My name is Thad Marney, here to represent the members of the Consumer Advocates for Smoke-free Alternatives Association. CASAA is a non-profit organization and is not financially affiliated with any
tobacco or electronic cigarette companies.
CASAA is deeply concerned about portions of the Proposed No. BOH10-04.1 regulation relating to electronic cigarettes. First, let me be clear that CASAA strongly supports banning the sales of these products to minors. However, additional regulation restricting the use of these products by adults in public and work places would have a severe, NEGATIVE impact on public health. Allowing the indoor use of these products will clearly send a POSITIVE message, not a negative one. Youth will see adults who eschew smoking cigarettes and are choosing a reduced harm alternative. Smokers will see that there is a smokeless alternative available that can keep them from going outside to smoke. Non-smokers will not have to walk through smoke and cigarette butts outside establishments. E-cigarette users who have managed to eliminate their exposure to
tobacco smoke will not be forced into smoke-filled smoking areas.
If smokers are encouraged to switch to smokeless products such as e-cigarettes, by allowing their use in public spaces, exposure to toxic smoke will be greatly reduced for both smokers and non-smokers alike. In contrast, treating e-cigarettes the same as
tobacco cigarettes will simply encourage smokers to keep smoking. Additionally, the ability for adult smokers to sample e-cigarettes in the store has been shown to greatly increase the likelihood that they will switch from smoking to using e-cigarettes.
Proponents of this regulation argue that indoor use of e-cigarettes will be confusing to patrons, encourage smokers to light up and create difficulties enforcing the current indoor smoking ban. While this may SEEM to be true, including smokeFREE products in a SMOKING ban will only serve to INCREASE confusion, but if the Board focuses on educating the public about e-cigarettes, the public will quickly learn the difference and confusion will be minimal. Additionally, due to the lack of lingering odor and cigarette ashes or butts, proving non-compliance for e-cigarettes would be extremely difficult, if not impossible.
Others will argue that e-cigarettes pose a risk to youth and bystanders. In fact, testing by the FDA and several researchers and labs has found nothing to support this claim. The FDA testing did find tobacco-specific nitrosamines in some of the two brands they tested, but they found them to be at the same levels found in FDA-approved nicotine patches. The only chemical of concern they found was a tiny amount of diethylene glycol in one out of 18 liquid samples and it was at a very low, non-toxic level, moreover there was nothing toxic nor carcinogenic found in the vapor itself. Compared to tobacco cigarette smoke, testing by the FDA and other known researchers has shown e-cigarettes to be extremely low in carcinogens, do not contain toxic levels of any chemical and deliver lower doses of nicotine than many FDA-approved nicotine products.
In conclusion, there is just no evidence that these products would be of any danger to the public. On the contrary, an article published today in the Journal of Public Health Policy argues that QUOTE electronic cigarettes show tremendous promise in the fight against tobacco-related morbidity and mortality. By dramatically expanding the potential for harm reduction strategies to achieve substantial health gains, they may fundamentally alter the tobacco harm reduction debate. END QUOTE
I’m giving you a copy of this article for your review, as well as sample door decals to help establishments to distinguish e-cigarettes from tobacco cigarettes.
Public policy and rules for behavior should be based upon scientific evidence and not reliant upon misinformation and conjecture. CASAA strongly urges the Board of Health to support harm reduction in public health by either striking sections nine B and twelve from this proposal or re-examining the entire proposal before committing to a vote. The greater implications of this proposed regulation should not be taken lightly.
Thank you.
