Monthly Archives: July 2017

Simple Simon would refuse to meet the pieman

by Carl V Phillips

I prefer to write about science (or those pretending to do science, or those who cannot seem to report on it accurately) and the activities of government actors. I very much appreciate the efforts of those who take on blowhards who just pontificate their opinions, but it is just not my thing. However, every now and then, one of the blowhards says something that is really useful as social science. Case in point, a recent tweet by Australian Simon Chapman. Continue reading

FDA’s proposed smokeless tobacco nitrosamine regulation: innumeracy and junk science (postscript)

by Carl V Phillips

For completion of this series (with this footnote), the following is what I submitted to FDA. My comment does not yet(?) appear on the public docket as of this writing. But I got a confirmation (confirmation code 1k1-8xfb-dhwh if you want to search for it later). It has a bit of extra content beyond what I already presented. Continue reading

Sunday Science Lesson: toxicology and “the chains” in American football

by Carl V Phillips

Those of you who read my series on fatal flaws in FDA’s proposed rule about limiting the nitrosamine NNN in smokeless tobacco (and presumably anyone reading this quick little tangent read those important and carefully crafted posts) might have tripped up over an oddity from the third post in the series. I quoted this from FDA’s proposed rule about how their key number, used for estimating the risk of cancer caused by some quantity of NNN, was calculated: Continue reading

FDA’s proposed smokeless tobacco nitrosamine regulation: innumeracy and junk science (part 3)

by Carl V Phillips

In Part 1 of this series, I described FDA’s proposed rule that would require smokeless tobacco products (ST) to have no more than 1 ppm of NNN (a tobacco-specific nitrosamine or TSNA) dry weight. I discussed some of the political and policy implications of this, and reasons why the rule will probably not survive. I also noted that almost no current products meet that standard, and that American-style ST probably cannot meet it. Despite the proposed rule probably being mooted, I noted there is still value in examining just how bad the ostensibly scientific analysis behind it is. In Part 2, I noted that the FDA’s estimate the standard would save 115 lives per year is premised on their estimate for the risk of oral cancer caused by ST use. But, in fact, the evidence does not support the claim that ST use causes any oral cancer risk. I then focused on why, even if one believes there is some such risk, the method used to calculate FDA’s quantitative estimate is utter junk science. Continue reading