Sirs,

Currently there are members of the Senate that are pushing the FDA to announce regulation of Electronic Cigarettes. This is of great concern to me as I used an Electronic Cigarette to quit tobacco cigarettes after 30 years of smoking so I offer my opinion on all aspects of this issue below.

TAXES

The purpose of increasing cigarette tax rates was to reimburse state expenditures for treating the many diseases caused by cigarette smoking. Because smokeless tobacco products have been found to be around 99% less harmful than cigarettes, there is no justification for such an outrageously excessive tax, which would discourage smokers from switching to a less harmful alternative. E-Cigarettes have been proven magnitudes safer than tobacco cigarettes as the links to scientific studies provided below will show. The public health benefits and savings from using e-cigarettes will be immense at a cost of Zero tax payer dollars!.

THE PUBLIC HEALTH AND PERSONAL HEALTH

While I agree there should be restrictions on sales to minors I believe that’s as far as the regulations should go. These devices are a potential public health miracle.

“Nicotine itself is not a particularly hazardous drug,” says Professor John Britton, who leads the tobacco advisory group for the Royal College of Physicians. “It’s something on a par with the effects you get from caffeine. If all the smokers in Britain stopped smoking cigarettes and started smoking e-cigarettes we would save 5 million deaths in people who are alive today. It’s a massive potential public health prize.”

This is 5 million lives saved in the UK alone by Electronic Cigarettes.

Clive Bates, the former head of  the anti-tobacco group ASH (Action on smoking and health) (www.clivebates.com) says

“If these products are to be banned or over-regulated, then a very serious problem arises: why should a health treaty deny a person addicted to nicotine access to products that greatly reduce their risk of disease?  There are no precedents for banning or marginalizing safer alternatives to a harmful market leader (cigarettes in this case) and it is absolutely unethical to do so.  The further danger of bans or excessive regulation of low risk, non-combustible nicotine sources is that they protect the cigarette market. It would be a terrible failing if it was unwittingly doing the dirty work of the cigarette industry.”

There are arguments from public health officials that we don’t know what is in the liquid these devices use. This is just an outright lie, there are many studies performed and ongoing that ALL show that Electronic Cigarettes are magnitudes safer than Tobacco Cigarettes.

a. Here is a list of the Top 10 studies on Electronic Cigarettes for your reference.

http://www.stevevape.com/top-10-studies-on-e-cigs-you-need-to-know-about/

b. Here is a study of the chemical constituents on 12 brands of Electronic Cigarette liquid showing they are much safer than cigarettes.

http://tobaccoanalysis.blogspot.com/2013/03/new-study-of-electronic-cigarette-vapor.html

c. Here is an ongoing study by Dr Konstantinos Farsalinos in Greece on the effect of e-cigarette vapor on heart cells - The results show so far that cells cultured with Tobacco Smoke had a viability rate of  3.9% (or 96% died) whereas cells cultured with Electronic Cigarette vapor had a viability rate above 100% (or the cells continued to multiply indicating ZERO ill-effect from Electronic Cigarette vapor).

http://www.ecigarette-research.com/web/index.php/research/cyotoxic-effects-of-electronic-cigarette-vapor-extract-on-cultured-myocardial-cells

Beyond an age restriction on sales, Electronic Cigarettes should be left to SAVE LIVES, they are a miracle consumer product, magnitudes safer than the Tobacco alternative and much more safe and effective than the pharmaceutical prescription drug options that have over a 90% failure rate and a tendency to kill people!.

Pfizer’s Chantix warning states: “Serious neuropsychiatric events including, but not limited to, depression, suicidal ideation, suicide attempt, and completed suicide have been reported in patients taking CHANTIX.”

In the very next paragraph, the warning reiterates that: “worsening of pre-existing psychiatric illness and completed suicide…have been reported in some patients attempting to quit smoking while taking CHANTIX in the postmarketing experience.”

There are currently 100’s of reports of Chantix related suicides.

On the other hand the Palosa study of smokers that were unwilling to quit shows that by merely being introduced to an Electronic Cigarette

“Electronic Cigarettes attained a Sustained 50% reduction in the number of cig/day at week-24 was shown in 13/40(32.5%) participants; their median of 25 cigs/day decreasing to 6 cigs/day (p < 0.001). Sustained 80% reduction was shown in 5/40(12.5%) participants; their median of 30 cigs/day decreasing to 3 cigs/day (p = 0.043). Sustained smoking abstinence at week-24 was observed in 9/40(22.5%) participants, with 6/9 still using the e-Cigarette by the end of the study. Combined sustained 50% reduction and smoking abstinence was shown in 22/40 (55%) participants, with an overall 88% fall in cigs/day.

