Tuesday, November 25, 2014

CASAA Comment to FDA regarding Swedish Match's Modified Risk Tobacco Product (MRTP) Applications

To:       U.S. Food and Drug Administration

From:  Carl V Phillips, PhD
            Chief Scientific Officer
            The Consumer Advocates for Smoke-free Alternatives Association (CASAA)

25 November 2014

VIA regulations.gov
Comment Tracking Number: 1jy-8fp5-yhfe

Re:     CASAA comments on Swedish Match MRTP application
           (Docket No. FDA-2014-N-1051)

1.      Introduction

This comment on Docket No. FDA-2014-N-1051, Swedish Match’s (SM’s) Modified Risk Tobacco Product (MRTP) application is submitted on behalf of The Consumer Advocates for Smoke-free Alternatives Association (CASAA). CASAA is a public health and education NGO. It is a 501(c)4 nonprofit membership organization that serves as the leading representative of consumers who use or might in the future use smoke-free tobacco/nicotine products. CASAA is not an industry group and does not represent the interests of industry. CASAA did not confer with Swedish Match or other industry representatives when creating this comment.

First, we wish to note that we heartily endorse the acceptance of SM’s application. It would benefit the public, who FDA and the rest of our government are charged with operating on behalf of, particularly by improving the public’s overall health. It would reduce a persistent problem of the government grossly misrepresenting risks to the public about this category of products. We can see no apparent downside for consumers or society as a whole in FDA granting SM’s application. The only apparent downsides are for two special interest groups: those who wish to keep consumers smoking because they have a financial interest in cigarette sales, or those who are pursuing tobacco prohibition and know that those goals will be unattainable if consumers have accurate information about low-risk products.

There is little chance we could add any research material to SM’s encyclopedic application, and so we will not attempt to do so. Instead we will highlight some key summary points and address some public-interest and ethical issues that fall outside of what SM emphasized in their application.

Friday, November 21, 2014

Call to Action! Madison Wisconsin E-cigarette Use Ban

This Call to Action will be updated as we receive more information about upcoming meetings and public hearings.

UPDATE 11/24/14
Next Board of Parks Commissioners meeting is December 10, 2014 at 6:30 PM at the Warner Park Community Recreation Center: 1625 Northport Dr, Madison, WI 53704

The ordinance is listed for discussion on the agenda: Click here to view

Next Madison-Dane County Board of Health meeting is December 17, 2014 at 5:30 PM (place TBD.) The agenda has not been posted yet, but will appear here: Click to view

The public is welcome (and strongly encouragd) to attend these meetings and address the lawmakers with their concerns and comments. Arrive early to sign up on the registration form to speak.

The City of Madison is poised to deceptively define smoke-free e-cigarette use as "smoking."  The justification written into the proposed law makes misleading, false and/or unproven scientific claims about "ultra-fine particles" and "volitile organic compounds."

The first reading was on November 18, 2014 and has been referred to the Board of Park Commissioners and the Madison-Dane Board of Health .

This ordinance will prohibit the use of e-cigarettes in all places where conventional smoking is prohibited. This includes businesses that wish to cater to e-cigarette consumers and retailers that need to allow customers to try samples. The same proposed ordinance also extends the prohibited areas to include Madison parks and beaches, which would also apply to vaping.

Because 10 alders have sponsored this ordinance (see sponsor list below), they only need just one more vote for this ordinance to pass. We strongly recommend members first focus efforts contacting the lawmakers who are not already on board with this proposal, to convince them not to vote in favor. However, be sure to also contact the sponsors to let them know how you disapprove of their decision to support this ordinance.

Thursday, November 13, 2014

CASAA Makes a Donation to Help Preserve Consumer Access to E-Cigarettes in Western Australia

Consumers in Western Australia are facing a particularly difficult situation now that the Supreme Court of Western Australia has ruled that the sale of e-cigarettes violates the provisions of Section 106a of the Tobacco Products Control Act, an act designed to outlaw the sale of candy cigarettes. Even more inexplicable, the devices that were the subject of the legal action were not cigalikes and did not contain nicotine.
To help preserve consumer access to e-cigarettes in Western Australia, CASAA has made a donation of $500 to help fund the legal battle to keep e-cigarettes available to consumers in Western Australia.
While CASAA is a U.S. organization, we recognize that we are a part of a global community. We remain focused on our U.S. efforts, but we realize the importance of established organizations reaching out to assist with efforts in other countries when we can help make a difference.

