Monthly Archives: May 2014

CASAA comments on deeming re Paperwork Reduction Act

by Carl V Phillips

Sorry for the lack of posts recently.  I have been busy.  One of the things I was busy with was those comments, which you can find here at the main CASAA blog.  It is something that might just matter.

Hitchman, McNeill, Brose (2014) Addiction paper on ecigs

by Carl V Phillips

This recent paper in Addiction by Hitchman, McNeill, and Brose, is a commentary calling for an “accurate and evidence-based debate” about e-cigarettes.  I will admit that my favorite part of it is this reference:

14. Phillips C. V. Anti-THR lies and related topics [internet] 2014. Available at: (accessed 11 March 2014) (Archived at on 24 March 2014).

I find it quite an entertaining citation, and for that I want to offer an apology to the authors.  That post was properly cited because it was (in my possibly biased opinion) the best debunking of the spurious gateway claims that was published at the time of their writing.  However, citing the title I published the analysis under must have given the authors pause.  Fortunately they went ahead and did it anyway. Continue reading

Hamburg letter helps clarify FDA’s naivety regarding e-cigarettes

by Carl V Phillips

The great mystery of the proposed FDA regulation of e-cigarettes is what benefit they think the proposed regulations would have.  As we have pointed out (here and here), the proposed regulations seem to impose costs — in the form of what is basically busy-work — without offering any apparent benefits.  A letter to the NYT from FDA Commissioner Hamburg suggests that FDA has absurd faith in the value of that busy-work (though we cannot rule out the alternative explanation, that FDA knows as well as expert observers do that it is worthless, and they are just intentionally imposing costs and lying about their motives). Continue reading

Clueless prohibitionists: the West was not wild (but is now, due to prohibitions)

by Carl V Phillips

Frequently the scientist in me is appalled by the drivel coming from “public health” regulators and “researchers” about tobacco products.  Every now and then, the more general scholar in me is equally appalled.

In the 2000s, a popular trope was to denigrate tobacco harm reduction with the non-analogy that switching to a low-risk alternative to cigarettes was “like jumping from a 10th story window rather than 20th”.  The exact floor counts varied, but heights were always chosen such that either fall was almost inevitably fatal, which not only overstated the near-zero risk from smokeless tobacco, but also overstated the risk from smoking.

My colleagues and I got so annoyed about this that we wrote this paper, in which we did a little research and concluded that a lifetime of smoking creates about the same probability of premature death as a (non-suicidal) jump from a fourth floor window or a bit lower (this ignores the fact that a death from the fall would be almost immediate, whereas the death from smoking would occur very late in life).  By contrast, the mortality risk from smokeless tobacco was in the neighborhood of the risk from a jump of less than two stories — there is a tiny possibility it will be fatal, but it is extremely unlikely.  We pointed out that many of us have intentionally taken such a jump. Continue reading

Scientific claims in the FDA deeming regulation (part 3 of ???)

by Carl V Phillips

Continuing this series with page 21 of the draft regulations.

I will skip the paragraph that is about little cigars basically being the same as cigarettes, and thus perhaps subject to their flavor bans, but will use it to anchor one observation:  Most of the content analyzed in the previous post, as well as much of what follows, conflates observations about very different products.  FDA is cogent when making points about little cigars being basically no different from cigarettes.  But they present an utter muddle when they try to talk about, say, flavors in general, as if they have similar implications for e-cigarettes, hookahs, and cigars. Continue reading

Scientific claims in the FDA deeming regulation (part 2 of ???)

by Carl V Phillips

Continuing from Part 1, I will skip the Executive Summary (the claims there are mostly redundant with those in the main body) and the Legal Authority (which actually does include some scientific claims), and pick up with the section, Background for Deeming All Tobacco Products To Be Subject to the FD&C Act.  If time permits, I will circle back to the scientific claims in the previous two sections after I provide the context from the main body.

To start, I am simply cataloging the claims and responding to them in the order they appear.  Particularly important points might be highlighted in the text, but the ordering does not imply importance.  Synthesis of the implications will follow.  Page numbers are from this version of the regulations. Continue reading

CASAA White Paper: Guide to Civil Disobedience

The following is the fourth in the series of CASAA White Papers.  As with the others, it is posted here to allow discussion.  Unlike the previous three, this is not considered a draft.  But discussion is welcome and revisions are possible if important potential improvements are identified.  For those who would like a downloadable formatted version, it is here.  Permission to copy, circulate, and post the downloadable file is granted, so long as nothing is changed.


The CASAA Guide to Civil Disobedience in Defense of Smoke-free Tobacco/Nicotine Products
Continue reading

CDC goes full-Orwell in opposition to tobacco harm reduction

by Carl V Phillips

The CDC has been one of the most dedicated opponents of people avoiding the risks from cigarettes by using low-risk alternatives.  This dates back from before I started working in the area, long before e-cigarettes happened.  But it has usually been the same pathetic offhand lies you see everywhere, like those I documented from CDC Director Tom Frieden in the previous post.  But it has also become a fully Orwellian war on truth (or, as I just learned, perhaps Peleven-ian is the modern update of that, though I have not read him), an attempt to create an alternate reality that will trap the ignorant masses. Continue reading