by Carl V Phillips
It has been a habit of many e-cigarette defenders to refer to recent chapters of the War on Tobacco as a war on nicotine, in part because they do not like their favored product being called a tobacco product. As for that motivation, whatever. But as for the statement, it was simply wrong.
The war on smoking in the USA morphed into a war on tobacco, which basically meant lumping in approximately-harmless smokeless tobacco with the not unreasonable original target of the war. This pretty much tracked the tobacco control industry’s professionalization (read: it went from being a noble — though obviously not universally embraced — hard-fought political cause to a venal business that had a license to print money and was constantly seeking new streams of revenue). Elsewhere in the world, the war was expanded to include Scandinavian smokeless tobacco as well as South Asian and other dip/chew products. Thus it was that for most of recent memory, the War on “Tobacco” was a ridiculously wealthy cabal of a few thousand people (with millions of useful idiots, of course) gunning for consumers and producers of smoked tobacco (tobacco, harmful), Western smokeless tobacco (tobacco, approximately harmless), and other oral products (not tobacco, often harmful).
When e-cigarettes finally became a major commercial product, after a remarkably long delay (which is, of course, a very interesting story, but not the present story), the Tobacco Warriors chose to add them to the list of targets. Thus the war became still more gerrymandered to include e-cigarettes. It was still a fairly well-defined single war, defined in much the same way that World War II was a war, despite really being two largely separate major wars and a few dozen border wars, tribal wars, and colonial struggles. The war is and was defined in terms of what a particular faction did: it was the Anglophone major powers, plus whoever happened to fight one of the same enemies for whatever reason, versus everyone they fought.
As with WWII, the current enemies of tobacco control (which, interestingly, can also be defined largely in terms of government action by the Anglophone major powers) are increasingly not allies of one another. Perhaps that is a tactical error, but they (we) do have rather conflicting interests. But the Tobacco Warriors themselves — a fairly tightly-knit group of agencies, sock puppets, and funders, working together and maintaining remarkable party discipline — make it a war. They also draw boundaries around it: Despite this being fought like every other awful war on drugs, the people involved barely overlap with the traditional Drug War cabals (and, indeed, often actively oppose them despite looking just like them, but that is yet another story).
You can muse about whether there is a better name than “the War on Tobacco” for whatever this is. But one candidate name that was clearly wrong was “War on Nicotine”. For one thing, not all of the targets of the war even contained nicotine. But more important, nicotine in isolation was their thing. It was their peeps who praised, touted, and sold nicotine in its “proper” medicinal form (never mind that NRT is primarily used for the same purpose as the products that are the main targets of their war). One of their favorite go-to tropes was still that cigarette companies’ introduction of lower-nicotine products in the 1970s was some evil plot.
And then something very strange happened. Very strange. Over the last few months, the U.S. FDA suddenly embraced a long-discredited anti-nicotine policy proposal. They announced a policy goal of forcing cigarette manufactures to lower the nicotine content of their products. (Well, legal cigarette manufacturers. The black market would inevitably replace the banned current products — one of the many reasons why this proposal is long-discredited.) Part of this has been an unending blast of government-sponsored anti-nicotine propaganda. The propaganda asserts — without any evidentiary or serious theoretical basis, needless to say — that forced nicotine reductions in cigarettes is the silver bullet that will “keep all new generations from becoming addicted blah blah blah”.
(Aside: I cannot overstate the strangeness and suddenness of this policy. Basically the only people who still supported this zombie idea were those who stood to profit from it. And then suddenly it was at the center of — indeed, is basically the entirety of — FDA’s tobacco policy. I strongly encourage someone who has the time and platform to make it worthwhile to investigate whether there is a money trail from the very small number of companies for whom this policy is an enormous windfall to the pockets of Price or Gottlieb — it is not like there is no history of corruption there. It is probably also worth checking Zeller and company, though they are not the variable here, so that seems like a long-shot. And the Trump campaign, of course, though given that the White House has not managed to put a government in place, it would have been quite a coup to push down such detailed policy from that far up the chain.)
