DOT should prohibit use of e-cigs on airplanes (our public comment)

Here is the public comment we just submitted supporting a US Department of Transportation proposal to prohibit use of e-cgarettes on airplanes. The comment period ends on Monday; I urge everyone to submit comments at the website below.

November 12, 2011

Docket Management Facility
US Department of Transportation
1200 New Jersey Ave., SE
Room W12-140
Washington, DC 20590-0001
http://www.regulations.gov/#!submitComment;D=DOT-OST-2011-0044-0003

RE: Docket No. DOT-OST-2011-0044 Smoking of Electronic Cigarettes on Aircraft

  Gentlemen and Ladies:

We support the prohibition of using electronic cigarettes (e-cigarettes) on aircraft. E-cigarettes are unregulated nicotine delivery devices that emit an unknown mixture of chemicals into the air. Use on an aircraft would increase the level or air pollution inside the aircraft cabin and subject passengers and flight crew to the toxic chemicals in the exhaled “vapor.”

The e-cigarette companies claim that the complex mixture of chemicals emitted is “water vapor.” Blu, an e-cigarette company, claims on their website that the white “smoke” e-cigarette smokers depicted in an aircraft cabin emit contains, “No second hand smoke only water vapor.”  (See image from the www.bluecigs.comhome page, accessed November 10, 2011.) Another retailer, The Safe Cig, claims, “Our vapor is so clean that you can exhale directly into a tissue or paper towel and not see or smell a thing!” (www.thesafecig.com).

There has been no independent scientific validation of these claims. xxx   In contrast, studies by the U.S. Food and Drug Administration scientists found that there are substances other than water contained in the vapor (FDA, 2009; Trehy et al., 2011). In a summary report of e-cigarette analyses released by FDA on their website, the products contained tobacco specific nitrosamines (NNN, NNK, NAT, NAB) that are carcinogenic, diethylene glycol, and propylene glycol.  Though few studies exist on the effects of inhaling propylene glycol, it is at minimum a mild irritant to the human respiratory tract (Sciencelab, Inc., 2010). Nicotine and related compounds, such as B-nicotyrine, anabasine, and myosmine are also present in the products (FDA, 2009; Flouris and Oikonomou, 2010; Trehy et al., 2011).  Nicotine is a neurotoxin (Abreu-Villaca et al., 2003) used as an insecticide (American Lung Association, nd).

There is no evidence that all these toxins are absorbed by the smoker.  In considering whether or not to allow this pollution source in the confined airspace of an airline cabin, the DOT should assume that at least some of these toxic chemicals will be emitted into the cabin airspace.  It would also be important for DOT to have data that these emissions are safe when emitted into the low pressure, low humidity environment of airliner cabins where the same air is re-circulated throughout the duration of the flight (Committee on Airliner Cabin Air Quality, 1986).

There is also concern about possible contamination from the nicotine solution used in e-cigarettes (Cobb et al., 2010). Some of these devices are refillable, raising the possibility of spillage of the concentrated nicotine solution used to fill e-cigarettes.  Nicotine fluid ingested or absorbed transdermally from a spill or leak could be fatal to a child (Yamin et al., 2010). Indeed, for this reason, the nicotine fluid may be in violation of TSA regulations prohibit bringing disabling chemicals on airplanes (TSA: Prohibited Items).

These concerns are heightened by the facts that these potentially toxic products are not regulated by any federal agency at this time and that there is evidence of poor quality control (Flouris and Oikonomou, 2010), meaning that there may be other chemicals emitted into the air. 

In addition, DOT must seriously consider the nuisance factor seriously.  Passengers and flight crew are in close proximity and many may object to being subjected to the vapor (and any associated odors) displayed in the image above from the Blu e-cigarette website.

In sum, the use of these products on aircraft has the potential to endanger the safety and health of airline passengers and employees. Research independent of the companies that manufacture and sell these products (and their associated advocacy organizations) is needed on the safety of the products and the effects of the vapor users emit specifically in the airliner cabin environment before DOT should even consider allowing e-cigarettes in enclosed aircraft cabins.

Until that independent evidence base is developed, DOT should to continue to preserve a smokefree aircraft environment on all flights.

Thank you for considering this comment.

Stanton A. Glantz, PhD
Professor of Medicine

Amanda Fallin, PhD RN
Postdoctoral Fellow

Rachel Grana, PhD MPH
Postdoctoral Fellow

References

Abreu-Villaca, Y, Seidler, F, Tate, C. & Slotkin, T. (2003). Nicotine is a neurotoxin in the adolescent brain: critical periods, patterns of exposure, regional selectivity, and dose thresholds for macromolecular alterations. Brain Res., 979(1-2): 114-28.

American Lung Association. (nd). What’s in a cigarette? http://www.lungusa.org/stop-smoking/about-smoking/facts-figures/whats-in-a-cigarette.htmlLast Accessed: November 11, 2011.

Blu. http://www.blucigs.com/customer-service#faq  Last Accessed: November 10, 2011

Cobb, N., Byron, M., Abrams, D. & Shields, P. (2010). Novel nicotine delivery systems and public health: The rise of the “e-cigarette”. American Journal of Public Health, 100(12), 2340-2342.

Committee on Airliner Cabin Air Quality. 1986. The Airliner Cabin Environment: Air Quality and Safety. National Academy Press: Washington, DC.

Flouris AD, Oikonomou DN. Electronic cigarettes: miracle or menace? BMJ. 2010;340.

Sciencelab, Inc. “Material Safety Data Sheet for Propylene Glycol.” http://www.sciencelab.com/msds.php?msdsId=9927239 Last Accessed: November 10, 2011

The Safe Cig. http://www.thesafecig.com/faq  Last Accessed: November 10, 2011

Transportation Security Administration. Prohibited Items. http://www.tsa.gov/travelers/airtravel/prohibited/permitted-prohibited-items.shtm#9 Last Accessed: November 10, 2011

Trehy ML, Ye W, Hadwiger ME, et al. Analysis of electronic cigarette cartridges, refill solutions, and smoke for nicotine and nicotine related impurities. Journal of Liquid Chromatography & Related Technologies. 2011;34(14):1442-1458.

U.S. Food and Drug Administration (FDA). July 22, 2009. “Summary of Results: Laboratory Analysis of Electronic Cigarettes Conducted by FDA” http://www.fda.gov/NewsEvents/PublicHealthFocus/ucm173146.htm Last Accessed: November 10, 2011

Yamin CK, Bitton A, Bates DW. E-cigarettes: a rapidly growing internet phenomenon. Annals of internal medicine. 2010;153(9):607.