is a partial truth aimed at one narrow ANTZ objection (out of many that they throw out there, not out of concern about that particular objection, but just to see what will stick in order to gain their agenda) that says to vapers that haven't quit that they are failures, and they should keep quiet about it so the rest of us can keep our right to vape.

 

[tombaker]

Each and every part of the below is factually wrong. Especially when you stop a study, at point when a smoker is continuing to use his E-Cig and his Analog on a path to eliminating the Analog, which would be reflected much better if the study was being done for more than 6 months or a year.

The measurement of Cessation only discounts, the study participant that remains adherent to using an E-Cig when the study time-frame ends. We already have 75% or greater of respondents saying they are using E-Cigs in order to quit. Which is exactly the path of dual user, which Glantz is excluding as a positive result. This will be easy to show.

Again....all of the below is for lack of better words......wrong. (All as meaning every sentence)

It's #4 that matters to mortality. If there's one thing that the public knows about smoking, it's the mortality statistics. And unless and until we can show that vaping reduces mortality, we cannot win this argument in the public policy arena.

(This is assuming that we agree with Siegel that reduced levels of smoking for individuals don't help with their expected mortality.)

In short, we must show that more people quit as a result of vaping being around, than would quit if there was no such thing as vaping.

Otherwise we are arguing that the benefits of reduced tobacco cigarette smoking (which are in the form of quality of life) must be weighed against the disadvantage of reduced cessation (which are in the form of increased mortality).

And that's a very difficult argument to make.

At the end of the day, we absolutely must emphasize cessation. I didn't say it should be the only thing we emphasize. But it's gotta be job #1, because complete cessation is the only thing that will affect mortality.

And if mortality is increasing as a result of vaping (i.e. fewer people are quitting) then we are in very deep trouble. We have lost this public health argument.

 

[Anjaffm]

You mean the flowers to Mitch Zeller?

I was hoping we could take up a collection, and make sure that some were also sent to Stanton Glantz.

hm.. where can I get a bouquet of poison ivy, please?

..............

@toddkuen:

Excellent opening posting. You said it all in a nutshell, dear.

 

[tombaker]

I'm confused. I think the FDA has shed some light on what they're looking at/for on page 20 of the IRFA etc analysis:

"The direction of the effects of electronic cigarettes on health and welfare depend on two
characteristics:
• Relative health effects. Are electronic cigarettes safer than the reference products, which
would likely be cigarettes or cigars? In other words, are there negative health effects
associated with electronic cigarettes? And, if so, are they less than, greater than, or about
the same on average as the tobacco products consumers now use?
• Relationship with other products. Are electronic cigarettes on balance substitutes,
complements, or not closely related to other tobacco products?

o Substitutes. Substitutes are competing goods. If electronic cigarettes are
substitutes for cigarettes and cigars, then consumers would use electronic
cigarettes instead of these other tobacco products. All else the same, as more
electronic cigarettes are consumed, fewer cigarettes and cigars are consumed.
o Complements. Complements are goods that are consumed together. If electronic
cigarettes are complementary to traditional tobacco products, then as more
electronic cigarettes are consumed, more cigarettes and cigars are consumed.
o Not closely related. If the consumption of electronic cigarettes has no effect on
the consumption of other tobacco products (and vice versa) then the two goods
are not related. We would think of the two activities and possibly the two groups
of consumers as independent."

etc, etc, etc

I'd hazard a guess that the questions FDA posited in the deeming regs will also shed some light on how they're going to approach the public health issue.

BINGO, my posts of late have been reflecting this actual passage, was going to start a new thread for it actually. Probably will still, when I have enough time. I looked for this after reading the Glantz raw documents.

You can see how Glantz is attempt to create a new review criteria, which some people have fully bought into and are trying to fight off a non-starter theory of Lactobifidusatoodle Study determining mortality in studies spanning 10+ years.

E-Cigs are clearly SUBSTITUTES....and Glantz Meta-Study confirms this. Which is why he seems to want to move the goal posts to a go-nogo jig. Either cessation or not. But the Deeming CLEARLY does not reflect that.

Frankly and clearly E-Cigs pass the above criteria with flying colors, and already confirmed by Glantz. Which makes his recommendations to the FDA all the more, silly.

