A critical commentary on the Glantz and UCSF e-cigarette submissions to the FDA

Screen shot FDA deeming regs page
Click to access the FDA page


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”

Turning the tables on public health – let’s talk about the risks *they* create

I’m here to tell you what to do, not to take responsibility for it

I’ve had enough of the one-sided conversation about the risks associated with e-cigarettes… poisons, gateways, renormalisation, fires, explosions, MRSA, pneumonia, dual use, undermining tobacco control, nitrosamines, anti-freeze, particulates, heavy metals, dead dog, dead cat…. blah blah blah.

ENOUGH! The public health establishment is conspicuously failing to recognise the risks associated with its preferred policy responses to e-cigarettes: with not having e-cigarettes, with banning snus, with prohibiting vaping in public places, with confusing people about risks, with controlling everything.  They carry on as if these risks are zero or somehow not their responsibility – but they are all plausible and all end in more smoking and more cigarette sales. We need to press them much more assertively on the risks they create and the harms their ideas may do:

  • “do you accept these risks are plausible and can you see how and why they might arise?”
  • “what evidence do you have regarding these risks?”
  • “what make you so confident your policy ideas will not cause more harm than good?”
  • “at what level of risk would you stop advocating these policies, or at least call for more evidence?”

For almost every policy idea there is for regulating harm reduction, there is a realistic risk that it will make things worse for health. And for almost every theoretical risks from vaping, there is a more plausible theoretical benefit. Let’s consider the following:
Continue reading “Turning the tables on public health – let’s talk about the risks *they* create”

Rogue research group opens the slurry gusher again

Slurry gusher: over-claim, over-hype and then spread it...
Slurry gusher: over-claim, over-hype and spread it…

Within a couple of weeks of a fake gateway effect discovery, more bogus science emerges, stretched to the limits of credulity and then hyped beyond to the media and into the grateful arms of the suggestible, wide-eyed world of tobacco control.  This time it is Rachel Grana and colleagues at University of California at San Francisco, part of Professor Stanton Glantz’ group, which is rapidly becoming a slurry gusher of black propaganda, media-political spin and unethical practice. The release follows an established track: Continue reading “Rogue research group opens the slurry gusher again”

Cease and desist: making false claims about the gateway effect

Gateway effect: maybe… but is it an entrance or exit?

I am totally exasperated by spin about the so-called gateway effect.

Unable to take any more, I decided to write to Professor Stanton Glantz and Dr Lauren Dutra, the authors of an analysis of teenage smoking and e-cigarette use based on the US National Youth Tobacco Survey:  Dutra LM, Glantz SA. Electronic Cigarettes and Conventional Cigarette Use Among US Adolescents. JAMA Pediatrics  online 6 March 2014. I hope the letter is self-explanatory. Update: reply from Professor Glantz and my response to his reply.

Continue reading “Cease and desist: making false claims about the gateway effect”