July 16, 2019
Candice Bowling and our colleagues at UCSF submitted this public comment to FDA's request for information on what the agency should do about cannabis. The Regulations.gov tracking number is 1k3-9b1v-110j. A PDF of the comment is available here.
Scientific Data and Information About Products Containing Cannabis or Cannabis-Derived Compounds; Public Hearing; Request for Comments
Docket No. FDA-2019-N-1482
Candice Bowling JD, MPA, Amy Y. Hafez, PhD, Lauren K. Lempert, JD, MPH, Matthew L. Springer, PhD, Neal L. Benowitz, M.D., Stanton A. Glantz, PhD
University of California San Francisco
June 20, 2019
I am proud that the San Francisco Board of Supervisors voted unanimously to end the sale of e-cigarettes in San Francisco until such time as e-cigarette companies get premarket authorization to sell their products.
The only reason the City had to do this is because the FDA is not doing its job by requiring e-cig companies to obey the law.
Even given FDA's cavalier attitude toward the law (which has been rebuked by a federal court in Maryland), there is nothing that prevented Juul and the other e-cig companies from submitting premarket authorization applications to the FDA three years ago. To date, not a single company has submitted such an application.
Having said that, FDA's recent authorization to sell IQOS in the USA makes me worry about what FDA will do about e-cigs once they do start getting applications. As detailed in an earlier blog post, FDA's standard for allowing new tobacco products to be sold is effectively that they are "not as bad as a cigarette." Just about anything meets that standard.
June 17, 2019
FDA’s April 2019 decision authorizing Philip Morris to market its IQOS heated tobacco product in the United States set a new low bar for establishing that a new tobacco product protects the public health.
Lauren Lempert and I have read the FDA’s 122 page decision document and prepared a detailed analysis of the FDA’s decision (the “Technical Project Lead Review”) for the IQOS PMTA. This analysis raises serious questions over how the FDA assessed the risks and public health impact of IQOS that raise serious questions about how the FDA will handle premarket applications in the future.
Before marketing any new tobacco product in the United States, a manufacturer must submit a premarket tobacco application (PMTA) to FDA. In May 2017, Philip Morris submitted a PMTA seeking an order permitting it to sell its IQOS heated tobacco product in the U.S.
June 17, 2019
On May 15, 2019, a federal court ruled that the FDA was abrogating its responsibility and set aside FDA’s August 2017 Guidance that gave e-cigarette companies until 2022 (and companies selling other newly-deemed combustible products until 2021) to file premarket applications (PMTAs) to sell their products. Another problem with the FDA’s current policy is that it would allow products to remain on the market while the FDA considered their applications, regardless of how long FDA spent thinking about it.
The court gave the health groups and the FDA two weeks to file their suggested remedies.
June 16, 2019
Chris Millett’s research group recently published “Smoke-free legislation and neonatal and infant mortality in Brazil: longitudinal quasi-experimental study” in Tobacco Control Consistent with research conducted in the US and Europe, they found substantial drops in neonatal and infant mortality following implementation of smokefree laws. These are large and immediate benefits that should be promoted when advocating for such laws.
In addition to saving a lot of lives, this saves a lot of money, since the avoided costs are saved immediately. Conversely, continuing to force pregnant women and babies to be exposed to secondhand smoke means more deaths.
Here is the abstract:
Objective To examine the associations of partial and comprehensive smoke-free legislation with neonatal and infant mortality in Brazil using a quasi-experimental study design.
Design Monthly longitudinal (panel) ecological study from January 2000 to December 2016.
Setting All Brazilian municipalities (n=5565).
Participants Infant populations.