1. E-Cigs are safer, much, and shown to be such by studies in place.
2. E-Cig users who are dual use, are shown and proven to be using less analogs. Studies are in.
3. There is no scenerio shown, or even discussed on ECF in the raw, that E-Cigs users consume more Cigs. Again why Glantz want the criteria cessation, vs the simpler Substitute criteria.
4. Bonus materials, E-Cig users are shown to try E-Cigs as a means of quitting, and self electing for that.
5. Its shown that for those that actually fully go into Cessation, that E-Cigs do it at a study level which is "significant"
6. Glantz counts Substitutes in process, as a negative outcome.

I honestly believe the health benefit box can be checked off, except for the actually filing of the papers, and doing the comments before the current 75 expires.

Remember comments are unlimited per individual and everyone else. So VOTE, and VOTE OFTEN

 

[tombaker]

ANyway I wasn't talking about the FDA as such. My bottom line is this - unless we can convince the public and policy makers that there will be fewer deaths, we lose. I don't see a way around that, except perhaps to argue that vaping will not increase deaths and that it will improve the quality of life for dual users. But even there, we have to show that vaping has at least as much cessation as "no vaping."
[/I]).

Wrong. The 2009, recognizes that all tobacco is not safe. It recognizes the benefits of displacing Analogs. You have constructed a self imposed impossible mountain to climb, and are defeated by your own mirage of facts.

 

[aubergine]

It does seem to me that dual use doesn't compete with cessation - it's a continuum of good. I'm getting a little lost in the fine points here. Could someone remind me what it is exactly that we're trying to establish here, and why?

 

[wv2win]

.................................
I do not understand why the FDA can not be treated as an ally...............................

I see no tactical advantage to treating the FDA as evil, liars, wanting death to vapers................................

I have not seen a good argument to not try to work with the FDA. There is no good reason to insult them. There are many good reasons to attempt to work with them, and get them to the right side of history.........................

The FDA has is positioned to accept the evidence, and conclude on the evidence in favor of Vaping......

That option has already been tried. CASAA sat down with the FDA and presented them with the scientific evidence on vaping. The proposed Deeming Regulations are the result.

So explain again how your method is going to make a difference???????????????????????????

If we could "just sit down" with Mr. Zeller, we would. But we mere mortals do not get an audience with His Excellency. We must meet with his advisors at "listening sessions," write letters, submit comments and testify at TPSAC hearings - all of which we have done. The FDA has been provided REAMS of scientific information and survey results providing evidence of efficacy and safety. CASAA even called off the "FDA dogs" during this period and played nice, avoiding any public criticism of the FDA...until they issued the proposed rules and proved to us they had ignored everything we had presented.

If you can arrange for a one-on-one meeting with the man, please let us know how you did it.

Do you actually think that the Deeming Regulations are the result of any CASAA meeting with the FDA, where items were given to the FDA? Do you actually believe what you wrote? The Deeming is a result of what? Exactly what are you proclaiming?

Why don't you go back and read your post I responded to about how you believe that all we have to do is talk with the FDA, show them the many positive studies on vaping and everyone will walk out of the room holding hands and singing Kumbaya.

And I in NO way indicated that the FDA's meeting with CASAA caused the Deeming Regulations. My meaning was clear. Your idea has been tried with no positive result.

What part of "it has already been done to no effect" do you not understand?

 

[toddkuen]

...
All that said, I think one of the big guys will file the lawsuit to assert your assessments point....just to have it concurrency running in the courts while the final rules are actually played out.
Your post is an excellent resource

A lawsuit has to happen after regulations take effect.

We need to have the right lawyers ready so that when some FDA-targeted shop gets a letter it can counter sue because it will then have standing.

The argument is simple: Nicotine as a USP formulary is explicitly exempted from the acts.

They will counter with the fact that there are nanograms of tobacco alkaloids present in the nicotine hence its a tobacco product.

The trick will be the next argument where we must counter them by one of a couple things (more ideas needed here):

One is to get an lower-limit established by the court, i.e., below X nanograms its just an impurity, impurity is a fact of industrial life.

Another is to argue that waste from tobacco processing contaminates everything with tobacco alkaloids and a certain amount are expected.

