The following public comment was delivered by AVA President Gregory Conley to the FDA workshop, “Electronic Cigarettes and Public Health,” which was held by the Food & Drug Administration from March 9-10. Joining Conley in giving testimony were, among others, Bill Godshall of Smokefree Pennsylvania, Dr. Carl Phillips of the Consumer Advocates for Smoke-free Alternatives Association, Dr. Joel Nitzkin of the R Street Institute, Ariel Savransky of the American Council on Science & Health, and Mark Anton of What-a-Smoke.
Despite the empty chairs in the photo, there were approximately 75 attendees during the speeches given by Conley and other harm reduction advocates.
The AVA’s public comment can be read below. The AVA also delivered a comment during a workshop held in December that can be read here.
AVA President Gregory Conley speaking before the FDA
(March 10, 2015)
Good morning. My name is Gregory Conley and I am the President of the American Vaping Association, a nonprofit organization that advocates for small and medium-sized businesses in the vapor market. Thank you for having me.
My comments today revolve around a theme found in several of yesterday’s presentations that greatly concerns me – the failure to recognize that the toxicology of vapor must be compared to cigarette smoke, not the use of no product at all. With 99% of daily vapers being smokers or ex-smokers, it hardly makes sense to singularly focus on eliminating any detectable levels of chemicals, especially when there is enormous risk that the regulation required to achieve such a goal would result in a net harm to public health.
Let’s be clear — the greatest health benefit will come from having products that smokers start using instead of cigarettes – not from having over-regulated medicalised products that are safe, but dull and unappealing.
Looking at the current market, what are smokers increasingly finding dull and unappealing, or at very least not satisfying enough to stick with? Closed system cigalikes. Several studies presented last month at SRNT add to the growing body of evidence demonstrating that ex-smokers who vape are far more likely to be using flavors and second and third generation products, i.e. open tank systems and bottled e-liquids, than they are cigalikes.
So why are so many activist researchers pushing for overly restrictive regulations that would squash premium vaporizers and e-liquid under the guise of ensuring e-cigarette products are “safe”? And why are so few people who call themselves public health advocates not expressing deep outrage and concern that the FDA’s proposed deeming regulation would, by the FDA’s own admission, wipe out 99%+ of nicotine-containing vapor products currently on the market?
Those who seek regulations that would eliminate or unduly restrict open vapor products should ask themselves why Reynolds American, the makers of Camel Cigarettes, have similarly asked the FDA to ban all open systems vaporizers, e-liquids, and most flavors.
The reason seems clear enough to myself and others – removing from the market the vapor products shown to be the most effective in helping smokers quit will have the deadly consequence of protecting the incumbent cigarette industry from competition from high-tech alternatives with superior characteristics.
Public health is about reducing disease and death, not eliminating all risk from human life. Please do not forget this. Smokers and vapers – the true stakeholders in this debate – are counting on you.