Thursday, July 6, 2017

Comment on FDA's unreasonable smokeless tobacco rule - DUE by July 10th!

The deadline for commenting on an FDA rule regarding product standards for smokeless tobacco (ST) is Monday, July 10th, 2017.

By way of background, the FDA published a rule for public comment on January 23, 2017 regarding a proposed standard for N-nitrosonornicotine (NNN) levels in ST products. The proposed limit for NNN concentration would be 1ppm of dry weight. Although some products do exist that would meet this arbitrary standard, the vast majority range somewhere between 1ppm and 10ppm.

Imposing a cap on NNN concentration at 1ppm of dry weight would:
  • Not result in a significant risk reduction. Any reduction in risk associated with forcing NNN levels to be reduced is likely to be zero and will be more than offset by the cost to consumers of limiting choice and destroying the diversity in the marketplace of these already incredibly low-risk products.
  • Set an unreasonable standard that most products--even if they were reformulated--would not be able to meet. Much like the PMTA issue with e-cigarettes, this would be a de facto ban on most ST products sold in the United States.
  • Reduce consumer access to the lowest risk tobacco products on the market today. This will have the effect of forcing U.S. consumers to shop overseas (increasing their cost), and for many, may cause them to replace their smokeless habit with smoking.

Take action NOW - Submit a comment!

Choose some points below to add to your comment:
  • Do you use smokeless tobacco as a form of tobacco harm reduction?
    • Do you use smokeless tobacco instead of smoking, or did you quit smoking by switching to smokeless tobacco?
    • Do you use smokeless tobacco in places where you cannot vape?
  • How important is the variety of smokeless tobacco products to you?
    • Are you “brand loyal” or do you benefit from being able to use different types of smokeless tobacco?
    • Do you know if your preferred brand will be able to meet this 1ppm of dry weight standard? (see this chart for reference)
  • What will you do if you are unable to purchase smokeless tobacco in the United States?
    • Do you think you would return to smoking?
    • Will you shop online, overseas?
  • For more information:
    • Comment from Reason Foundation here.
    • Dr. Brad Rodu provides background and insights here, with links to other comments on the rule.
    • Dr. Carl Phillips has provided an in-depth analysis in a three part series here, here, and here.

* You are commenting on a publicly viewable docket on Any personal information you provide in your comment will be publicly available. The information you provide to CASAA in order to complete this engagement will not appear on

Saturday, May 20, 2017

San Francisco, CA - Local Alert - Help us stop the flavor ban!

(Update - 05.20.17)
CASAA has received word that the flavor ban ordinance will be on the calendar for

Wednesday, June 14th, 2017
10:30 AM

For the May 24th meeting, this ordinance (170441) is on the agenda under the “30 day rule” section. This means that the legislation will not be considered and no action will be taken at this meeting.

That being the case, NOW is the time to prepare your remarks AND make contact with members of the public safety committee.

Take Action - Send a Message!

(Original Post - 05.18.17)
San Francisco Supervisor, Malia Cohen is introducing an ordinance that would ban the sale of flavored tobacco and vapor products. The first opportunity for this ordinance to be heard in committee will be on
Wednesday, May 24th, 2017
10:30 AM
Public Safety and Neighborhood Services Committee

We need to stress that this is not a confirmed hearing and we will provide an update with any change. At this time, Supervisor Cohen’s flavor ban is not on a posted agenda.

In advance of a hearing, NOW is the time to reach out to city supervisors and urge them to oppose this ordinance.

Take Action - Send a Message!

In advance of any hearing, please take this time to prepare your remarks to the committee.
  • Plan to speak for 3 minutes or less & Practice your presentation.
  • State how long you were a smoker, how long you’ve been smoke free, and how vapor products helped you.
  • How important are e-liquid flavors to you remaining smoke free.
    • Did flavored products help you lose your taste for smoking?
    • Did the variety of flavored e-liquid inspire you to give vaping a try?
  • What would you do if flavored e-liquid was no longer available?
    • Would you make your own?
    • Would you purchase outside the city/state?
    • Would you feel pressured to return to smoking?
  • Review the Meeting Info Guide here.

San Francisco is one of several municipalities in California that are considering prohibiting the sale of flavored vapor products. This is a policy movement and it is a very real threat. We know that proponents of these bans are well funded and have the support of respected organizations. That said, there is no reason to think that “it can’t happen here.”

Wednesday, March 22, 2017

Help us send letters to HHS Sec. Tom Price - #DelayFDA

Earlier in March, CASAA, AVA, SFATA, and VTA sent a joint letter to House leaders urging them to support HR 1136, which would modernize the 2007 predicate date for vapor products newly deemed to be tobacco by the FDA. In keeping with the spirit of cooperation, we are working together again to generate messages to HHS Secretary Tom Price with the engagement below. If you own or manage a vapor shop, please find a space to provide this opportunity to your customers.

The letter we are providing urges Secretary Price to delay implementation of the FDA deeming regulations. Without this delay, many in the vapor industry will begin closing down their operations. If action is not taken soon, consumers will be losing access to reliable, affordable, life-saving vapor products.

CASAA is reaching out to vapor retailers and providing a partially pre-written letter with lots of blank space that can be offered to your customers. Handwritten letters, phone calls, and in-person meetings have the most impact on policy makers. It is vital that Secretary Price receives as many letters as possible so that he understands the impact that the deeming regulations will have on millions of Americans.

How to set up:

  1. You’ll need some supplies.
    1. Download and print the letter - click here for the PDF file.
    2. Envelopes
    3. Stamps
    4. A pen (maybe a few pens)
    5. Clipboard (optional)
  2. Hopefully, you have a space in your shop for people to stand or sit and write.
  3. Print one of these handy flyers we made to promote the letter writing campaign
    1. click here.
    2. or here

How to follow through:

Here is the address for HHS Secretary Price:
Honorable Thomas E. Price, M.D.
U.S. Department of Health & Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
  • Put the letter(s) in an envelope.
    • You can send individual stamped envelopes with your customers’ return address on them or;
    • Put a bunch of letters in one package.
  • Affix postage and pop it in the mail.

And that’s it!
Thank you for helping your customers’ voices be heard.
If you have any questions, please send an email to

Help us send letters to HHS Secretary Tom Price

urging him to delay all FDA Deeming deadlines!