Meanwhile there was the recent paper from Glantz’s shop, elegantly shredded by Chris Snowdon, in which the authors feebly attempt to tar NRT (their nicotine) as part of the evil machinations of the cigarette industry in the 1990s. I won’t even try to explain — there is nothing remotely defensible about it; read Snowdon if you want details. The importance is that Glantz’s current role is as a paid surrogate for FDA. This cannot be coincidence. FDA and tobacco control cannot comfortably fight a war on nicotine when the nicotine-iest products out there are their products that they have always embraced. So they need to muddy the waters around those products. What better way than to manufacture retroactive innuendo that NRT always was a brilliant cigarette industry plot that the hapless tobacco controllers fell for, and not the colossal screw-up on their own part that it was? That exact ploy has worked for them before.
FDA’s Center for Tobacco Products has always been a propaganda shop (they have certainly never been a real regulator). But previously their propaganda was lame pointless messages pitched at ignorant consumers (who do not even know CTP exists, let alone see their messaging), perhaps to provide memes for their useful idiots to publish (and, again, not actually be seen by anyone in their target audience). The current effort is different in terms of both volume and apparent purpose. You can see the volume by checking out the Twitter feeds of @FDATobacco and FDA Director @SGottliebFDA, and also see the content there and by following the links.
This is not the usual background noise of silly anti-tobacco propaganda. This is a clear example of a fixture in the U.S. political system: a concerted push by a government faction to sell their policy. (The most recent high-profile example of this was from the faction trying to destroy the Affordable Care Act.) The target audience for this includes lazy reporters, who will just transcribe the propaganda and get a free byline, and influential pseudo-experts (aka, useful idiots) who do not know enough to not believe everything they read. The general public, the apparent target of CTP’s previous propaganda, is at most an afterthought as an audience. But the most important audience for these propaganda efforts are others in government, or who have similar levels of policy-making influence, trying to persuade those on the fence and to bludgeon those who might oppose the policy.
For example, there was this from NCI (part of the National Institutes of Health, which along with FDA is part of HHS) that came out just after the Glantz propaganda dropped and as it was being touted by FDA and their surrogates.
The cabal at FDA will find it hard to run a full-on War on Nicotine if NCI actively opposes them. Similarly, there are presumably a lot of tobacco controllers further down in government, and in political organizations, who still embrace the old (correct) notion that nicotine — especially their nicotine — is not the problem. Most of them are just puppets, and will dutifully recite that we have always been at war with Eastasia …er, with nicotine, as soon at they get the message. Others can simply be silenced by the deluge from the agency that has more money than the rest of tobacco control combined. That is the playbook for this kind of inward-directed propaganda.
And so we have, for the first time, an actual War on Nicotine. Note that this does not mean the whole war can be relabeled The War on Nicotine for reasons noted above. This is just part of it. We are still stuck with “War on Tobacco (etc.)” for the larger effort unless someone can come up with something better.
Some commentators who focus only on e-cigarettes appear unaware of what is really happening. Gottlieb and FDA substantially delayed the implementation of the stealth ban on e-cigarettes and have made various noises about embracing e-cigarettes as a low-risk alternative to smoking. So, hey, everything looks good for e-cigarettes! Some of those commentators have even bought into the FDA propaganda that the FDA policies support harm reduction (at utterly Orwellian claim which I will address in my next post or you can check out my Twitter thread). However, since e-cigarettes are basically a nicotine delivery device, how can there be both a war on nicotine and a more pro-ecig policy?
One possible explanation is that FDA is signaling a plan to shift toward the position of British tobacco controllers who have seized control of the vaping mindspace there, intending to use e-cigarettes as just another weapon against smoking and smokers. That playbook involves keeping just enough of a boot on vaping to keep it from being accepted as a normal personal choice (it is only a smoking cessation medicine!), and staying in a position to squash it when supporting it becomes no longer politically expedient.
It could be that. But I find it genuinely hard to find that explanation in what we are seeing.
The two messages are simply too flatly contradictory. It is not exactly novel to see messaging from governments that includes policy proposals alongside stated support for goals that are antithetical to those policy proposals. Especially from this government and from this agency — after all, we heard basically the same happy talk about e-cigarettes even as FDA was marching toward a total ban as rapidly as they could. Obviously anyone other than lazy reporters and political actors who are looking for plausible deniability when they fall in with their faction’s bad policies should focus on the policy, not the contradictory happy talk.