The following website provides details about not only the court action, but also information about the trust fund and safeguards put in place to protect contributions towards this effort: http://www.gofundme.com/Ecigs-Our-Right-to-Choose

Saturday, November 8, 2014

Call to Action Baltimore, MD - Indoor Use Ban

A second hearing was held this week on Wednesday, 11/5.  It is our understanding that an amendment to the bill has been submitted and recommended favorably by the committee that would allow the use of electronic cigarettes in dedicated vapor retail shops.  The proposed amendment also stipulates that restaurants and bars would be able to allow vaping inside as long as proper signage is displayed informing patrons that e-cigarettes may be in use on the property.
While the amended version is obviously better than the original (which would have banned e-cigarette use wherever smoking is prohibited and which original version is still possibly under consideration by the City Council), it should be pointed out that the proposed ordinance (as amended) would unjustifiably prohibit the use of e-cigarettes in thousands of other workplaces and indoor areas within Baltimore City.
A “Second Reader” has been scheduled for Monday, November 10th, 2014 at 5:00 PM before the full city council.  The hearing will be held in the Du Burns Council Chamber, 4th floor, City Hall.  We encourage you to continue participating in the legislative process by contacting your officials and voicing your opinion on this ordinance (and the amendment).  The full list of Baltimore City Councilmembers and their contact information can be found here.

Comma delimited list of the members of the Baltimore City Council:

helen.holton@baltimorecity.gov, william.welch@baltimorecity.gov, edward.reisinger@baltimorecity.gov, eric.costello@baltimorecity.gov, carl.stokes@baltimorecity.gov, warren.branch@baltimorecity.gov, marypat.clarke@baltimorecity.gov, councilpresident@baltimorecity.gov, james.kraft@baltimorecity.gov, brandon.scott@baltimorecity.gov, robert.curran@baltimorecity.gov, bill.henry@baltimorecity.gov, rochelle.spector@baltimorecity.gov, sharon.middleton@baltimorecity.gov, nick.mosby@baltimorecity.gov

Friday, October 31, 2014

How CASAA Members Can Help

Members often tell us they don't have a lot of time or money, but they want to help. The main thing CASAA needs is members getting our information out to the public and recruiting new members. Below is a list of things that only cost you a little time and effort. CASAA needs members to do these things more than ever. Without your involvement, CASAA cannot succeed!


If you haven't yet, make sure you've joined CASAA by using the form at Become A Member. It's quick and it's free!

Call to Action: Philadelphia is Considering a $2.00 Tax E-Cigarettes and and $.50/ml Tax on E-Liquids

By now, every vaper in SE Pennsylvania should know about Philadelphia Councilwoman Brown’s proposal to impose a burdensome tax on vapor products. The proposal is being presented as a necessary measure to partially shore up an astonishing gap in the city’s budget for public schools. (Apparently, this is a new twist on “Think of the children.”)

Brown’s proposal, if passed, would mean a $2.00 tax on devices and $0.50/ml tax (up to $5.00) on liquids. Although some may be tempted to view this tax as a “bake sale” for public schools, at its core, the proposal is predatory and short sighted. The fact remains that Councilwoman Brown sees an opportunity to exploit an emerging market with potentially devastating consequences to consumers and businesses in Philadelphia.

Simply stated, if this proposal passes, brick and mortar shops in Philadelphia will not be able to be competitive, and Philadelphia consumers will lose a valuable resource. Local vape shops are not simply a convenience for consumers.  They provide a hub for social gatherings, expert information and help in making the transition from smoking to vaping, and a place for people to try different devices and liquids prior to purchase.

October 31, 2014:  Please note that for now, participation in this Call to Action is limited to people who have an address in Philadelphia.  We expect to expand participation to a broader geographic area next week, and will update this Call to Action when we've done so.

Wednesday, October 29, 2014

Make Your Voice Heard: You Vape - You Vote

You Vape - You Vote!

Election day is less than a week away, and we encourage vapers everywhere to take some time to become more informed about the candidates and their positions on issues that are important to you, including stances on e-cigarettes are other low-risk alternatives to smoking. And, most importantly, make your voice heard by exercising your right to vote.

Tuesday, October 7, 2014

Call to Action: New York City is Considering Banning the Sale of Flavored E-Cigarettes and E-Liquids

On October 7, 2014, Councilman Constantinides introduced an ordinance that would ban the sale of flavored e-cigarettes and flavored e-liquids in the five boroughs. As is often the case, flavor bans like this are poorly researched and fail to account for the fact that practically ALL e-liquid is “flavored”. Furthermore, this ordinance fails to carve out an exemption for dedicated vapor shops, allowing sales by tobacco bars only.