Mouth (20.6%) and throat (32.4%) irritation, and dry cough (32.4%) were common, but diminished substantially by week-24. Overall, 2 to 3 cartridges/day were used throughout the study. Participants’ perception and acceptance of the product was good.

Conclusion

The use of e-Cigarette substantially decreased cigarette consumption without causing significant side effects in smokers not intending to quit

(http://ClinicalTrials.gov webcite number NCT01195597).”

That’s 22.5% of people that were “unwilling to quit smoking” that inadvertently quit smoking just by using an Electronic Cigarette!… An overall 88% reduction in Tobacco consumption in users that had no intention of quitting!, HOW IS THIS A BAD THING FOR THE PUBLIC HEALTH?

It is worth noting that at the same time that the FDA is using misinformation to downplay the risks of Chantix, it is using similarly deceptive techniques to exaggerate the risks of electronic cigarettes. The FDA has informed the public that electronic cigarettes pose a carcinogenic risk, as it contains “known carcinogens.”  They failed to mention that the carcinogens are in such low levels so as to pose no risk to the user, in most cases at lower levels than FDA approved smoking cessation products such as Nicorette. So while the FDA is hiding the fact that Chantix has actually been associated with more than 300 deaths, it is suggesting to the public that electronic cigarettes may cause cancer, despite the absence of a single death associated with these products. 

All evidence currently points to e-cigarettes being magnitudes safer than their tobacco alternative. It makes no sense from a public health standpoint to regulate or tax people back to regular tobacco cigarettes when they’ve made a choice to prolong their own lives by switching to a reduced harm option. Since starting Electronic Cigarettes over 12 months ago my  blood pressure is now 118/79 and my GP is supportive of the switch. 

MEDICAL DEVICE REGULATION.

This has to be the worst idea being floated. Ingesting nicotine isn’t a disease, it doesn’t need to be cured. Vaping doesn’t cause disease that needs to be cured!. Naturally the big tobacco companies and Big Pharma love the idea of regulating Electronic Cigarettes as a medical devices, it protects their business from competition. Only Big Tobacco and Big Pharma would be able to afford to make these devices if this standard is adopted. Never mind that they are both responsible for more deaths due to their products than Electronic Cigarettes ever will be!. Big Tobacco is also writing and sponsoring bills at the local level to ban online sales of Electronic Cigarettes and accessories. I hope everyone is smart enough to see through this blatant ploy to eliminate competition and thus protect their own business model and distribution chain. The fact is, Electronic Cigarettes are already regulated as Consumer Devices. The electronic components have to comply with CE regulations and the liquids use common food products and Nicotine that are already approved by the FDA. No further FDA regulation is necessary.

SAFETY IN MANUFACTURING

The industry itself has already imposed a “Vaping age restriction” of 18. The liquid industry has created its own regulatory standards for Responsibility, Standards, Testing, Tracking and Packaging, (AESMA) http://www.aemsa.org/ is an example. Most of the electronic devices themselves are of excellent quality. We vapers know which ones to avoid and which companies “self-regulate” from a safety standpoint. Primarily its the independent companies that have adopted these self-regulatory practices while the larger companies (Blu, N-Joy etc) have not. For Example, Blu uses Johnson Creek e-juice while Johnson Creek are not a member of AESMA.

FLAVORINGS

I have read anti-nicotine groups concerns about flavoring, that it attracts children and acts as a gateway to smoking, yet in all their “studies” they are unable to find even one single example of this. It is completely unsupported by real evidence.

http://tobaccoanalysis.blogspot.co.uk/2013/01/new-study-on-electronic-cigarette-use.html

A study by “Action on Smoking and Health” (anti-tobacco group) that shows no evidence of the use of E-Cigarettes by children or as a gateway device for children.

http://www.ash.org.uk/files/documents/ASH_891.pdf

They say adults don’t use these flavors, which again is completely untrue. Every “Vaper” I know avoids Tobacco flavored Electronic Cigarettes simply because they don’t want the reminder of tobacco, they merely want their nicotine in a safer way. I personally use “Candy Cane”, “Black Licorice” “Mint chocolate chip” “white chocolate raspberry” and numerous other flavors that I enjoy and that keep me from returning to Tobacco Cigarettes. I am 43.

I haven’t even touched on the community of “Vapers” that has sprung up, a user support system that is doing more for the public health than the Government has ever done without a single tax payer dollar having been spent.

In conclusion, I implore you, I beg you, do not allow this life saving product to be over-regulated, over-taxed or banned thus forcing people back to deadly tobacco. All evidence and studies show that these products have the potential to eradicate Tobacco Smoking and Tobacco related disease in 10 years if left alone to do what they do best, SAVE LIVES.

Sincerely