But many do not. Thus this happy talk serves the rather obvious purpose of getting e-cigarette advocates — the most vocal and potentially politically effective opponents of a new War on Nicotine — to sit on their hands until the actual policy goal (whatever its crazy or corrupt motivation) has enough momentum. So we can expect no overt anti-ecig actions by FDA for a while. They still will not approve any new products (so there will be those temporarily grandfathered into minimal paperwork in 2016, and an a high-paperwork probably-denial grey-zone for later products, still leading to the full-ban in 2022) or allow any merchant claims about the low risk. They are just pausing, not retreating. They might withdrawal their proposed de facto ban of most smokeless tobacco, issued under the guise of being a health and safety regulation, though frankly that would probably only be because it will never survive judicial review (smokeless tobacco and harm reduction advocates are a much smaller voice than e-cigarette advocates).
But if they gain momentum for their War on Nicotine policy, things will probably go downhill quickly. Implementing a substantive policy (for the first time ever) will empower FDA to go ahead and fight the e-cigarette advocates they temporarily appeased. It seems impossible that a hugely impactful and crazy expensive policy of cigarette nicotine reduction, for the chiiiildren, will not spawn limits on e-cigarette nicotine density and “child friendly” flavors. With the delay of the full-on e-cigarette ban they no longer have the luxury of not even trying to actually regulate the products; FDA will be wanting to hurt vapers through other means.
If the proposed policy is quashed things are a bit harder to predict. Perhaps FDA will be shy to take on more fights. Perhaps there could be a real change of heart, but it would be the height of foolishness to read that into the same old rhetoric. Perhaps the political party that controls our government is really so deeply dedicated to consumer welfare and free choice, as some advocates seemed to think before the election, and they will clean house at CTP and change its direction (haha — kidding, of course — if that turns out to be the case, I vow to print this out and eat it).
But it seems most likely we would still see e-cigarette “regulation” that serves only as harassing partial bans as soon as they are no longer all-hands-on with their current policy. That is consistent with everything they have done so far. Moreover, it seems especially difficult for them to walk back on e-cigarettes after campaigning for a War on Nicotine for a year and convincing their useful idiots that we have always been at war with nicotine.
I find this broad brush approach problematic, I don’t think they know what they do.
Great post as always Carl. We’ve been sold a bill of goods by the 1988 SG report declaring nicotine as addictive as heroin. (Jack Henningfield almost surely wrote that entire section, using almost exclusively his own [mostly flawed] research.) Everyone seems to have bought into this notion of the primacy of nicotine as the overriding motivation for vaping and other tobacco use. There’s just too much research out there that contradicts this. I have no doubt nicotine has some reinforcing properties, but not enough on its own. Otherwise NRT would be flying off the shelves. This is why the war on nicotine will fail. The war isn’t against nicotine. The war seems to be against deriving pleasure from nicotine containing products that have other desirable properties. There’s a lot to like about using these products aside from nicotine. You are correct this is a wrongheaded policy but it’s based on a flawed premise.
Oh, where to start?
Yes, Henningfield is the worst person in this field that most people who read you or I have never heard of. Right now he is out there claiming he has supported THR from the start — hell, he is probably claiming he invented it — when actually he was instrumental in helping derail it (as a shill for pharma).
The whole concept of “as addictive as” is so patently meaningless that the fact that anyone would say such a thing speaks to how sloppy tobacco control is. They might as well be writing poetry (it was a warm as it was blue).
More to the point, I agree that making the war about nicotine misses a lot. But also, making it about nicotine having some ill-defined property called “addictive” further misses. If, say, one gets up in the morning and really “needs” either a cup of coffee or a pouch of snus — either is fine; no reason for both — then something else is happening (not exactly something subtle in this case).
There is clearly a war on pleasure that these people are part of. It goes back to the origins of “public health” as a purity movement, and long before that. Presumably the kashrut laws (and a good bit of the rest of those books) were written by someone who just objected to pleasures of the flesh. However, while that is true, I think this should not be written off as just a part of that. It is its own thing. The sponsored attack on NRT was clearly not about pleasurable substances. The *claim* that they believe that nic reduction in cigarettes will have some miraculous effect is not about anti-pleasure. It is another form of mysticism. Or, as I hinted, it is pure corruption on someone’s part.
This to the end of resolving the cognitive dissonance created by the paradigm: PhRMA nicotine good, Tobacco nicotine bad. Just as with religious zealots, when the lies become untenable – shift the goal posts.
Harm reduction is not anti-tobacco, anti-nicotine, or anti-anything – it is reducing the harm. As such it is not mandatory, you can still drive a car without wearing seatbelts, but a preferred choice. That is the key – choice.
