Tobacco Center Faculty Blog

We just submitted this public comment on California’s Bureau of Medical Cannabis Control’s proposed emergency regulations for legalized medical marijuana sales.   A  PDF of the comment is here.
 
Instructions for submitting public comments on emergency cannabis regulations: https://oal.ca.gov/commenting-on-emergency-cannabis-regulations/.
Link to BCC Notice: http://www.bcc.ca.gov/law_regs/bcc_emerg_rulemaking.pdf
Link to BCC emergency regulations: http://www.bcc.ca.gov/law_regs/bcc_prop_text_reg.pdf
 
 
Comment on Proposed Regulation
 
CALIFORNIA CODE OF REGULATIONS TITLE 16, DIVISION 42
BUREAU OF MEDICAL CANNABIS REGULATION
November 16, 2017
 
Candice Bowling, JD, MPA[i]
Postdoctoral Fellow
 
                                                     Daniel G. Orenstein, JD, MPH[ii]

Last August (2017), the journal addiction published a paper by Jean François  Etter, “Gateway effects and electronic cigarettes,”  that tried to dismiss the very strong and consistent evidence that adolescents who initiate tobacco product use with e-cigarettes are more likely to go on to smoke cigarettes, the so-called “gateway effect.”
 
Much like past tobacco industry efforts to use the Bradford Hill criterial for causal inference to dismiss the evidence linking smoking with lung cancer, Etter came up with something analogous to the industry’s old “constitutional hypothesis” that argued that smokers got lung cancer because there was some genetic factor that both increased the risk of lung cancer can made it more likely that someone would start smoking.  Figure 1 in his paper sums up his position: