Monthly Archives: October 2012

Gutka is not smokeless tobacco

by Carl V Phillips

There is a popular oral dip product in India called gutka.  It was recently banned, in one way or another, across much of India, though it appears that this has had relatively little impact (other than perhaps raising the price to the extremely poor people who are most of the users).  Gutka is more popular in that country than is smoking, and is used by an absolutely enormous number of people.

Gutka, and the somewhat similar paan that is popular in Pakistan, appears to pose a very serious risk for oral cancer and other oral diseases, and perhaps other serious diseases.  The health consequences appear comparable to those from smoking, and might even be worse — in particular because, unlike with smoking, many of the serious effects appear to occur before old age.  (The “appear” caveats I keep repeating reflect the fact that most of the epidemiology about these products is so utterly lousy that precision is impossible — we had better quality information about smoking half a century ago.  But there is enough information that it is difficult to doubt that there are serious and high risks.)

So, gutka and paan are, indeed, nasty.  But what they are not — contrary to the typical portrayal — is tobacco.  Gutka does contain tobacco, and paan sometimes does (but not always), but it is not the first ingredient and may not even be the second.  The first ingredient in gutka is areca nut (also known as betel nut), and other ingredients include catechu (a derivative of the acacia tree), various flavorings, and calcium hydroxide (aka slaked lime, or just lime).  The ingredients in the one packet of it that I have that lists the ingredients (most do not) are “betelnuts, tobacco, catechu, cardamom, lime, menthol, natural & artificial flavors”.

So this is tobacco only in the sense that a Big Mac, fries, and Coke is lean beef, potatoes, and water.  The latter are major components of those products, of course.  But if they were all that was consumed, while it would not exactly be healthy eating, but it would not be all that bad.  But a funny thing happens when you consider everything in the foods (various unhealthy fats, high glycemic carbohydrates, carcinogenic products from cooking, etc.) — the meal becomes rather unhealthy.  This is a nearly perfect analogy to the deadly implications of calling gutka “tobacco”.

Something in gutka is pretty clearly quite unhealthy.  Lime is a good candidate — it is quite caustic on your skin, as you might have experienced, and is even worse for your oral mucosa.  It has fairly obvious and rapid negative effects.  But it might be that holding areca nut or catechu in your mouth for a long time is quite harmful too.  The one thing that we can be pretty sure is not causing most of the harm is tobacco.  Why?  Because it is the one of the ingredients that has been extensively studied, as an oral dip exposure, and has been found to produce minimal risk.

To be precise and careful (quite unlike most of those who write about this topic), it is possible that the interaction of tobacco with the other ingredients causes more harm than the other ingredients would cause if the tobacco were absent.  It is also possible that because of the way this particular tobacco is processed, it causes harms that American and Swedish style smokeless tobacco do not.  (There is a plausible but unsubstantiated hypothesis that the much higher concentrations of nitrosamines in some non-Western and archaic products could make them much more hazardous, though there is no evidence that it would be anywhere close to as bad as gutka is.)  Thus, we cannot conclude that the role of the tobacco is benign, but it is clearly wrong to suggest it is the main source of the problem.

Who suggests that?  Pretty much everyone.  The impetus for me writing this post was running across this newspaper story about how the gutka ban is failing due to the black market, with a headline that refers to it as “chewing tobacco”.  But it is not just bad reporters and casual observers who make the mistake.  The packets of gutka I have all display the mandated statements “tobacco kills” and “tobacco causes cancer” and what I assume are their Hindi equivalents.  I do not know whether current products still have those statements (once you ban something, it is difficult to enforce labeling regulations, after all), but the point is that the government’s official statements describe the product as “tobacco”.  This is probably the fault of the World Health Organization, since India’s policy is pretty much “do whatever WHO tells us to do”, but I actually do not know the story.  (Anyone know?  Please let me know.)