Anything that mandates a choice is not harm reduction but social engineering. Social engineering derives its “just cause” from the notion that a few, well intentioned and politically empowered, individuals can dictate policies that make people better – regardless of their individual consent.
Advocates beware – ensure that we present a choice and not a mandate.
Nicotine is available from tomato greens. The sellers of nicotine can choose to use tomato greens instead of tobacco whenever they feel like winning the ultimate victory.
On Sep 3, 2017 3:40 PM, “Anti-THR Lies and related topics” wrote:
> Carl V Phillips posted: “by Carl V Phillips It has become a habit of many > e-cigarette defenders to refer to recent chapters of the War on Tobacco as > a war on nicotine, in part because they do not like their favored product > being called a tobacco product. As for that motivation, ” >
No, they can’t. I have run the numbers here. You can look it up.
When I ran the numbers they came in at 50,000:1.
I.E. the weakest cigarettes had 50,000 times the concentration per gram of nicotine as the most nicotine laden vegetables.
I vaguely recall getting an order of magnitude less than that. But I might be wrong. Either way, even if you had unlimited raw material for free, the extraction cost would make it prohibitively more expensive than tobacco derived.
Minor point , there are some Australian members of the Solanaceae group, that were (and to some degree still are) extensively used as ‘native tobacco’.
These plants are not members of the Nicotiana genus, and have quite high levels of nicotine (and other related compounds).
People would walk many hundreds of miles to get the best kinds of these plants .
BTW The Australian Tax office officially doesn’t classify them as ‘tobacco’ for tax excise purposes.
Pharma NRT doesn’t work as a total replacement for smoking = bad.
Ecigs and Snus do work as a total replacement for smoking = bad.
BTW the Chinese manufacturers are releasing new products all the time , are these new products really not available on the US market?
They are still available (but…). I clarified the text a bit.
It is not entirely clear (to me, anyway) how this plays out. Older products merely have to be “registered”, en masse, eventually (by the manufacturer or by the importer if the manufacturer is out of jurisdiction). New products have to be registered immediately, with ingredients lists submitted well in advance. Except that small operations do not have to comply for a few more months, so right now they can still pretty much do whatever, though they may end up undoing a lot of that, or flouting the rules, rather than catching up with compliance. The existing rules *seem* to be relatively minor for major US manufacturers but a big burden for ad hoc importers (vape shops) and boutique manufacturers — but not an impossible one. I have not heard of any enforcement action or denials, but they pretty much always have the option. I have not heard any reason to believe they will not occur.
So maybe I should have added that we can expect not much in the way of enforcement action either until they do not need to neutralize the ecig crowd anymore. I did not say it because I honestly do not fully understand what they can do, must do, think they can do, etc. — in terms of new products — under the current rules.
If anyone actually in the trenches for dealing with compliance would like to clue me in, I would appreciate it.
Perhaps medieval Crusades provide a better historical analogy than WWII. Notice that there were many crusades and that the crusaders “enemies” or targets (Muslims, Jews, Byzantine Christians) were not united and often fought among themselves. Just as tobacco controllers with to “save smokers” from evil addiction and bring them to the “true health”, Christian crusaders wished to “save souls” by bringing them to the true faith. Nicotine possibly plays the role of Satan and some anti-smoking vaping activists play the role of Byzantium. The Byzantine Christians thought that sharing the same belief in Christ as the crusaders (and having Muslims as common enemies) would spare them from devastation. It didn’t.
Degrading nicotine in legal cigarettes in the USA (if it actually becomes the law of the land) would create nicotine cartels in Mexico and Colombia to fill the demand north of the border. I still cannot imagine how the DEA could implement practical measures to wage this new drug war. Billions of nicotine degraded cigarettes are daily sold in the USA, how will they distinguish them from the smuggled fully nicotine counterfeits?. Will cops carry around portable labs to test cotinine? These practical difficulties in policing this prohibition is likely to render it non-operational, as smokers will find it quite easy to disobey it. The only way to circumvent this would be to change the chemistry of the degraded legal cigarettes so that their smell and taste is very different from fully nicotine cigarettes.
I hesitate to pursue the analogy further. I was really just trying to make the one isolated point about how wars get defined. Someday I suspect history will record “the” war of the early 21st century, defining it as the USA and everyone who supported them, versus everyone they attacked. At least then Yemeni and Palestinians will be properly recognized as US victims.
