Submitted to FDA deeming docket: E-Cigarette Makers Are in an Arms Race for Exotic Vapor Flavors

July 23, 2014
 
Docket No. FDA-2014-N-0189
 
On July 15, 2014, the New York Times published the attached article, "E-Cigarette Makers Are in an Arms Race for Exotic Vapor Flavors," that documents the importance of flavored e-cigarettes, particularly in attracting youth to the use of nicotine.
 
The FDA should seriously consider this information, particularly the change in NJOY's assessment of the effects of flavors on youth between when it was not using flavors to when it decided to start using flavors to maintain its market share, and prohibit the use of flavors in e-cigarettes as part of the current rulemaking (and not delay action to a subsequent rule making).
 
The e-cigarette companies state that flavors are important for attracting not only youth but also adults to their products.  The FDA needs to resist the urge to focus entirely on youth and consider these effects on adults, because the Family Smoking Prevention and Tobacco Control Act requires the FDA to apply a population public health standard to the entire population not just to youth.
 
Stanton A. Glantz, PhD
Professor and Director
 
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