E-cigs and other new products should be compared to quitting, not smoking

The public health debate and FDA frame for evaluating e-cigs, heated tobacco products, and other new products has been over whether they were an “off ramp from cigarettes” or whether they were a less dangerous alterative to cigarettes.

That’s not how the tobacco companies think about these products.  They see them as alternatives to quitting entirely.

At the UCSF Tobacco Center’s annual “It’s About a Billion Lives” symposium last week, Professor Dorie Apollonio gave a brilliant history of the industry’s alternative products going back over 100 years, to the invention of the Bonsack cigarette manufacturing machine.

The tobacco companies have known for over 100 years that people were concerned about the health dangers of smoking and working to quit smoking.  All these new products have been developed as an alternative to quitting so that the companies could hold on to customers.

“Harm reduction” and “continuum of risk” ideas were developed as marketing and policy messages to promote these alternatives to quitting completely. 

Rather than the focus on “smokers who cannot or will not quit” that FDA and other public health harm reduction enthusiasts talk about, the industry was concerned about smokers who were likely to quit so they could keep them from quitting completely.

The thing that kept the companies from bringing these new products to market was concern that doing so would trigger FDA regulation of cigarettes.  The 2009 Family Smoking Prevention and Tobacco Control Act solved this problem for the tobacco companies by grandfathering cigarettes and other older products and creating a regulatory framework built on the industry’s harm reduction framing.

Fortunately, the FCPTA framework could be used for effective regulation because it requires that new products be “appropriate for the protection of public health.”  To actually protect public health, the FDA needs to apply this standard the same way that the tobacco companies do: By comparing use of the new products to quitting rather than continued smoking.

Everyone – especially everyone at FDA and other regulatory agencies – should watch Prof. Apollonio’s presentation here.  It starts at I hour 16 minutes and ends at 1 hour 57 minutes.