Anyway, yes, among the many problems with the proposed policy is the impossibility of detecting noncompliance, other than at the batch level in mass production. Smuggled product immediately looks legal. Presumably it would be sold in other noncompliant ways that would still allow arrest if transactions were intercepted, but once the product was in the hands of the consumers, they would be safe. There would be the incentive for smugglers, of course. Indeed, since basically taxes are pushed as high as they can go without tipping into a massive grey market, this might force a lowering of taxes to avoid making the black market *too* attractive. That is kind of amusing. I will write about it sometime if this goes anywhere. Also there is the little matter that someone will come up with a quick and easy way to fix the cigarettes using a high density nicotine PG solution. It is not inconceivable that those chiiiildren who this is supposedly targeted at will be on the cutting edge for that (having more free time, creativity, and lifestyle flexibility), and this will revitalize their interest.
As far as I know (please correct me) there are not sufficient reliable “randomized” clinical tests looking at the effectiveness of VLNC in conditions that reasonably mimic real smokers’ choices. I have a strong suspicion that the experts proposing the nicotine elimination policy have cooked up their own fake theories on the smoking habits of *real* smokers and may box themselves into a corner before admitting that real life cigarette smokers will simply dislike and reject the offered VLNC. I sense that this will be one of the reasons why the VLNC policy could be a spectacular failure, besides the facts that it will generate black markets and compliance will be too hard to enforce. Perhaps such a massive FDA induced massive (and costly) fiasco is needed for the beginning of the end of the current authoritarian tobacco regulation. Perhaps a major public health disaster is needed for real THR policies to emerge.
Notice that “herbal” stuff not containing tobacco has always been available, to be smoked, yet very few cigarette smokers actually smoke it. For example, amazon.com sells such stuff to be smoked in a pipe or on roll your own (RYO) fags. A few years ago I bought two packages of each, same herb mixture, one for the pipe (for me) one for RYO (for my wife). Once we smoked them, we immediately noticed that it was not tobacco. Our reaction was completely different. As a pipe smoker I enjoyed the herbal mixture and could (probably) adjust in the long term if I was forced to smoke only this stuff. However, my wife hated it and vowed never to smoke that shit again. Perhaps what explains the difference is that pipe smokers enjoy more the feeling of the smoke and the aroma, whereas cigarette smokers enjoy more the inhalation hit. There are some similarities in the vaping experience. Cigarette smokers starting to vape initially enjoy high nicotine liquids, but as they keep up vaping and quit cigarettes they vape liquids with less and nicotine and start enjoying flavors (like pipe smokers). However, cigarette smokers not interested in vaping would likely reject their usual tobacco replaced by some de-nicotinized stuff analogous to this type of herbal stuff. Perhaps this has to do with how nicotine is absorbed: very fast through the pulmonary alveoli when smoking cigarettes, while very slowly through the bucal mucouse when smoking a pipe. Anyway, I sense that FDA experts will simply ignore all this.
Well, this is really pretty much the only way to do the experiment: implement the policy and see what happens. It is difficult to imagine any research design that could possible well-represent this. Maybe if you locked people up for it. But since the supposed benefit is nonsmoking kids not getting hooked in the first place, that might be frowned upon.
There are a few people who have strongly associated themselves with “theories” (actually: obviously silly dogma, without scientific basis) that this will work. You might be right that a spectacular boondoggle like this could change the way things are done (especially if it is discovered that it was motivated by corruption), but I seriously doubt it. It might happen somewhere else, but people in power in this country have no humility. Just look at: lack of resignations following failures; the Democratic Party leaders clinging to power and the same-old tactics despite one loss after another; Republicans backing the same failed economic policies for three decades.
(Aside: oral mucosa absorption is actually pretty quick compared to gastric or dermal. A matter of seconds slower than pulmonary, though that is enough to blunt the spike. Also, holding alcohol in mouth is good for getting drunk faster, though that is not so good for your oral health.)
As for your point, as you say, no one wants this or there would already be a market. It is theoretically possible that there is a market failure, due to path dependence or an evil conspiracy, such that the nicotine content is higher than would be optimal for people, but they are stuck used to what it is. Under that (completely baseless) story, mandatory lowering could actually make people better off. There is actually a pretty good case to be made for that for sugary drinks, but not nicotine. After all, you don’t have to smoke it clear down.
