If anyone wants the Word file with my comments to the FDA (that includes full weblinks to all referenced documents), please send me an e-mail requesting it to
billgodshall@verizon.net
Thanks for all the kudos. During the past two weeks, I scrolled through all of my weekly THR Updates since 2009, and cut-pasted, edited and reorganized about a thousand excerpts (including those on nearly every published study on e-cigs) that I thought would help to keep all e-cig products legal in this country (after FDA issues a Final Rule for the Deeming Regulation).
Please note that Katherine Devlin at ECITA has posted all of my Tobacco Harm Reduction Updates since 2010 at
Bill Godshall, SmokeFree Pennsylvania to
Bill Godshall, SmokeFree Pennsylvania
Also, Roly has posted the recent THR Updates at
Bill Godshall - Tobacco Harm Reduction Updates
I have just one suggestion: you may wish to revise this statement: "To date, there is no evidence that e-cigarette usage has harmed anyone, which is logical since the products emit a tiny amount of vaporized nicotine (similar to nicotine inhalers that are marketed as smoking cessation aids) and water vapor." (emphasis added)
As I recall, that was an excerpt from testimony I submitted to the FDA back in 2010 or 2011 (before an exploding mod/battery injured someone). But which of the 14 parts of my comments is that excerpt from (so I can check)? Regardless, it's too late to revise anything in the comments, as that deadline has passed.
I wrote (in my comments to FDA, which was also contained in my presentation on the FDA deeming regulation at the 2014 Food and Drug Law Institute's annual conference in DC on April 23 the day before FDA proposed the Deeming Regulation)
According to the US Surgeon General, daily cigarette smoking causes 480,000 deaths annually in the US. In sharp contrast, the scientific and empirical evidence indicate that cigar smoking causes no more than several hundred deaths annually, smokeless tobacco causes no more than several dozen deaths annually, pipe smoking causes no more than several deaths annually, there’s no evidence that e-cigs or dissolvables have ever caused any disease or death.
Jman wrote:
I know of no one else that could get by posting that much and not get criticized for length. Secondly is the obvious bias against BT/smoking and not realizing how much that plays directly into validity/criticisms of vaping.
Don't know what length of a sentence has do with anything. Besides, it came from a speech I gave to dozens of lawyers, who write half page sentences.
There was no "bias against BT/smoking" in that excerpt. Rather, it was simply pointing out the estimated number of deaths attributable (based upon scientific evidence) to the use of different tobacco/nicotine products.
Although I think SG Report's estimated deaths caused by secondhand smoke (which were the same as previously estimated by CDC) are too high (as secondhand smoke exposure has dramatically declined in the US the past 2 decades), and although I think the recent SG Report's estimates of deaths due to daily cigarette smoking are too high (as they didn't consider the huge decline in cigarette consumption the past decade), its pretty clear that daily cigarette smoking is still killing at least 350,000 Americans annually.
In sharp comparison, there's no evidence e-cigs have caused any deaths.
Jman wrote
I ask Bill or anyone where the evidence is that smoking causes death?
There have been more than 50,000 published studies (and I've read many of them during the past 35 years).
Regardless, Jman's (and anyone else's) denial of the scientific evidence that cigarette smoking causes diseases and deaths is not going to win over anyone (to endorse vaping) who understands or supports science, public health or common sense. In fact, the most effective way to keep e-cigs legal to make, market and use is by repeatedly pointing out the comparative risks and benefits of cigarettes versus e-cigs.