But it gets even worse than that.  The anti-THR liars have made a concerted effort to trick Westerners into believing that the apparent harms from Indian “tobacco” are relevant to Western products.  The classic example of this IARC Monograph 89, from the International Agency for Research on Cancer — a unit of WHO that primary is known for its science-by-committee declarations, and is mistakenly seen to be an authoritative and apolitical research organization.  The authors of that document — including longtime professional anti-THR activists like Stephen Hecht (already represented in this blog), Scott Tomar (who got a passing mention but seems to have disappeared), and Deborah Winn (who will likely make an appearance) — tried to bury the fact in their 626 pages that their conclusion that smokeless “tobacco” causes cancer was basically based just on studies of gutka and paan along with a single old study of an archaic American product.

I realize that this post leaves the reader with many points of curiosity that call for more information.  I will try to circle back to these sometime.  But I will conclude by creating one more:

Why did I say it was deadly to refer to gutka as tobacco?  THR in the West is about replacing smoking with smoke-free alternatives.  But in South Asia, there is a lot of room for something else that could be called THR:  The replacement of gutka and paan with smokeless tobacco (snus).  Western-style smokeless tobacco could be made domestically (and thus be affordable, though perhaps more expensive than the current products — I am not sure) and it would presumably have about the same unmeasurably low risk as snus.  Given that the impact of the local dip products is similar to that from smoking, this has similar potential to Western THR.  But — as with Westerners who think that “tobacco” or nicotine is the problem rather than smoking — this is very unlikely to be pursued so long as everyone thinks that it is the tobacco that is the problem.

One real motive of the liars, wonderfully illustrated by the “plain packs” campaign

by Carl V Phillips

In the About page, I briefly address the various true motives of the anti-THR liars.  Though they have misappropriated the term “public health” to describe themselves, those who work to oppose THR (whether lying or not — though I am not aware of any who do not base their opposition on lies) clearly do not much care about health.  They are working to keep people smoking, after all.

To the extent that these same people support the more visible anti-smoking efforts, they can still hide behind claims they care about health.  Even then, though, it is pretty clear that this is frequently not their real motive.  Today at Spiked, Martin Cullipich provides a nice example of how the advocates for de-branded cigarette packages clearly know that requiring “plain packaging” will have no impact on smoking rates and thus on health.  (Well, the ones pulling the strings know that.  They keep some useful idiots out front who are not smart enough to see through their own propaganda.)  A bit of journalism reveals how those activists have made it quite clear that the only thing they really care about is hurting the major legal tobacco companies, even though that is merely a matter of lowering prices and encouraging black market purchases, both of which will tend to increase rather than decrease smoking.  (I have written several posts about the economics of this, starting here, and you can follow the links there back to the extensive analyses of the topic by Snowdon and Puddlecote.)

Cullipich also points out that those who wish to control packaging do not really want plain packages, though they use that term.  What they really want are packages with horrible graphic images that — despite the claims that this is about protecting children — most parents do not want their kids encountering (as they obviously will when the labels are on the packages of legal and popular consumer goods).  The activists pretend that those labels are “warnings”, but they contain no information that could qualify as a warning.  Instead, they are really emotional violence, designed to hurt and manipulate people in ways far worse than the marketers the ANTZ so detest.  (We analyzed that point a few years ago in comments to the FDA; the FDA ignored our comments, but some of the same language from the comments ended up in the court ruling that forbade the attempt to do this in the US, so I think we perhaps had some impact.)  Again, this is the intentional infliction of harm, which obviously cannot be about helping people.  One or several of the other motives listed in the About page must be the true motives.

Finally, it is worth noting that all of this non-health-promoting manipulation of packaging is targeted at “tobacco products” rather than cigarettes specifically.  There might have been an interesting fight to try to defend smokeless tobacco from this attack, and maybe even have it actually do a tiny bit of good by using smokeless tobacco to encourage switching.  We probably would have lost, though that is moot:  The same countries (i.e., the same tiny cabal of tobacco control industry people who think they have a right to impose their will on entire countries) that are pursuing these anti-corporation efforts have already banned the sale of smokeless tobacco.  So just in case there was any doubt that these people are actually motivated by trying to help smokers improve their health, that observation should put the issue to rest.

THR adoption model illustrates several lies

by Carl V Phillips

I am outsourcing to myself today.  I just posted, at my EP-ology blog, a video of a talk I gave last week which presented a social-dynamics-based model of the spread of THR adoption in a population.  The video speaks for itself and my other post contains more details about the modeling, so I will offer only the briefest of summaries here and then emphasize a few points about how it relates to anti-THR lies.