So the (balmy) idea clearly is that smokers will dutifully buy an inferior product and just suck it up (!) rather than making an effort to get/make the real thing. Seems unlikely. Some will quit instead, of course.
The comparison of vaping and pipe is rather compelling. That is probably one to keep thinking about.
Did you say ‘fags’ Roberto? You were in the UK too long, you’ll be preferring cricket to baseball next!
Hi DP. I lived more than 5 years in the UK in the 1980’s and never went to a cricket match. I always thought of it as an exotic cryptic game played by the “natives”. Last July when in London I went to a cricket match for the first time ever and (I guess) finally understood how it’s played. I was warned by my hosts not to embarrass them by saying “oh … this looks like baseball”.
Carl, I get the feeling from watching what is going on here in Australia that TC don’t really care about black market cigarettes. My feeling given their ridiculous objection to tobacco companies providing support to police efforts to counter smuggling that their real target is legal tobacco. If they can reduce the sale of legal tobacco enough they can then convince policy makers to just ban it. Couple this with Chapman’s ridiculous denial that black market is a problem based on a government telephone survey asking people if they have broken the law lately, combined with falling sales of legal tobacco this might be enough to bring about a total ban?
Could this be what they are doing with de-nicotine cigarettes? Or am I giving them too much credit?
I can’t say I understand politics there well enough to do an analysis like I did here. Sometimes something that looks like random silliness, stupidity, and lashing out is just that. Sometimes you can find the highly rational tactical explanation, like the latest from FDA. There is plenty of evidence that Chapman and his idiot minions are genuinely irrational. But that does not mean every single thing they do is irrational. A full-on ban would be out of the question, politically, in most jurisdictions, but I don’t know about Australia. But if so, yeah, it could be a viable tactic to intentionally create such a black market “problem” that a ban seems like a good idea (to the idiots who think that banning drugs ever works out well). That strikes me as plotting beyond Chapman and his Trump-like impulsiveness, but there presumably are some actual puppet masters there (just as Glantz is not actually an influential figure here despite being most obvious).
As for banning in the USA, that is explicitly prohibited in the TCA. Congress could do it, of course, but they won’t. So de-nic is, in the minds of some (though who knows about Gottlieb), the way of effectively doing the ban that they really want. It is definitely that for some of them.
It could be that a form of careerism is in play if , on the record sales of cigarettes decline that’s a measurable outcome. And black-market sales ‘dont count’.
Antivapers are simply Antismokers dressed up in new clothing.
(1) It’s fair to say that almost(*) ALL Antivapers are Antismokers.
(*) The only exceptions are the smokers who have quite rightfully responded negatively to those vapers and vaping vendors who’ve joined in attacking them, thinking that by joining in throwing the smokers under the bus they’d avoid having bans aimed at them as well. They seem to have learned their lesson well in New Orleans and elsewhere, but they’re still out there at a disturbing level unfortunately.
(2) Interestingly though, in converse to (1), not all Antismokers are Antivapers. If you go to https://www.sott.net/article/128768-Recognising+Anti-Smoking+Types you’ll see a brief summary of the “Types” of Antismokers out there. SOME of those “types” — most notably “The Greedy” and “The Controllers, though joined sometimes by the Neurotics and the Ex-Smokers (at least those who became “Ex” without vaping) — are against vaping, but other categories (most notably “The Idealists” joined by some of the “Truly Affected” and “Innocents”) are not.
The Glantzians are trying desperately to grab The Idealists by playing up all sorts of imaginary dangers of “secondhand vaping.” It’s a tougher row for them to hoe since the numbers of chemicals and the concentrations involved are pretty much a thousandfold less than the ones for “secondhand smoke,” but that’s never stopped them in the past: they successfully ignored the thousandfold difference between primary smoking and “secondary smoking” just by pumping tons of money into the media conflating the two.
That’s the same tactical road they’re trying to travel with their attacks on vaping. Ignore the differences in concentrations, play up imaginary fears and possibilities, and wrap tons of lies around every zeptogram of fact that might be in their press releases.
Read this brief excerpt from my “Of Vapors And Vapers” chapter to see the kind of argument that may be effective against them:
Click to access TNSite-SlabVIII-OfVaporsAndVapers.pdf
NEVER let them get away with their lies. Write letters to the editors and responses online to news stories — not just at sites like this wonderful one, but out where the “passers-by” will see your arguments: It’s that growing army of “The Innocents” that you have to stop the Antivapers from building!
