
It was a dire (though mercifully short) experience: I decided to provide a brief response to each of the many submissions to FDA issuing from UCSF under the direction of Professor Stanton Glantz. Here is my contribution to FDA deliberations in PDF form: Critical commentary on the comments on the FDA deeming rule submitted by UCSF faculty and fellows (PDF) The text and links are set out below. I summarised it in the comment section of the FDA web site as follows:
The UCSF submissions show multiple failures of fact and interpretation; inappropriate framing; and dramatic systematic biases – emphasising minor or implausible risks while diminishing or ignoring entirely very significant potential benefits.
I might have added that the cigarette based business model of the tobacco industry could not ask for better allies. Almost everything coming from UCSF on e-cigarettes will, if regulators acted on it, protect cigarette sales from competition, support a diminished market for e-cigarettes best suited to tobacco industry dominance, increase avoidable smoking and lead to more death and disease. Nice work! Continue reading “A critical commentary on the Glantz and UCSF e-cigarette submissions to the FDA”