The video starts with a general background about THR and the case for it.  Early feedback is that this is a particularly good version of that, so you might be interested in that part alone.  As for the new model, it shows how adoption of e-cigarettes moves like a contagion through a population (though unlike a simple disease contagion, it involves individuals learning and making rational economic decisions).

The premise of the modeling challenges one of the fundamental anti-THR lies, the claim that smokers are not making a choice to smoke and that somehow they are just accidentally doing it:  You cannot model individual choice without recognizing that individuals are choosing.  And you cannot model that without recognizing that they are rationally choosing what seems best for themselves.  Whatever exactly “most smokers want to quit means” (I have written about that previously), it clearly does not mean “prefer to not smoke today when offered the choice”, because they obviously are offered the choice.

A model of deciding to switch to THR requires recognizing that smokers are making that choice because they want to, which means that the benefits exceed the costs.  The very existence of what is represented by each of those words in italics is denied by most the anti-THR liars and other ANTZ.  Their entire deadly game is premised on the denial of those concepts.

Of course, an analysis cannot demonstrate its own premises.  I have to assume that is a lie to be able to even do the work.  But the model’s output does demonstrate the wrongness of another claim:  There is a classic anti-THR claim that THR is not worth pursuing because not too many smokers are interested in it.  The basis for that claim was that not too many have adopted THR (except in a few places like Sweden).  I do not hear this very often any more.  Maybe the ANTZ have given it up, though they probably still repeat it in their echo chambers, where every lie, no matter how thoroughly debunked, lives on as a zombie.  I fact, at the same conference where I gave the talk, I was astonished to hear one of the attendees dredge up that moronic, obviously false, and even explicitly debunked claim that THR is like jumping from a 5th floor window rather than 10th floor.  But I digress…

The claim of little interest is obviously a stupid excuse for an argument against encouraging THR.  Just because most people do not eat enough vegetables does not mean that we stop pointing out that it would be a healthy choice to make.  Beyond the silly “we should not try” claim, though, the model shows why it is wrong to even think “we should not be optimistic” (though perhaps an honest mistake and not a lie, because the reasoning necessary is a bit tricky — thus the model).

The model shows that adoption of THR will typically slowly increase over a long period of time and then reach a tipping point and jump up sharply.  This is not an artifact of particular details of the model design — it happens pretty much no matter what details are used.  This means that the fact that only, say, 5% of smokers have adopted THR as of now does not mean that it will not hit 60% within a couple of years.  The abstract model cannot show that this will happen, of course, but it shows that something like that seems very likely at some point in the adoption of THR.

The model also demonstrates that a constant low-level anti-THR campaign (or a campaign against a particular THR product category) can dramatically delay the time at which the tipping happens.  In other words — in keeping with what many of us have been saying all along — the reason THR has not been more successful yet is that the ANTZ have delayed it.  The lack of massive uptake to date is not an argument against promoting THR; rather it is an argument against their behavior.

To put that in context and for more details, follow the link and watch the video.

TrANTZlating “no safe level”

posted by Carl V Phillips

I was asked by a CASAA member to turn the trANTZlator on the very confusing phrase, “there is no safe level of X”.  You have probably heard or read that phrase most often in the context of “there is no safe level of second-hand smoke.”  This is actually a pro-THR lie, as mentioned yesterday but the same phrasing is frequently used as an anti-THR lie in the context of the chemical exposures from THR products.

The reason this is a lie is that most anyone reading this phrase interprets it in the natural way:  no matter how low the quantity of the exposure is — and in particular, including whatever level of exposure is being discussed in the particular context — there are health effects that are significant enough to warrant being called “unsafe”.   But this is never what the phrase actually means.  It could be argued that the phrase is fine to use in a scientific context because readers there know what it really means.  But it clearly should never be used in popular communication where it will almost always be misinterpreted.