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The FDA can’t seem to make up its mind about what is bad about vaping! All we can do is fight back with facts backed up by science. Thanks for continuing to inform the public!
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Just at GTNF-2017.com. CTP Director Mitch Zeller and other prominent PH attended (including Fairchild, Hatsukami, Henningfield, Pinney, Abrams, Yach, et al) as well as industry and some other interested parties, (think tanks, investors).
An interpretation I heard from industry and that was supported by some independent observers at the conference was that FDA/CTP have decided to talk about VLNC to appease part of their audience or ‘stakeholders’ (unreconstructed TC) to provide space for adoption of the risk continuum.
The reception of people from 22nd Century (commercial advocates of VLNC as I’m sure readers of this blog know) at the conference in sessions I attended appeared to be highly skeptical, and indeed the discussion around VLNC acknowledged that such products are not viable for adult smokers and instead are, paraphrasing, “to free the next generation from nicotine addiction and harm of smoking”.
Others argued that the only acceptable way to achieve such a goal was to offer such compelling RR products that consumers of all ages would prefer them, especially if the truth about the de minimis risk relative to combustible cigarettes were widely known. (as an aside, I asked Director Zeller in the Q&A at the end of his talk what he thought FDA’s role was in correcting the mis-information from other government agencies at the federal, state or local level around nicotine and vaping and he refused to comment saying essentially he couldn’t discuss other agencies.) The interpretation then is that FDA/CTP need time to allow those superior RRPs onto the market and their success will obviate the need to force VLNC onto consumers.
I find your analysis compelling (as usual) but am curious your thoughts on the above interpretation of FDA/CTP’s apparently schizophrenic policy aims.
Ok, here are my immediate thoughts in response. I reserve the right to refine them as I think more, of course.
I find the appeasement explanation rather difficult to accept. First, they do not have to appease those people. FDA is now the 500 lb gorilla in the mix — they have real power, more money than everyone else combined, and an official seat at the table in government. Yeah, of course, they don’t like having CTFK et al’s pet congressmen asking annoying questions at hearings. But it does not matter much. Besides, no one in congress is paying much attention to anything this detailed right now (never mind that it is actually a really huge deal, perhaps only second to what happens to ACA among domestic issues in terms of real impact — they don’t get that).
Second, surely Zeller et al know as well as the rest of us that these people cannot be appeased. They grab whatever they are given and start treating is as The Natural Order as soon as it is even seriously proposed, and then keep fighting everywhere else. So the next time they perceive FDA as being “soft on e-cigarettes” or whatever they will start screaming again. That is, unless there is actually an explicit deal — that would change this analysis. It would have to be between FDA and three or four key players. But even then there is a huge fringe of third-tier players that would scream just as loudly (as far as the public or Congress would hear) even if the second-tier players sit on their hands (per the above, FDA is alone in the first tier). Of course someone might have overlooked this little problem. Or I *suppose* it could be that this hypothetical deal with the second-tier involved them actively supporting those “soft” moves. But that seems really unlikely.
Third, as I have made clear, I do not believe that Zeller/FDA actually want to ease up on low-risk products. I believe they are just playing people (really well, I might add). In addition to the big huge anti-low-risk actions they have taken, there have been various trivial ones (some of which I have documented here) that would not have evoked a reaction if they had made the pro-low-risk decision. But they didn’t. Not once. And then there is the refusal to say anything (or let industry say anything) to combat the disinformation, as in your Q&A example. Notice that all the rhetoric about “continuum” (which in itself is a backdoor anti-low-risk characterization, as I have repeatedly explained) is aimed at a level that will only be noticed by insiders and picked up by gullible reporters; none of it is presented in terms that are legitimate scicomm.
Finally, I propose you substitute a few words in what you just wrote: “The government decided to provoke a war with North Korea in order to appease the hawks so they could achieve their real objectives of getting out of Syria and Afghanistan.” Except they are not actually moving to get out of those other wars, even though they could, and continue to make them worse. And the appeasement “gesture” is ridiculously disproportionate to the actions they are trying to “get away with”.
Moving on, it is good to hear that 22nd Century is regarded accurately. But that does not explain why so much of what FDA has said looks like it was cribbed from their press releases. I remain deeply suspicious.