Another is to point out that children working in tobacco fields are over exposed to nicotine every day under no standards what-so-ever and the government is presenting conflicting standards.

(there are probably more but I have not thought it through...)

While this will delay things I still plan to have non-tobacco nicotine in hand in quantity.

 

[toddkuen]

I have repeatedly responded to your posts with one simple suggestion, which basically amounts to this sentence, which I will express in some rather blunt terms: "If your insights are so valuable, then please demonstrate this, instead of posting about it."

Your posts suggest that you apparently believe that ....

...aved the day with your insight, your brilliance, and your experience, ...

So how is your response any different than the FDA response to ecigs?

Prove you're better or go away - an FDA argument.

Nothing, including CASAA is 100% effective.

Yet I am held to a different standard.

Another FDA argument (see, only quitting 100% is acceptable).

And finally the last underline in the quote.

Nobody at the FDA wants any disruptive thinking to spoil party.

I know my insights work in other contexts - but are they valuable?

Obviously not to the mini-FDA we have going here - but at the same time your arguments are full of important information about how attacks are thwarted through various means.

Good stuff from my perspective.

Where did you develop this style of thinking?

 

[Roger_Lafayette]

It does seem to me that dual use doesn't compete with cessation - it's a continuum of good. I'm getting a little lost in the fine points here. Could someone remind me what it is exactly that we're trying to establish here, and why?

Okay imagine the world before vaping. Look at the quitting rates before vaping. Roughly 5% of smokers have quit annually, via counselling, cold turkey, NRT etc.

Now look at the quitting rates among vapers. If it turns out that those quit rates aren't lower, then you have at least the same if not a higher percentage of vapers who are still smoking. That's correlation. Now the public health people will identify various kinds of causal links by surveys. For example, the perception of reduced risk among dual users. (Which, if we believe Siegel, is false insofar as mortality goes.) Or the perception that vaping will help smokers quit (which, Glantz and the other public health people will argue is false to the extent that vapers allegedly have lower quit rates). Or other ways in which vaping is better than smoking (doesn't smell, annoy others, etc.)

If this bogus claim can be established - namely that vaping supposedly causes less quitting, then the public health people can argue that vaping is the indirect cause of more deaths.

Now fast-forward to a time when the FDA might be able to reject an application and pull a product off the market (after the window closes). If they were to pull all the vaping products, the ANTZ would say "Hey, we're saving lives, because we're taking away these products that reduce quit rates. Because more quitting means fewer smoking-related premature deaths."

Now if we could beat the argument that someone who smokes one cigaratte a week has the same mortality as someone who smokes 5 PAD, it would be a different situation. But as long as reduced smoking is no better than continued unabated smoking in terms of morbidity (premature death rates), then then the only thing that matters is cessation, right?

Now we have to say that the improved quality of life for dual users (a plus for vaping) must be balanced against reduced quit rates and therefore higher morbidity (which is would be a minus for vaping - if vapers have lower odds of quitting.

That's why I mentioned the whole "de-normalizing" thing. Basically the strategy is to make it a total PITA to smoke tobacco cigarettes. Anything that makes it easier to keep smoking tobacco cigarettes (even at reduced levels) will increase the number of deaths. Therefore all forms of discrimination directed against smokers (such as employment and insurance plus social discrimination), "smoke free" areas (including residences, airports, colleges, industrial parks, etc.), massive taxes, reducing the number of B&Ms, and so forth are all things that make it harder to smoke.

Just keep turning the screws, the pubic health people say, and fewer and fewer smokers will want to put up with the hassle. And the more who quit, the more lives will be saved. Keep jacking up the taxes, keep reducing the number of places where people can smoke. Keep reducing the number of jobs open to smokers. Keep raising their health and life insurance premiums. Keep encouraging nonsmokers to socally eschew smokers. Because then more smokers will quit (instead of just smoking less) and more lives will be saved as a result.

We have lost those arguments. We can no longer win when we argue that public sector jobs shouldn't be closed to smokers (a growing trend). Or that cigarette taxes shouldn't just keep going up. Or that health insurance rates shouldn't be twice or thrice instead of juts 50% more (actually health insurance companies often apply higher rates even to NRT users, unless they're enrolled in an approved cessation program). Or that the number of "smoke free" airports, college campuses, industrial parks, military bases, public parks, and rec. areas, beaches etc. shouldn't be increased. Even apartment buildings (most cities in Marin co. CA now have this rule, I think, and one just applied it vaping).

