June 1, 2014
On June 2, 2014, Reuters published a long article about the FDA's application of a 70% consumer surplus discount to account for the "lost pleasure" due to any health benefits generated by the proposed deeming rule because people smoke less. (The FDA had discounted the health benefits of its failed warning labels by 50%.)
Not a single outside economist Reuters contacted supported the FDA's decision, including several conservative economists and Jonathan Gruber, whose work the FDA quoted to justify what it did.
Here is what they said:
John Graham, who headed the White House Office of Information and Regulatory Affairs, which vets agencies' cost-benefit analyses, under President George W. Bush, said he could "not recall a specific instance" during his 2001-to-2006 tenure "where lost enjoyment played a significant analytical role."
Loss of pleasure had occasionally been used when analyzing proposals to ban products, Graham said, but was not treated as a deduction from benefits, as the FDA is doing.
Lorillard (maker of Blu ecigs) tells parents ecigs just emit "harmless water vapor;" that's not true
May 31, 2014
On April 23, 2014, Lorillard, makers of Blu e-cigs, posted a statement on its Youth Smoking Prevention Program website, "Real Parents Real Questions" website that tells parents
"The 'smoke' you see coming out of e-cigarettes isn't smoke -- its WATER VAPOR."
Needless to say, there are many other things in e-cigarette emissions, including ultrafine particles and 9 chemicals on the California Proposition 65 list of known carcinogens and reproductive toxins. Also see our peer reviewed paper summarizing the scientific literature on e-cigarettes.
In case Lorillard decides to change this page, here is a PDF of what it said on May 31, 2014.
May 31, 2014
I just submitted this public comment on the FDA deeming rule (comment number 1jy-8cep-qnbg):
LORILLARD TOBACCO ADMITS THAT FLAVORED E-CIGARETTES ATTRACT YOUTH; FDA SHOULD USE THIS INFORMATION TO PROHIBIT FLAVORS AS PART OF THE CURRENT RULEMAKING
Docket No. FDA-2014-N-0189
May 31, 2014
On April 23, 2014, Lorillard Inc.'s Youth Smoking Prevention Program posted a page on e-cigarettes on its "Real Parents Real Questions" website[1] that stated:
- "Kids may be particularly vulnerable to trying e-cigarettes due to an abundance of fun flavors such as cherry, vanilla, pina-colada and berry."
It also stated:
May 29, 2014
Anna Song, a professor of psychology, Paul Brown, a professor of economics, and I have submitted a public comment detailing why the FDA's decision to discount the health benefits of regulating ecigs, cigars, and other tobacco products by 70% is inconsistent with a large body of scientific evidence.
The FDA's argument for doing so in the "Regulatory Impact Analysis" is also logically inconsistent with the scientific evidence that the FDA itself presents in the body of the deeming rule.
Our public comment is 22 pages long, so I am not including the whole thing in this blog post; you can read the whole comment here.
This is the introduction and summary of the comment: