2nd Jul 2010

Great letter From Kristin Noll-Marsh CASAA

Dear Ms. Gerrish,

My name is Kristin Noll-Marsh and I am on the board of directors for CASAA (Consumer Advocates for Smoke-free Alternatives Association.) We are a non-profit advocacy group seeking to educate the smoking public about reduced-harm tobacco alternatives. We are not funded by any electronic cigarette, tobacco or pharmaceutical company.

I recently saw your report on electronic cigarettes and noticed some inaccuracies and incomplete information that I hope you will address.

The first inaccuracy is that, while Johnson Creek may have been the first U.S. company to manufacture e-liquid, they are no longer the only company producing e-liquid in the U.S.. There is a company in Florida that also makes a high-quality e-liquid.

Second, the comment that propylene glycol is "used in some windshield wiper formulas and antifreeze alternatives" is quite misleading and incomplete. If we were to listen to Dr. Miller's opinion that propylene glycol "belongs in your car" then we must also be concerned about toothpaste, imitation food flavoring, mouthwash, intravenous medication, anti-bacterial hand creams, deodorant and a great many other products we consume both orally and topically every day. Propylene glycol is a GRAS product (generally regarded as safe) and is approved for human consumption and use by both the FDA and the EPA. The way your story portrayed it, people will be led to believe that it is highly toxic!

Third, you report that the "American Lung Association wants more research done on electronic cigarettes because at this time they are not regulated and not FDA approved," yet you failed to report that a federal judge has ruled that the FDA had failed to show that e-cigarettes are a danger to the public and that they should be treated the same as other recreational tobacco products - which is their intended use. You also failed to report that the American Lung Association receives HUGE contributions from e-cigarette's biggest competitor - nicotine products made by pharmaceutical companies. The AMA, ALA, ACS and other groups who are speaking out against e-cigarettes have failed to disclose that they stand to lose millions in contributions from pharmaceutical companies. Additionally, as a tobacco product, e-cigarettes are not required to meet safety standards any more restrictive than those required of traditional cigarettes. Traditional cigarettes do not require FDA approval. So, to state that e-cigarettes are "not FDA-approved" misleads the public into believing that e-cigarettes require FDA "approval" and deflects from the fact that tobacco cigarettes do not need FDA approval and are currently sold in just about every community.

Fourth, "Dr. Miller said the goal should be to help people quit smoking altogether, rather than swapping cigarettes for the electronic type." This statement is true - to a point. The goal IS to get people to quit smoking, HOWEVER by switching to e-cigarettes they HAVE quit smoking! There is no smoke in e-cigarettes! What Dr. Miller is really calling for is for people to quit NICOTINE. However, nicotine use (absent the smoke) has not been shown to be high risk. To fail to acknowledge that it is the SMOKE that makes some nicotine use dangerous is misleading to the public. Switching to smokeless tobacco (or electonic cigarettes) has been shown to reduce health risks by 98-99%. Suggesting that ALL nicotine use carries the same risk is irresponsible, as studies indicate that smokers who think smokeless tobacco is just as dangerous will be discouraged from making the switch. If that smoker fails to quit smoking altogether, they would at least be at considerably less risk if they'd switch while trying to quit (if they even feel the need to quit nicotine, as it's so low risk.) Something that carries only a 1-2% health risk is considerably safer than many foods and activities people expose themselves to daily.

Fifth - Dr. Miller states ""Nicotine addiction is a terrible disease, there certainly are treatments that are effective, and stopping smoking at any age is a healthy thing to do,"

Smoking and nicotine addiction are two linked yet also completely separate issues! There are many people who are addicted to nicotine who don't smoke - they use snus, strips, lozenges (products made by both the tobacco industry and the pharmaceutical industry), gums, patches, chew and e-cigarettes. SMOKING causes serious disease and death. People smoke to get nicotine. If people used an alternative nicotine source, then nicotine addiction wouldn't be any more of a terrible disease than caffeine addiction. People who use alternatives nicotine sources have reduced their risk of smoking-related disease by 98-99%. Dr. Miller, who should know better, is equating the dangers of smoking with nicotine use, when accepted research shows that nicotine does not cause the cancers and other diseases that smoke inhalation does. Look at it this way - text messaging while driving increases the risk of death. Driving without texting still carries a risk of death. However, texting is not dangerous on it's own.