Why shouldln't the same rules be applied to vaping? We can argue until we're blue in the face that vaping doesn't pose the same risk to bystanders (especially outdoor vaping). But the increased hassles associated with smoking tobacco cigarettes are no longer justified by the degree to which they protect nonsmokers from either health risks or just plain annoyance. They are justified soley by the claim that they reduce the number of smokers - as opposed to the use of cigarettes as such. In other words these hassles allegedly encourage people to quit completely.

So until we can show that vaping helps smokers quit completely, the public heath people will be able to successfully argue that vaping should at the very least be treated like smoking for all these purposes. And if vaping actually reduces quit rates, then vaping leads to less quitting and more dying (premature preventable deaths due to smoking).

Smoking kills. (In the sense of increasing preventable premature deaths.) And if vaping can be shown to reduce quit rates, then vaping kills indirectly via smoking, even if vaping in itself is a completely harmelss activity. Vaping is the "accessory" so-to-speak, not the "culprit" as such. Or the "enabler" if you like.

(There are other arguments too, like the "relapse" argument - vapers are still feeding their 'hand to mouth addiction, and perhaps still using nicotine, so they are supposedly more likely to go back to smoking tobacco cigarettes. And then there's the gateway argument for adults. These are not as common. But I have seen the odd study that claims that vapers who go back to smoking tobacco cigarettes are a net minus for vaping, becuase they might've quit otherwise via "safe and effective means." The adult-gateway argument seems to be mostly dead for some interesting reason, at least I haven't seen it made in a while.)

You will notice that CASAA and vapers generally have been arguing for a long time that anti-vaping bans will just encourage people to "go back to smoking." So this argument is already there. But now, for the first time, we are looking at the possibility that there will be hardly any vaping products left on the US market in four or five years. Perhaps none.

Well, what would be wrong with that - if it saves lifes (by avoiding preventable premature deaths)?

But the reverse is also true. If vapers tend to quit more than the general population of smokers, then making it harder to vape, means there will be fewer quitters and more smokers. Thus there will be more (preventable premature smoking-related) deaths.

 

[Jman8]

Not even Glantz nor even Matt Myers of CFTFK will say that tobacco cigarette smoking kills all tobacco cigarette smokers immediately, as I'm sure you well know. That is quite obviously not what is meant by the phrase "smoking kills." (Were you aware of that? Because if you were, then I have to wonder why you wrote what you just did.)

Thanks for the condescending remarks. I'll take that into consideration in my response.

"Smoking kills" is a sound bite for those with very feeble arguments when it comes to 'prevent smoking.' It's precisely why a minor might smoke, because they realize (immediately) that this meme is deception. Telling anyone under 20 that this product will kill you in your 40's (or later) is not appealing to reason, but to emotion. Idiot adults think minors are little idiots and this will motivate them to think twice about puffing on a smoke. How's that working out for them?

"Smoking kills" has been around for most of my life and has lead to around zero prevention in my research.

I believe the operative phrase is "causal link." In other words, there has to be evidence that there's something about vaping that's currently killing people. What they're saying right now is that the only thing they can pin on vaping is that vapers are less likely to quit smoking than the general propulation of smokers. That was exactly the point of Grana, Popov and Ling's paper in JAMA Internal Medicine published in March. I'm sure we all remember this media frenzy.

The "causal link" is what I feel is disputed or highly questionable. There's a corollary, but cause? Nope.

A corollary will be put forth on 'vaping kills,' and arguably already has been put forth. Just need some old dead vapers to help bring that closer to home. Anti's are patient, they can wait for that inevitable information to come on in. CDC will be right there to tout the (alleged) results.

Please have the discussion with Dr. Siegel, who believes that the mortality rates of smokers are largely independent of how much they smoke: Anti-Smoking Advocate Incorrectly and Irresponsibly Tells Public that Smoking Half Pack Per Day is No Better than Smoking Two Packs Per Day

Either, you don't understand what you are linking to, or you don't understand what you are linking to. How about the excerpt from what you linked to that supports what you are saying Dr. S. believes?

