Health Canada’s review of its tobacco and vaping legislation focuses only on reducing youth vaping. It shows no awareness of the links between smoking and vaping, between adults and adolescents, and the case for harm reduction at all ages
This blog takes a critical look at Canada’s ongoing review of its tobacco and vaping legislation. Health Canada produced a discussion document to inform the review, posed twenty-two questions and invited comments. Responses from me and David Sweanor are set out below.
Health Canada is trying to ban almost all vaping liquid flavours. This is on top of measures to limit nicotine strengths and marketing. It is the nearest they can get to a prohibition without actually having to prohibit the most promising low-risk rival to cigarettes. The likely effects are obvious: more smoking. But in a bizarre twisting of reality and evidence, Health Canada finds that making vaping less attractive relative to smoking will… um … reduce smoking. And that’s how it justifies the measure. We respond with a counter-analysis.
It is first-class public-interest journalism, with some hard messages for Bloomberg but plenty of balancing comment too.
The response. The interesting thing is that this drew a joint response from Kelly Henning of Bloomberg Philanthropies, Matthew Myers of the Campaign for Tobacco-Free Kids and Robin Koval of the Truth Initiative. See Vaping and Philanthropy: Debating Strategies That Work (web archive). There is a substrate of anger and panic in the letter that suggests that Gunther hit a raw nerve.
What is unusual about this letter is that Henning, Myers and Koval actually try to defend their positions. Normally, they don’t defend their positions, they just assert them with millions of dollars of amplification. It offers a rare opportunity to provide a critique of their stance. So I have taken their response letter, broken it down into 15 propositions, and provided a response to each. Each section starts with a quote from the letter pulled out in a quote box in bold dark-blue. The letter is analysed in its entirety. Continue reading “Holding the Bloomberg anti-vaping propaganda complex to account”
The Netherlands is proposing to ban e-cigarette flavours – what could possibly go wrong?
The government of the Netherlands, led by Paul Blokhuis, State Secretary for Health, Welfare and Sport, is in imminent danger of fooling itself into becoming an unwitting ally of the cigarette trade. By taking measures to make vaping less attractive (notably by proposing a ban on all non-tobacco flavours for e-cigarettes), it threatens to degrade the appeal of a low-risk rival to cigarettes, provide regulatory protection to the cigarette trade, prolong smoking, obstruct quitting, and add to the burden of disease and death. All this in the name of protecting youth, while managing to harm both adults and adolescents. Quite a feat for any politician.
The problem is hubris – believing that the world responds to regulation in the way the regulator thinks it should. Experience suggests foreseeable perverse consequences will be the result of the ill-conceived prohibitions of much safer alternatives to smoking, including flavoured e-cigarettes.
It really isn’t difficult to understand why and how this would happen – I can only assume the State Secretary received very poor advice, which would not be unusual in this field. Nevertheless, twenty-four international experts have set out the arguments and evidence in detail in a submission to the Dutch government, hoping to spare Mr Blokhuis later embarrassment and, even more importantly, to avoid yet more death and disease from smoking in the Netherlands. It should also be a wake-up call to like-minded politicians and naive policymakers in the United States, European Union, and the World Health Organisation who continue to fail to grasp the impact of low-risk products in the real world.
The case is set out in 30-page submission to a Dutch government consultation on the measure. The relevant documents are:
In June 2019, an influential and well-respected research group published a paper in the BMJ showing both a sharp rise in youth vaping in Canada between 2017 and 2018 – mirroring the rise in the United States. But the truly shocking finding was that there had also been a sharp rise in youth smoking (not seen in the United States).
Starting from well before publication, the paper had a strong negative influence on Canada’s approach to tobacco harm reduction, causing a reversal from a promising and insightful pro-public health approach to making ad hoc responses to a mounting moral panic. Yet it turns out the smoking figures were wrong – a consequence of a flawed weighting procedure.
By July 2020, a correction had been issued in the BMJ noting that with revised weighting, smoking had, in fact, fallen. But, absurdly, the correction was buried in a statistical supplement and the published paper still states, inaccurately, that youth smoking increased in its results and conclusion. The discussion section of the paper continues to discuss an increase in smoking that never happened. Given the political salience of this paper, a proper correction or retraction and resubmission is essential.
I did a Twitter chat with the Campaign for Safer Alternatives on the typical objections raised to tobacco harm reduction. For those interested in the responses but who missed the live chat or got as confused as I did in trying to follow threaded answers, here is the chat as it unfolded over 15 questions with everything in the right order.
American vapers and vaping businesses will shortly enter a period of chaos and existentially threatening regulation. First will be a ban on almost all flavours. Going into 2020, the industry will be in crisis and vapers and smokers will be in danger of losing one of the most important innovations of the century. Here are twenty things you should know.
American vapers and vaping businesses will shortly enter a period of chaos and existentially threatening regulation. First will be a ban on almost all flavours – everything except tobacco flavour and possibly menthol and mint. That is likely to shut down nearly every vape shop and e-liquid company that isn’t part of a tobacco company. Then by 12 May next year, any surviving vaping companies and will have to comply with the hugely burdensome, opaque and unpredictable pre-market tobacco application process. Going into 2020, the industry will be in crisis and vapers and smokers will be in danger of losing one of the most important innovations of the century.
When senior officials claim that the is an epidemic of teenage vaping or nicotine addiction, what do they actually mean and does the claim makes sense? Most vaping is infrequent, and regular use is concentrated among smokers, where is may be benficial.
I have been following FDA Commissioner Scott Gottlieb on Twitter and was alarmed at the threat he issued to vapers and the vaping industry in response to recent trends in US adolescent vaping.
If this is his analysis, @SGottliebFDA hasn’t tried hard enough to understand what is – and is not – a material risk in these youth vaping numbers. Yet he appears willing to put millions of adult lives at risk by imposing regulatory overkill on a life-saving product for smokers. https://t.co/HB64pgtjRJ
I disagree with the FDA’s analysis of what is happening with adolescent vaping and also what should be done about it. So I need to put some flesh on the tweet above and examine some of FDA’s claims in more depth. Please dip to these talking points… it’s a long blog but I hope at least some of it will be illuminating.
New data on youth vaping. Time to take a closer look at the disclosure of some 2018 U.S. National Youth Tobacco Survey data (see MMWR). The survey is conducted annually, with field work in February-June. Usually, the results are published in headline form about a year later (2017 data was published in June 2018) and full datasets some time after that. 2018 is different however. CDC and FDA (the co-authors) have rushed out data that they argue supports the claim there is an ‘epidemic’ of teenage vaping use (see FDA chief calls youth e-cigarette an ‘epidemic’, Washington Post).
FDA action in response. In response to the alarm that it has done much to create, FDA has now taken a variety of actions, notably to restrict access to e-cigarette flavours that are not tobacco, menthol or mint – as described in a 15 November statement by Scott Gottlieb, FDA Commissioner.
Backing for the action? But does the data support any of this regulator activity? I conclude that the partial release of data does not provide justification for FDA’s policy. This is because the data required to understand underlying changes in the pattern of tobacco use has been withheld. In other words, the data to create alarm has been released, but the data required to understand if the alarm is justified and the policy is sound has not been released. Continue reading “More heat than light – new US statistics on youth vaping provide no basis for FDA policy”