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:
May 26, 2014
On May 21, 2014 Andrea King and colleagues published a nice experimental study, "Passive exposure to electronic cigarette (e-cigarette) use increases desire for combustible and e-cigarettes in young adult smokers," in Tobacco Control, showing that when young adult smokers saw someone using an e-cigarette it made them want to smoke as much as if they saw someone smoking a cigarette. (The "passive exposure" is watching someone use an ecig during a conversation.)
Seeing an ecigarette being used did not make smokers who did not already use ecigarettes want to use an ecigarette, but did stimulate desire for an ecigarette among ecigarette users. Exposure to to a neutral stimulus (seeing someone drink a bottle of water) did not affect desire for either a cigarette or ecigarette.
May 24, 2014
Wendy Max and Yingning Wang, two economists at UCSF have submitted a public comment on the FDA's regulatory impact (cost-benefit) analysis. Here is a summary from the beginning of their comment:
May 20, 2014
Several people have asked me how to submit comments. It is easy.
1. Go to www.regulations.gov.
2. Type (or cut and paste) FDA-2014-N-0189 into the search box and press "search."
3. This will open the page for the deeming rule docket.
4. Type your comment into the text box or upload any files that you want the FDA to consider (or do both).
5. Fill in your name and the other identifying information that is requested and click the button to submit the comment.