Those who use it in popular contexts either know that it is going to be misinterpreted (and thus are intentionally misleading people) or actually think that the sloppy technical phrase has its natural language meaning (in which case they have no business claiming they know what they are talking about).  Most readers of health science figure out the truism that quantities matter or “the dose makes the poison” — i.e., that trivial exposures do not matter in any practical sense.  The “no safe level” claim sends the message that this (true) belief is wrong, and it is difficult for the lay reader to have the confidence to reply, “I know that is never true.”

Most of the time, the claims “no safe level” is a sloppy shorthand (understood in the scientific context, but unknown to the broader audience that hears the phrase) for “no established safe level” or “no known safe level”, which in turn trANTZlates into “there is almost certainly a level of exposure that is perfectly safe, and it may well be that the levels being discussed in the particular context would be considered safe (in the common sense of the term), but the science has not been done.”  In other words, what is really a statement of ignorance is intentionally presented in a way that will be interpreted as a very strong affirmative claim.

Very occasionally the phrase actually does mean “we have tested exposures as small as we possibly could, and we still saw an effect” (example).  But even then it does not have the meaning that most people take from the phrase.  “As small as we could test” is still not “as small as could occur”, and “an effect” (e.g., at the molecular level) is not the same as “a measurable health effect” (i.e., real results on the actual health of people).  The former of these puts the lie to the literal interpretation of the statement, but it is the latter that really matters.  Any effects that are measured down to the lowest practical levels of exposure are not health effects, and only actual health effects can warrant use of the word “safe”.  Tiny measurable effects in vitro or even at the biomarker level do not necessarily imply actual health effects, and if they do, those health effects are almost certainly undetectable because they are tiny or extremely rare.

That leads to the ultimate problem with the phrase.  The natural interpretation of something being unsafe (which it must be, if there is “no safe”) includes the harm/risk having nontrivial magnitude.  What probably deserves to be called the #1 anti-THR lie is the statement “not a safe alternative to smoking”.  It literally means “there is some tiny tiny risk” or even “we are not sure it causes absolutely no risk whatsoever”, which is true for every exposure and thus technically true, but obviously misleading (i.e., the worst kind of lie).  When people read “not safe” or “no safe level” they do not interpret it as “some utterly trivial health risk that is so close to zero it does not matter”.

Indeed, there are a few exposures where any exposure actually does create a health risk because the risk is a constant role of the dice.  The simplest example is exposure to motorized transport:  Each second of exposure causes a tiny finite risk of injury from a collision.  The degree of safety is proportional to the quantity of the exposure, with any positive amount of exposure creating a positive amount of risk.  But if someone said “it is not safe to drive or walk to work”, it would be immediately clear that they were not using those words in the normal way (and so if they said the exact same thing in a context where people would believe them, it would be a lie).  If they said “there is no safe level of driving”, they would be effectively communicating that the phrase does not mean what people think it means.

As a slight aside, this reminds me of an ironic story that I recently heard (from a friend who contributes to this blog) about people who are so afraid of the “no safe level” of ETS will cross the street twice to avoid catching a whiff from a smoking area.  But we calculated that the risk from the average street crossing is three, maybe four, orders of magnitude higher than the risk from that ETS exposure — even if the effects of exposure are linear.  But furthermore, unlike the risk of accident from crossing the road which is pretty close to linear over the amount of exposure (crossing the road once is 1/1000th as risk as crossing 1000 times), chemical exposures like ETS tend to be far less than linear (that is, even if an exposure has risk X, an exposure that is 1/1000 as great has a risk much less than X/1000, and perhaps basically zero).  Of course, the total health damage done by the “no safe level” message in that case is pretty trivial compared to the damage done by using the phrase to discourage THR.

So what does “no safe level” mean?  Unfortunately, the trANTZlator can offer no consistent substitute.  The phrase is sloppy and can mean any of several things, ranging from “we are pretty sure there is a safe level but are not sure what it is” to “the risk is proportional to the exposure level and it never goes to zero, but it gets as small as you want, and well into the range that people would consider safe”  But it never means what most people think it means, that the quantities being discussed are known to cause health risk at a level that we should care about it (and moreover that any exposure causes such a level of risk).  After all, if the liars thought they could defend that claim, they would simply make that claim.

