by Carl V Phillips
A recent paper was ostensibly a research agenda for dissolvable smokeless tobacco products. It is totally lame and is so devoid of useful content that it would not be worth reading at all, except that it is written by some of the US FDA tobacco unit’s pet consultants, and thus can be seen as either a calculated trial balloon for the FDA or, more likely in this context, an engineered excuse for doing what they were planning to do anyway. The entire paper is vaguely hostile to dissolvables without actually saying anything concrete (because there is nothing concrete to say).
The glaring omission from the paper — and the definitive evidence that the paper was not trying to provide an honest policy analysis — was the complete lack of mention of pharmaceutical (NRT) nicotine lozenges. The latter products are so similar to dissolvable ST that only someone who is trying to mislead their readers would fail to draw the comparison.
Clearly there are differences in appeal: the ST products are made by people who understand what consumers like and are trying to give them what they want, whereas the pharma products are decidedly yucky (personally I do not find any of these products appealing, but the pharma products are more unappealing, an assessment shared by people I have talked to who like the ST products). There are potential differences in the benefits (all of the psychoactive chemicals in tobacco vs. nicotine alone). And there are theoretical tiny differences in their health effects, though it is not necessarily obvious which direction that goes in, and in any case it is tiny and unlikely to be measurable unless there is something very strange about dissolvables that makes them unlike snus.
But physically and behaviorally, the products are basically identical, and it is the physical and behavioral aspects that the recent paper (and, thus presumably FDA) is most focused on. For example, there is the inevitable “look like candy” claim, though the pharma products resemble candy just as closely and, unlike the ST products, are actually packaged in ways that resemble candy (for more on that, read my parody of those claims if you have not done so — I am fairly confident you will find it worth your time).
There are several discussions of how smokers might use these products to deal with smoking place restrictions (with the insinuation that allowing smokers to avoid suffering is a bad thing). But there is no mention that most people who use pharma nicotine use it for just that purpose. The authors seem to also be unaware of the existence of snus pouches and e-cigarettes — they suggest that dissolvables are unique in their ability to provide smokers with a comfortable and socially acceptable smoke-free alternative.
Simply ignoring the similarities, while casting insinuations about dissolvable ST that are unaffected by the small differences, is the typical ANTZ strategy. It seems to be the most definitive evidence that they are consciously endeavoring to protect their friends/patrons in pharma (not that there is not plenty of other evidence, but this is the most blatant).
While the recent paper was not one of the semi-psychotic hatchet jobs that we often see, it definitely had its share of “come up with anything we can say that is negative”:
The packaging of dissolvables also raises important questions. Some current product packages include 12 dissolvables per container. It is unclear if such package size is appropriate for the exclusive dissolvable user, or if it is more suitable for the needs of a dual user seeking to maintain nicotine levels during periods of smoking abstention.
I realize that ANTZ do not always seem to be a part of the same humanity as the rest of us, but how have they overlooked the fact that manufacturers often introduce a new product with a limited quantity, rather than demanding consumers pay for a large quantity to try the product. I suspect consumers still can figure out how to buy a larger quantity at one time if they wanted — tobacco users are not as dumb as the ANTZ apparently think. But beyond that, the claim is just moronic on its face: Exactly how many smokers find themselves saying “well shoot, this only comes in a 24 pack, but I only expect that I will find myself needing to be temporarily smoke-free 12 more times in my life, so I guess I will not buy it”?
Of course, were the 24 pack were the norm, Greg Conley cleverly observed that the paper would have instead read:
Some current product packages include 24 dissolvables per container. It is unclear if such package size is appropriate due to the extremely high risk of child poisonings.
(Note: There is no evidence of particularly high risk — this is parody.)
Finally, as is practically mandatory for these papers:
This increase in the marketing of dissolvables has sparked controversy because the design of these products could conceivably contribute to an overall increase in tobacco consumption, thus leading to an increase in morbidity and mortality.
Apparently they have not read me and others pointing out that this claim is absurd (mentioned here recently), and that any substitute for smoking cannot help but lead to a decrease. Apparently also they are incapable of performing the simple arithmetic that it takes to independently derive that conclusion. Of course, they do not really have to have such analytic skills because they have figured out how to make a living writing content-free papers and then cashing their huge checks from the US taxpayer.
[Minor Update: After some discussion, I have conceded that the neologism has standardized as the plural of the noun-ification of the adjective "dissolvable" -- that is, without the "e" that was toyed with as a way to create a distinct word. I will further concede that I should have at least been consistent :-) -- so all the appearances are now standardized. If nothing else, this is a nice lesson in how language usage evolves based on utility rather than following arbitrary rules like to not split infinitives or that a preposition is not good to end a sentence with. After all, the rules say that the word is dissoluble.]