More on the FDA ecig workshop
4 June 2015
by Carl V Phillips
Those of you who watched my contribution to the workshop (which you can do by following the link in yesterday’s post) probably found the most memorable observation to be the one about San Francisco. But I am rather prouder of not missing a beat regarding a later question. Leading into that, there was a rambling multi-part question to the panel, which a couple of others responded to bits of. I took the mic last to respond to the phrase “renormalizing smoking” in the question.
I pointed out that this was a silly trope: How could ostentatiously not smoking – sending the signal “I used to smoke but I now think it is a bad idea so I vape instead” – possibly encourage smoking? The moderator, CTP’s Carolyn Dressler, responded that the questioner really meant “renormalize inhaling nicotine”, which I serious doubt is actually true but I ran with it anyway. (I am never quite sure about her, whether she is probing to motivate further scientific discussion, or whether she thinks she can play gotcha games to score debating points for her personal beliefs or CTP policy. I have never noticed her pushing follow-ups on CTP’s pet junk science pseudo-researchers to explain the basis for their unsupported claims.)
So I responded that using low risk tobacco/nicotine products is going to be the new normal, with about half the population doing it, like coffee today and (unfortunately) smoking 50 years ago. I believe I also used the phrase “what’s wrong with that?” After that, someone rushed another question up to her (that someone can handwrite on an index card so fast is impressive) and Dressler moved it to the top of the queue (reprise above parenthetical). It asked why I would want half the population to be addicted to nicotine. I believe it took me only a small fraction of a second to reply that it is not about what we want, but about what people want for themselves.
That is what I am most proud of.
I think it can be a really useful shock to the system for these people to remind them that they are in the business of trying to make the people act contrary to the people’s preferences. It is so embedded in the DNA of public health to not care about people’s preferences that they can get away without thinking about this fact or admitting it to themselves. Putting it in their faces is always good.
I then went on to dispute the trope about “addiction”. I pointed out that by the only official government definition of addiction that I am aware of, from NIDA, smoking does not qualify as addictive. But even if we quasi-define that slippery word to mean “that which is experienced by smokers”, there is no evidence that users of low-risk alternatives experience the same thing, and pretty compelling evidence that they typically do not. I have covered all that thoroughly before, so I don’t have to explain it to my readers. I think I probably should have pushed the point a bit further – for those in the audience who do not read or think – and pose my challenge for anyone to come up with a definition of “addiction” that includes smoking (let along vaping), but that excludes (and not by gerrymandering) eating or wanting to spend time with your kids and that constitutes a seriously bad thing.
Another major response I gave was to a question about how to better communicate the risks to the public. I responded “what risks?” and pointed out that the “perceptions and propaganda” research that had been presented on the previous day clearly showed that people seem to grossly overestimate the risk, and so it must be we should educate them about how low the risks are. I kind of regret not going on to say “I suspect the questioner meant to say вЂ?how can we better trick people into believing the risks are much higher than they are, in order to manipulate them into not vaping in cases where they might rationally choose to do so if they knew the truth?'”
My other regret is not getting to point out that about half the claims by UCSF liar Lauren Dutra, in her presentation on the first day, had been completely debunked in careful analysis following previous occasions that she or Glantz made the same claims, but that she just keeps repeating them anyway. This is the standard practice of tobacco controllers, and anyone who is actually seeking the truth needs to attend to the debunkings rather than listen to the liars. There was just no opening to say that.
And perhaps I had already thoroughly fried them enough for one day. It is probably already the case that they will look for any excuse not allow consumers to be represented again. Of course they are already doing that and I just barely snuck in as the first such representative ever, so this is not really a change. It is pretty clear that they are not going to do it unless some external pressure is applied.
*** FDA response to a question— Note last sentence in first paragraph. [my emphasis there]
And note that definition of “tobacco product” does not cover those cigarettes made with no tobacco but entirely from “tobacco substitute material” (Patent Office’s term for fake tobacco) even though the FDA is working on ALL cigarettes, even though any number of them don’t have any tobacco. If that definition somehow covers nicotine extract, which is added to the industrial waste cellulose used instead of tobacco, that certainly isn’t clear. But cig firms could get nicotine extract from potatoes, eggplant, tomatoes or other members of nightshade family… which would keep that nicotine from being classified as “derived from tobacco”.
Center for Tobacco Products FDA
From:
Sent: Saturday, April 11, 2015 9:23 PM
To: AskCTP
Subject: Import Tobacco Inspections
Are raw tobacco imports into the United States inspected for contamination with banned pesticides?
Is that the job of the FDA, or the USDA, or EPA or other?
Thank you.
From the FDA: [July 17, 2015]
Thank you for your inquiry regarding banned pesticides for tobacco products.
The Federal Food, Drug & Cosmetic Act (FD&C; Act) gives the Food and Drug Administration (FDA) the authority to regulate the manufacturing, marketing, sale, and distribution of tobacco products in the United States. Section 201(rr)(1) of the FD&C; Act defines “tobacco product” as “any product made or derived from tobacco that is intended for human consumption, including any component, part, or accessory of a tobacco product.” At this time, there are no FDA requirements to inspect raw tobacco imports for banned pesticides.
Other statutes and regulations may apply to you and your product. Please visit our website for additional FDA guidance, compliance, and regulatory information: http://www.fda.gov/TobaccoProducts/GuidanceComplianceRegulatoryInformation/default.htm .
You may also sign up for automatic email updates on various topics on our website: http://www.fda.gov/TobaccoProducts/ResourcesforYou/ucm176164.htm
We also recommend that you contact the following agencies for further information:
United States Department of Agriculture (USDA):
http://www.usda.gov/wps/portal/usda/usdahome?navtype=MA&navid;=CONTACT_US
Environmental Protection Agency (EPA):
http://www2.epa.gov/aboutepa/mailing-addresses-and-phone-numbers
U.S. Customs and Border Protection (CBP):
http://www.cbp.gov/contact
If you have additional questions regarding this specific inquiry, please reference the incident ID: IM0607267.
Thank you,