StatistiLie – ANTZ cleverly choosing the wrong year to report

posted by Carl V Phillips

Since I am still trying to recover from my travels, though have about ten more complicated posts I want to write, I will temporize again — this time outsourcing the lie of the day to Dick Puddlecote.

He points out how several anti-smoking liars tried to mislead the public by reporting statistics from the wrong years.  In particular, in response to the many recent claims that rising taxes are driving more smokers to the black market and this will continue to increase, they compared two past years instead of the current data.  They cleverly (obviously intentionally) ignored the facts that (a) most of the taxes that inspired the flurry of concern took effect since the period they report and (b) there are newer statistics available — and indeed even reported in the newspaper.  It will come as no surprise that the ANTZ concluded that their taxes do not drive people to the black market, but the new statistics support the opposite conclusions.

It is even a bit worse than that, so I recommend you read the whole thing.

Though this is about cigarettes, it is very much an anti-THR lie.  It touches on both of the fundamental lies of anti-THR.  It implies that tobacco/nicotine use is somehow so unlike every other consumption choice that consumers will not behave rationally.  That is, unlike what economics tells us about …well, about every choice people make, for some mysterious reason, tobacco consumers will not gravitate toward low-cost competitors when someone increases prices.  If you can be tricked into believing that, then you can be tricked into other departures from the obvious simple economics, like believing that people who choose to consume nicotine/tobacco do not really get any benefit from that choice.  Thus, the lie goes, there is no value in THR because no one really wants to be consuming these products rather than being abstinent.

In addition, the absurd claim that consumers will not shift toward the black market means that taxes can be raised, without bound, and smokers will respond only by quitting.  (Note that a ban is basically an attempt to raise the tax to infinity, though incomplete enforcement means that it is always actually finite.  Thus, punitive taxes are effectively partial bans.)  For any other good, a ban or price increase will cause substitute markets — in particular, black market supply chains — to gain market share.  But if smokers are the exception to that, and will just obey like they are supposed to, then universal cessation is just a few tax increases away.  And so, their lie goes, there is no reason to pursue THR.

I am adding the new tag to this blog, statistiLie, to try to identify lies that are based on intentionally using the wrong statistics.  (As always, keeping in mind that when an author knows so little that he does not know a claim is wrong, it does not change the existence of the lie, but merely its nature.  An author who unintentionally uses clearly wrong statistics is lying about his knowledge.)  A large portion of all anti-THR lies involve statistics, of course.  I will try to reserve this for the particular case when it is clear that there are statistics that are useful for addressing a particular point, but other numbers are chosen instead, and moreover that the author hides the existence of the more useful numbers.

I did not want to merely use the tag “statistics” because too many people observe that statistics are used to lie and jump to the conclusion that those quoting statistics should not be trusted.  But statistics are the only way we move toward the truth in these matters, and I want to push back against this sullying of the word.  It is interesting to note that in this case that the ANTZ were claiming that the various commentators who based their conclusions on the right statistics were lying.  There is a danger that the real liars will accuse someone else of lying with statistics; indeed, it is a typical ploy by the liars.

Finally, it is useful to note that some anti-smoking lies are pro-THR (e.g., exaggerations of the risk from ETS) — still lies with everything that implies, but they do tend to encourage THR rather than discouraging.  But the statistiLies about the economics (black markets, plain packaging, advertising, bans, etc.) very often try to support the core anti-THR assumptions.  Thus, those lies about smoking turn out to be an anti-THR issue.

“Tobacco” is still not a useful category

posted by Carl V Phillips

After two weeks and many meetings, I have a lot I want to debrief here and at EP-ology.  But right now I face a long flight and accumulated exhaustion, so a simple post to fill the gap — tempting fate by criticizing the US government just before arriving at immigration.

Starting to smoke has immediate effects on oxygen delivery and lung function, and some upper airway effects do not require much accumulated damage.  “Greatly”?  Well that is perhaps a bit strong, but it does not have a precise meaning, so just call it typical advertising hype.

However, smokeless tobacco use has no such immediate effects.  This is obviously true since it is not clear whether it has any serious health effects ever.  This is not to say that a child ought to be free to decide to use any of these products.  But since — as is the message of the original post — “children” (meaning c.17-year-olds, though the word choice is clearly intended to evoke images of 10-year-olds) are using tobacco products, there are numerous benefits from choosing smokeless rather than smoking.  Telling them that they might as well smoke is no better than directing that lie at adults.

