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Stop demonising a potentially useful product for smokers


There isn't serious dispute that vapour products are much less risky than cigarettes. There is no need for 'probably'. The physics and chemistry of vapour and cigarette smoke are are sufficient to know that. Expert attention is focussed on where in the range 95-100% the risk reduction lies. By suggesting a doubt, you would be misleading people into believing they could be indifferent to risk between smoking and e-cigarette use. I hope no-one in a pharmacy gives out that sort of advice. There is a disreputable history of antagonists to harm reduction approaches using residual uncertainties to exaggerate what is unknown - hoping to scare people into complete abstinence. That is deeply unethical. Nicotine is not harmful in the doses experienced as either a smoker or a vaper - though it is the addicting agent. I can't say much more than that. If there are hazards in vapour, it will be thermal breakdown products of excipients or flavourings. So far these have not been found at levels that give any material concern. I cited Igor (2014) above on this - it's worth a read. The General Product Safety Directive would apply as you say, but the framework of consumer protection law allows for products specific standards to be set. Alternatively, a directive could itself establish standards without resorting to classifying products as tobacco or medicines when they are neither - for example, there is regulation specific to cosmetics. If Article 20 of the directive is struck down in court, then the opportunity to do this arises again. I support mandatory standards: e.g. use of pharmaceutical grade nicotine and excipients, banning known respiratory sensitisers, electrical safety, child resistant proof containers, sensible labelling - and the products should be and do as they are described (another principle of standard consumer protection law) There's nothing good or clever about the Tobacco Products Directive. It's main features are pointless or counterproductive, and it doesn't actually do useful things that should be done. The TPD limit of 20mg/ml for e-liquid strength is arbitrary and counter-productive and most vapour products are not medicinal and should not forced to be classified that way. These stronger liquids are used mostly by people first converting to vapour products, and most vulnerable to relapse, and by more dependent smokers. 25-30% of users make use of products above the threshold at present - with no problems. These are the people who most need readily available products in a wide variety of options. Deny them that by making the stronger liquids require medicine marketing authorisation and there will be fewer, less appealing and more expensive products - and possibly none. The result would be more smokers who don't switch and more relapse from vaping - a supposedly safer regime causing more harm. It wouldn't stop there - there would be a rise in DIY, home mixing and black market activity - all with higher risks than the status quo. The limit on container size serves no purpose but makes the products more annoying to use and so less attractive. Again we tilt the odds towards smoking. We don't generally control hazardous substances in the home by limiting bottle sizes to safe doses - imagine if that was done for bleach? The TPD ban on vapour product advertising is disproportionate. Most tobacco advertising is banned in the EU because tobacco kills 700,000 per year. Vapour products likely kill no-one and have a highly beneficial effect as an alternative to smoking. But bans on advertising protect incumbents (cigarettes) and favour those with extensive distribution channels (tobacco companies), while making it hard for new innovative products to capture users' attention. Again, good news for cigarette sales, not so good for health (or pharmacies). The TPD imposes a form of regulation and testing regime that will likely only the big companies to participate in the market. I say likely because the Commission is still working on the detail. It's very well suited to confining the products to commoditised high volume low diversity products, and very aversive to the products that are growing in popularity with the users. So if you want to shape the market to create an oligopoly for Big Tobacco and a few pharma companies willing to dip their toes in the water, then the TPD is a very well designed instrument for your purposes.

Posted date

22 SEP 2014

Posted time



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