Here's one to chomp on while you are searching for that:

The truth is that Dr. Glantz is simply wrong. He is not a medical doctor and therefore has no personal experience treating patients upon which to draw. As a physician, I can testify to the fact that when smokers substantially reduce the amount that they smoke, they experience immediate and significant health benefits.

***​

I am not conerned about whether anyone is or isn't "thrown under the bus."

Says the person who is throwing people under the bus.

I am looking for the points that give us the best chance of defending vaping in the public policy arena. And the best one I can find is: "Vapers are Quitters."

Then please stop. Just stop being an advocate. You can still be a (righteous) vaper. Or if you want to be an advocate still, then open up and tell the truth rather than answering to Glantz's latest feeble attack. You can make the cessation claims all you desire, but if sticking to myopic logic that de-emphasizes the "experience (of) immediate and significant health benefits" which Dr. S. alluded to, then really you are speaking on a tangent that is pretty much only ANTZ authorized.

You are more than welcome to argue with people like Siegel (see above link) and question every single piece of scientific data that has ever been proffered regarding tobacco cigarette smoking. Far be it from me to stop you. However I do not see this as an effective approach to getting what vapers want and need in the public policy arena.

Given how off base you are with Dr. S. words and with how much you are towing the line of "smoking kills," I am quite certain it is your approach that will be the ineffective one. I have to wonder how you'll behave in a world where "vaping kills" is the new meme from ANTZ? What will be your next pet project for advocacy?

BTW I think we may have reached the point where this discussion is no longer productive. So unless you come up with something that's new, I think I've had enough of this particular debate.

..."except, I may discuss it over the next 5 pages Jman, but you ought not to respond to my righteous points. You got that?"

 

[Jman8]

My bottom line is this - unless we can convince the public and policy makers that there will be fewer deaths, we lose. I don't see a way around that, except perhaps to argue that vaping will not increase deaths and that it will improve the quality of life for dual users. But even there, we have to show that vaping has at least as much cessation as "no vaping."

Your bottom line demonstrates that this path will be ineffective. Everyone dies. Therefore "fewer deaths" will not be something that one can prove. Vapers will die. Anti-vapers will boldly claim that their vaping caused their death, and downplay any notion of 'correlation.' It will be proclaimed as 'causal link.' If sticking with the erroneous logic put forth with 'smoking kills' it will be understood by reasonable people as - these people do not understand causation, nor science. But they do understand propaganda.

 

[Roger_Lafayette]

Your bottom line demonstrates that this path will be ineffective. Everyone dies. Therefore "fewer deaths" will not be something that one can prove. Vapers will die. Anti-vapers will boldly claim that their vaping caused their death, and downplay any notion of 'correlation.' It will be proclaimed as 'causal link.' If sticking with the erroneous logic put forth with 'smoking kills' it will be understood by reasonable people as - these people do not understand causation, nor science. But they do understand propaganda.

Again we are talking about premature deaths from smoking-related illnesses. If the ANTZ develop the concept of vaping-related illnesses, that might be an issue. But so far that hasn't happened.

You can reargue the entire question if you want, by claiming that smoking is harmless or not proven to be harmful. Good luck with that quest.

***

Either, you don't understand what you are linking to, or you don't understand what you are linking to.

From Siegel's blog:

The major problem with Dr. Glantz's argument is that he is considering only smoking-related mortality. The literature he cites deals with mortality only. However, there is more to life than simply its length. The quality of life is also important (although apparently not for smokers, according to Glantz).

Siegel goes on to argue that respiratory morbidity may be improved, but doesn't cite anything. The key issue here is that he is basically conceding the overall morbidity arguemnt to Glantz (because respiratory issues are only one of many "smoking related illnesses").

If vapers have a lower quit rate than the general population of smokers (as Glantz falsely claims) then vapers may die more often from smoking-related illnesses than smokers who do not vape - despite having a higher quality of life than smokers who do not vape.

I.e. vaping leads to more smoking-related deaths, because dual users are less likely to quit than smokers who do not vape. (But of course this is false, which is my point. Vaping leads to cessation.)

What part of that do you dispute?