In general, any use of the term “tobacco” to refer to an exposure is wrong.  Tobacco is the name of a plant.  It does not describe any particular exposure and indeed, there are several potentially health-affecting exposures to tobacco that are quite different from one another.  It is basically like saying “poplar trees instantly cause your health to decline greatly” — there are ways in which this is true, but it is pretty obviously a dumb thing to say without actually specifying the exposure.

Moreover, many (perhaps most) uses of the term “tobacco” to describe an exposure are not just wrong, but are lies.  They are intended to make the reader to falsely believe that (possibly true) statements about the effects of smoking apply equally to THR products.  The above statement is pretty clearly an example of that.  After all, it does not take any more effort to type “smoking” than “tobacco”.  (Yes, the term “smoking” is not technically limited to cigarette smoking.  But with absent any modifiers, that is the understood meaning, and that is a useful meaning.  That contrasts clearly with use of “tobacco”.)

It is a simple point, but no one is more in need of remedial lessons than the high school intern who writes the embarrassing @FDATobacco twitter feed.

More on a research agenda for e-cigarettes

posted by Carl V Phillips

I am going to keep brainstorming this (clearly related though somewhat tangential) subtopic that I started here, which has produced some useful feedback.

Based on numerous conversations I have had two different meetings since making that post, as well as the comments on that post, I think there is a need to dramatically increase the emphasis on the hardware specs and conditions, as compared to my original portrayal.  That is, I mentioned that we need to study the mapping from e-cigarette liquid chemistry to vapor chemistry as a function of the hardware used.  But I did not put enough emphasis on the latter bit.

While we are not going to be able to test every possible configuration, we should at least carefully examine the effects (on the liquid->vapor relationship) of different heat and power levels, as well as such things as what happens when the atomizer is heated dry.  We should also want to know what changes as components get old.  As noted in the previous comments, there are too many variables but if we can see what happens to a high-quality, pure, relatively typical liquid under varying circumstances, that would be useful.

The next step after that — dramatically more expensive and harder to do, but useful — is to look for human biomarker changes.  A bit of this had been done, but it is very limited.  It should also be tied back to the chemistry — given how much more expensive human subjects research is, it should always be combined with a chemical analysis of what is being vaped.  Perhaps we will have to wait until very large companies want to test their specific highly standardized products this way, perhaps to please regulators, but the results will also offer useful general knowledge.

Moving on from chemistry, I will branch the conversation into other areas of research.  We really need to collect the many personal testimonials about quitting smoking using e-cigarettes and analyze them.  In this case, by “we” I mean not a vague “the scientific community” or “humanity”, but CASAA in particular.  We have been planning to do that, and will start on that soon.

It would likewise be nice to have more of the data about how much product is actually being sold and how many people are consuming it.  This is not all that difficult to know, in theory, but there is remarkably little public information.

Finally, going beyond the relatively easy observations in the social science situation to actively create information, it would be valuable to understand more about users who fall in between trialers/beginners and the category I call “aficionados” (basically anyone who uses mods).  They are most of the users, almost certainly, and growing.  But are they really happy with the products they are using?  Are they at risk of relapse to cigarettes?  What would improve their vaping experience?  We have some good guesses about those, but learning more could improve THR efforts.

That is what I have for now.  I open the floor to comments, which are most welcome.

Right level of excise tax on THR products? Zero.

posted by Carl V. Phillips

I have seen the claim come up a few times (this week it was here, coming from an e-cigarette industry group) that the tax on low-risk alternatives to cigarettes should be proportional to the tax on cigarettes, with the proportion determined by the comparative risk.  They seem to be saying that, for example, if the tax on cigarettes is $1 per pack and it were determined that e-cigarettes are 3% as harmful as cigarettes, then the tax on an equivalent quantity of e-cigarettes or nicotine solution would be 3 cents.