In short, this would mean the end of vapor sales in New York City as we know it.  The ordinance has been referred to the Committee on Health, and it is possible (if not likely) that this proposed ordinance will be heard in committee on Thursday, October 23, 2014.  Tri-State area advocates are strongly encouraged to plan to attend. (We will update this Call to Action as additional information becomes available.)

We are asking advocates in the Tri-State area to please contact NYC council members on the Health Committee and thoughtfully express your opposition to this ordinance.

NYC residents can follow the link below to find your council members and contact them directly as well: http://council.nyc.gov/html/members/members.shtml

Residents are encouraged to call and meet with their council members.  Please feel free to contact board@casaa.org for tips and guidence with talking to lawmakers.

Please share this Call to Action with anyone you know who lives or works in New York City.  In fact, share this with anyone you know who might feel inclined to visit the city.  

Participation in this Call to Action is NOT limited to residents of New York City, but if you are not a resident, please edit the letter to share what relationship you may have with New York City (for example, you have family or friends who live there, you plan on visiting, et cetera).

Also, please note that the CQRC campaign sometimes glitches and resets, and, if so, you may lose any edits you make to your email. If you are editing the email, you should consider editing the letter in a word processing program and then copying the final product into the CQRC program.

Wednesday, October 1, 2014

CASAA Welcomes Brad Rodu and Igor Burstyn to its Leadership

CASAA is delighted to announce that Professors Brad Rodu and Igor Burstyn have joined its Board of Directors. Anyone interested in CASAA will be familiar with them and their work, but by way of brief introduction:

Brad Rodu is Endowed Chair in Tobacco Harm Reduction Research at the University of Louisville’s James Graham Brown Cancer Center. He has been working on tobacco harm reduction advocacy longer than anyone else, dating back to his landmark 1994 paper in Nature, and has produced an enormous corpus of research studies and other analysis on the topic. He is widely considered the father of the tobacco harm reduction movement.

Igor Burstyn is Associate Professor of Environmental and Occupational Health at the Drexel University School of Public Health. He is an expert in environmental health and research methodology, and has been interested in tobacco harm reduction for almost ten years. His most notable contribution in the field was his systematic review of e-cigarette chemical exposure, which was sponsored by CASAA in 2013.

We cannot imagine better additions to the CASAA leadership than Drs. Rodu and Burstyn.

As part of this reorganization, Carl V Phillips has left the Board of Directors and now serves as CASAA’s Chief Scientific Officer (a cosmetic change of titles from “Scientific Director” to avoid confusion). Don’t worry -- Dr. Phillips’s contributions to CASAA’s work will remain almost unchanged. Upon his departure from the Board, CASAA began paying Phillips a token sum as a consultant. We felt that it was inappropriate to continue to take so much of the time of a top professional in the field without some compensation. While CASAA is unable to pay him or any other member of the leadership what they really deserve for all their hard and valuable work, this is something.

We are certain that those who remember CASAA’s modest origins are excited to see how CASAA has grown, not only in terms of its leadership, but also in terms of its membership, reach, and substantive work. The addition of these two top researchers will further enhance CASAA’s ability to advocate for THR and the consumers who depend on these potentially life-saving alternatives to smoking.

Thursday, September 18, 2014

International Call to Action! Celebrate World Vaping Day by Telling the World Health Organization How E-Cigarettes Have Changed Your Life.

Today, September 18, 2014, is World Vaping Day. We can think of no better way of celebrating World Vaping Day than by sharing our success stories with the World Health Organization (WHO).   

WHO is, to put it mildly, anti e-cigarette and has called for strict regulation of e-cigarettes, including a ban on e-cigarette use in public places. It sees e-cigarettes as challenging the core message of tobacco control and as a threat to WHO's goals of a tobacco-free world.  WHO seems willing to embrace speculative and unsubstantiated concerns about e-cigarettes (including the increasingly discredited gateway theory, namely, that e-cigarette use will lead to non-smokers starting to smoke), but fails to give any weight to the fact that an ever-increasing number of people  have quit smoking (or have substantially reduced their smoking) by using e-cigarettes.  

According to the WHO, we are anecdotes.

And so today, on World Vaping Day, we are asking vapers from across the world to join together in sending a personal message to WHO.  Tell your story and explain how e-cigarette use has changed your life.  Let them know that we are real people, not anecdotes.  (While this Call to Action is being released on World Vaping Day, it will continue indefinitely.)