As for allowing time and such, why? How? The products will either displace cigarettes or not. They are more likely to if FDA et al stop opposing them, but they show no real signs of doing that. Meanwhile, as per my analysis, they have launched a campaign to win endorsements for their headline proposal. That is not the behavior of someone who is just throwing out a proposal they intend to string along without action for years while events overtake it.
I see no contradictory policy aims, only duplicity and a remarkably naive target audience for it.
the really disturbing aspect of a ‘war on nicotine’ is the considerable evidence that nicotine has real neurological benefits .
“for years Quik has endured the skepticism and downright hostility of many of her fellow neuroscientists as she has published some three dozen studies revealing the actions of nicotine within the mammalian brain.
“The whole problem with nicotine is that it happens to be found in cigarettes,” she told me. “People can’t disassociate the two in their mind, nicotine and smoking. It’s not the general public that annoys me, it’s the scientists. When I tell them about the studies, they should say, ‘Wow.’ But they say, ‘Oh well, that might be true, but I don’t see the point.’ It’s not even ignorance. It’s their preconceived ideas and inflexibility.””
Interesting. Thanks for the link. I was, of course, aware that nicotine had several apparent benefits (and perhaps smoking or other whole-leaf tobacco exposure has others still). But I had not seen that piece.
However, I tend to disagree that this is THE really disturbing aspect. I find it most disturbing that a bunch of puritanical busybodies think they have some right to tell people what they can or cannot use to alter their own neurochemistry — whether the long-term health effects of that use are positive or negative.
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I suspect that Scott Gottlieb told Mitch Zeller to delay the FDA’s vapor Deeming prohibition date from 2018 to 2022, and that displeased Zeller then duped Gottlieb to propose moving forward on VLN cigarettes as a political compromise to appease irate CTFK, ACS, AHA, ALA, AAP, Legacy, many THR opponents at DHHS, and left wing Congressional Democrats and left/liberal news outlets that have demonized and lobbied FDA to ban vapor products since 2009.
But since FDA stated it would propose an Advanced Notice of Proposed Rulemaking for VLN cigarettes (as opposed to a Proposed Regulation, as FDA did with the Deeming Regulation), the FDA is allowing itself to reject and/or delay the VLN cigarette indefinitely.
I wasn’t surprised by Glantz’ latest anti NRT paper and rhetoric, but I don’t think it will influence Zeller (who worked as a GSK lobbyist via Pinney from 2002-2013, who collaborated with Matt Myers and Philip Morris to negotiate details (including the grandfather date) of the TCA in 2003/04, who lobbied Congress to enact the TCA until 2009, and who then lobbied FDA to propose/impose many anti-THR and pro NRT regulations until Obama’s DHHS hired the heavily conflicted Zeller to head the CTP in 2013 and to propose/impose the Deeming Rule) or FDA policy.
For more than a decade, other DHHS funded anti tobacco extremists
(John Pierce, Greg Connolly, Hillel Alpert) have correctly criticized NRT as ineffective for smoking cessation. But the first thing FDA did after Zeller arrived in 2013,was to further liberalize regulations for NRT by approving its long term use (as long as smokers continue to smoke).
Regarding Gottlieb’s 4 year delay of vapor prohibition day in America (to 2022), the biggest (and most important) challenge for the vapor industry and real THR advocates will be to convince Congress to repeal the Deeming Regulation for vapor products and enact reasonable vapor product standards (e.g. Duncan Hunter’s bill – HR 2194), and to convince Gottlieb to support the legislation and/or to unilaterally repeal and replace the Deeming Rules for vapor products and replace it with reasonable vapor product standards.
Unfortunately, to eliminate market competition from premium vapor products (open tanks and e-liquid), the large tobacco companies who market cigalike e-cigs will lobby to keep the Deeming Rule and to oppose Hunter’s bill (and any other reasonable standards for vapor products that would allow tens of thousands or even hundreds of products to be sold in the US).
And if/when/after FDA approves PMI’s PMTA and MRTP applications for IQOS, I’d be shocked if PMI and Altria (which will exclusively market IQOS in the US if FDA approves PMI’s applications) don’t spend $1 billion or more to keep the Deeming Regulation and to oppose any/all reasonable product standards for vapor products.
PMI and Altria don’t want to compete against hundreds of thousands of vapor products when they can lobby FDA to give them a monopoly for IQOS, ban all new (i.e. after August 8, 2016) vapor products from being legally sold in the US, and then ban all vapor product sales in 2022.
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