The reasoning behind this is completely wrong at several levels.  I cannot really call this an anti-THR lie because it is almost always coming from the pro-THR side (the ANTZ tend to prefer a tax as close as possible to infinity — i.e., a ban — for THR products), and is presumably motivated by trying to appease the ANTZ, an utterly pointless exercise.  Still, it is wrong and it is anti-THR compared to what is right.

The first observation is one you have probably already thought of:  How could we define what is an “equivalent quantity” (answer: it would necessarily be fairly arbitrary) and how can we determine what the comparative risk is with enough precision for this purpose (answer: we cannot, except for the well-studied smokeless tobacco products).

The second simple observation is that using this proportion assumes that the cigarette tax is somehow “right” in the first place, and thus is a proper baseline to use for setting other taxes.  But cigarette taxes vary radically (even across jurisdictions that have roughly the same levels of wealth and attitude toward cigarettes), so there clearly is no accepted correct level.  Moreover, the increasingly popular level of taxation is “as high as possible without tipping too many consumers into the black market”.  I know the following is a technical point and one that most of us do not agree with, but just to note it:  This means that those with the power really think the cigarette tax should be higher, but they are running up against a ceiling (a maximum caused by natural forces).  So the target (“optimal” in their minds) level of tax is higher than the actual level.  So, if it really were sensible to tax e-cigarettes based on the cigarette tax, it would need to use that higher “optimal” target level, not the constrained actual level.

That is moot, however, because the main point is that the proportion just makes no sense.  The excise tax on tobacco products can only be justified based on incentives.[*]  There is a lot of talk about the taxes paying for the burden smokers impose on the public coffers, but this is clearly disingenuous rationalization by those who want to create incentives:  First, we do not tax most things (e.g., cars, rock climbing equipment) based on the health danger they represent, so this is obviously not how we really make policy.  Second, most risky behaviors, including smoking, tend to balance out their own costs, with any increase in medical consumption being offset by a fairly similar decrease in total net consumption (from dying earlier rather than living a long retirement).

[*This is not quite true:  A high tax on a single good can be legitimately justified as a way of raising government revenue while taxing a relatively inelastic market in order to minimize distortions -- economist talk for not creating much of an incentive to avoid the taxed activity because consumers are not very sensitive to prices.  That is undoubtedly much of the reason for high cigarettes taxes, but policy makers will not admit to that.]

So, if the motive is incentives, high taxes to discourage smoking, what is the right tax level to discourage the use of low-risk alternatives?  It should be obvious that it is zero.  Actually, it is really negative — i.e., we should be subsidizing these products to create more incentive to switch from smoking — but it is realistic to assume we are stuck with a floor of zero.  (The exact optimal level of the negative tax would depend on our objectives, consumer behavior, and factors such as the incentive effect of lower prices on non-users — I intend to write a paper about that sometime.)

The lower the price of low-risk alternatives is compared to cigarettes, the more incentive there is to stop smoking.  Since the cigarette tax is intended to discourage the highly-risky behavior, smoking, if we are going to set taxes of other goods based on this, they should further that goal of reducing the highly risk behavior.  Any positive level of tax on alternative products actually interferes with this goal.

Of course, a large portion of the ANTZ are anti-tobacco extremists, who do not actually care about improving health outcomes, but really want to torment users and eliminate all tobacco/nicotine products regardless of risk for various reasons.  From their perspective the right tax for low-risk alternatives is the same as it is for cigarettes: “as high as possible without tipping too many consumers into the black market” (that will be different numerically, but is the same conceptually).

So basically there are these possibilities from the above:  If the goal of a tax is to encourage healthier behavior, the tax on low-risk alternatives to cigarettes should be negative (which is to say, realistically, zero).  If the goal is to hurt users and eliminate tobacco product use without regard to risk, it should be as high as possible.  If the goal really were to make vapers or snusers “pay their own way”, it should probably be negative (zero), though that would require some tough calculations to nail down.  Finally (and just ignore this if it is too technical — it is not all that important) if the goal is to maximize government revenue by taxing an inelastic demand, the additional excise beyond regular sales tax should probably also be zero since overall demand for these products (due to the risk of switching to higher-risk alternatives) is probably not much less elastic than that for most categories of consumer goods.

For none of these does it make any sense to peg the tax level to that of smoking, via the comparative risk or any other function.