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In December 2014, the FDA held the first of a series of \u201cworkshops\u201d in which \u201cexperts\u201d are invited to inform them about the physical characteristics of e-cigarettes. It should be no surprise that the people who were granted time to speak were largely non-experts and that consumer representatives were closed out of this meeting. This is your opportunity to help remedy that<\/b>. If you watched the workshop, you know what we are talking about. If you did not, all you need to know is that FDA sought the opinion of people who presented information at about the level you might see in a magazine article on e-cigarettes.<\/p>\n
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Please note that the comments we are asking you to submit are for the first workshop (December 10 and 11, 2014). The second FDA workshop last week was much the same. The speakers were somewhat more expert, but still could have learned a lot from a consumer representative, and yet our application to include CASAA experts on the program was refused. We will have an opportunity to comment on that meeting later.<\/p>\n
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FDA claims that these workshops have nothing to do with their decision about whether and how to impose the \u201cdeeming\u201d regulations and are only to inform the eventual regulation, but this is ridiculous. Whatever information flows now will obviously affect both.<\/p>\n
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The good news is that consumers and other experts on e-cigarettes have an opportunity to comment on this matter.<\/b><\/p>\n
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We know that the vaping community — which includes everyone from small manufacturers, to DIY modders, to consumers who make themselves expert on the hardware or liquid — has more collective expertise than FDA and their supposed \u201cexperts.\u201d \u00a0We need to collect examples.<\/p>\n
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1st –<\/b> Please try to recall your favorite writings on the relevant topics from: threads on ECF or other forums; informative blog posts by consumers, consumer advocates, or vendors; how-to videos; etc. \u00a0Keep in mind that the topic at hand is characteristics of e-cigarette hardware and liquid<\/b>, including variations, modding options, etc.<\/p>\n <\/p>\n There are tens of thousands of great threads and posts out in the world that cover these topics, providing consumers with useful information about the products. **Please make sure that the material is high-quality<\/strong>. (A few bad posts on a forum thread are inevitable, of course, but keep in mind that you are demonstrating that <\/i>we are more expert than their \u201cexperts.\u201d<\/i><\/b>) Also, please do not include material that is primarily about smoking cessation or other behavioral issues; this is specifically about physical characteristics of the devices, liquids, and vapor.<\/i><\/p>\n <\/p>\n 2nd –<\/b> Collect a list of these \u2013 at least one or two of them — and ten or a hundred if you want \u2013 and make them part of a comment (talking points provided below).<\/p>\n <\/p>\n <\/p>\n <\/p>\n 3rd –<\/b> Submit your comment <\/strong>here<\/b><\/a><\/strong>. The Deadline is April 15, 2015.<\/p>\n <\/p>\n Required and Suggested Talking points – <\/b><\/p>\n <\/p>\n <\/p>\n Sample Letter –<\/b><\/p>\n <\/p>\n To: U.S. Food and Drug Administration<\/p>\n Re: Electronic Cigarettes and the Public Health; Public Workshop; 79 FR 55815, September 17, 2014, Docket No. FDA-2014-N-0001<\/p>\n Date:<\/p>\n <\/p>\n I am a consumer, writing on my own behalf. \u00a0<DESCRIBE YOURSELF><\/b>. I am writing to comment on \u201cElectronic Cigarettes and the Public Health; Public Workshop; 79 FR 55815, September 17, 2014, Docket No. FDA-2014-N-0001.\u201d This docket fol lows up on a workshop you held in December 2014 that was intended to hear expert presentation about physical and performance characteristics and variations of e-cigarettes and their toxicological and other implications.<\/p>\n <\/p>\n It was apparent from the material presented at that workshop that the event could have greatly benefitted from expertise that exists in the consumer community. Many e-cigarette consumers, like myself, watched the workshop presentations. The simplis tic assessments coming from many (if not most) of these hand-picked \u201cexperts\u201d were \u00a0so inexpert and so clearly politically motivated that it was actually insulting.<\/p>\n <\/p>\n I am commenting to call attention to some of the enormous body of knowledge and expertise that exists in the consumer community. Please consider the following material that came from consumers and\/or small producers who are close to the consumer community:<\/p>\n <\/p>\n <\/p>\n For convenience, I have provided copies of the content from these links as part of this comment.<\/p>\n <\/p>\n Once you review this material and similar material from other consumers, it should be apparent that FDA\u2019s level of expertise, and that of its supposed experts, is inadequate. FDA should be reading what is already known in the world, not tryin g to reinvent the wheel. FDA should get itself up to speed on this material, which already exists, before it presumes to judge who is even expert enough to comment, let alone before it bans 99.99% of the products on the market, as it is currently proposing.\n
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\nThank you for considering my comments.<\/p>\n
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