Finally, your report stated "At its annual meeting this week, the American Medical Association recommended that e-cigarettes be classified as a drug delivery device. That will make them subject to FDA regulation." This is also incomplete information. If e-cigarettes are classified as tobacco products, they will also be subject to FDA regulation, they just won't be subject to FDA "approval" any more than tobacco cigarettes are subject to FDA approval under the new "Family Smoking Prevention and Tobacco Act." Should the FDA require e-cigarettes to be regulated as drug delivery devices, rather than as the intended use as recreation tobacco products, e-cigarettes will be removed from the market and hundreds of thousands of e-cigarettes users will return to smoking cigarettes. Since e-cigarettes are intended to by used as an alternative to tobacco cigarettes and not as a treatment for nicotine addiction, there is no way for them to meet the standards of a nicotine cessation product similar to pharmaceutical smoking cessation products. In effect, a much safer alternative will be removed from the market, leaving smokers only one alternative - deadly tobacco cigarettes. (By "smokers," I mean those who continue to choose to smoke to get nicotine, not those attempting to quit smoking.)

The real story here is why the FDA and all of these "public health" groups are choosing to attempt to ban an obviously much safer alternative for smokers, when tobacco cigarettes are perfectly legal. Several tests, including that one by the FDA, have revealed none of the toxic levels of chemicals and carcinogens found in tobacco smoke, yet they continue to mislead the public that they found anything dangerous. They have failed to find anything dangerous in e-cigarettes and there have been no reports of illness or injury attributed to e-cigarette use in the 6 years they have been on the market worldwide and 2 years in the U.S. On the contrary, thousands of e-cigarette users are reporting improved health and vitality and positive reports from their doctors. They also fail to reveal their financial connections to pharmaceutical companies that have the most to lose should e-cigarettes remain on the market. Considering that e-cigarette users are reporting an 80% success rate of switching fully to e-cigarettes from smoking vs. the 97% failure rate of pharmaceutical products designed for the same purpose, one can see why pharmaceutical companies (and the organizations which benefit from pharmaceutical profits) would see e-cigarettes as a threat to their bottom line. And the claim from these groups that e-cigarettes are a threat to or are targeting children has no valid evidence. A CASAA survey of over 2,200 e-cigarette users put nearly 90% of users over the age of 26 and 78.3% over the age of 30 and all of them were smokers before switching. Despite the sweet flavors available and the "slick advertising" that opponents claim attract children, the high cost, limited availability compared to traditional cigarettes (online sales require credit cards and most stores already have a "no sales to minors" policy in place) and lack of the "coolness factor" serve as greater deterrents that far outweigh any attraction.

By all means, forbid e-cigarette companies to advertise as being healthy or 100% safe. Require child-safe packaging and ingredient lists. Put nicotine warnings on the label. Conduct inspections of the manufacturers to make sure they aren't using unlisted or hazardous ingredients and are using proper sanitation procedures.

But to require e-cigarettes to be removed from the market until they can be proven as safe and effective as products that are meant for a completely different purpose - all while traditional cigarettes remain available on the market - defies all reason.

Some other opinions about e-cigarettes:

The American Association of Public Health Physicians (recognizes by the AMA) has come out in support of e-cigarettes - "The AAPHP Task Force, on the basis of extensive literature review and analysis, has concluded that a national harm reduction initiative, based partly on the potential attractiveness of E-cigarettes to current smokers, could save the lives of 4 million of the 8 million current adult American smokers who will otherwise die of a tobacco-related illness over the next 20 years." (Source: Joel L. Nitzkin, MD, AAPHP White Paper: The E-Cigarette in the Context of Overall Tobacco Control)

Dr. Elizabeth Whelan, president of the American Council on Science and Health stated, "Cigarette smoking remains the leading cause of preventable disease and death in the United States today. Any alternative acceptable to addicted smokers should be taken seriously. Instead of condemning the e-cigarette, the FDA should be sponsoring studies to evaluate its safety and efficacy -- leaving it on the market in the interim."
FDA Smoke Screen on E-Cigarettes (from the Washington Times) > Health Issues > ACSH)

Bill Godshall, of Smokefree Pennsylvania states, "Smokefree Pennsylvania and other tobacco harm reduction advocates have been urging the FDA to reclassify and to reasonably and responsibly regulate e-cigarettes as tobacco products (instead of trying to ban them by claiming they are drug devices), and have been urging the FDA to begin to truthfully inform smokers and the public that e-cigarettes and other smokefree tobacco/nicotine products are far less hazardous alternatives to cigarettes that pose no known risks to nonusers." (Source:
Bill Godshall at Vapefest 2010 Tobacco Harm Reduction: News & Opinions)

Dr, Michael Siegel is a professor in the Department of Community Health Sciences, Boston University School of Public Health. He has 25 years of experience in the field of tobacco control. He previously spent two years working at the Office on Smoking and Health at CDC, where he conducted research on secondhand smoke and cigarette advertising. He has published nearly 70 papers related to tobacco. He supports e-cigarettes and he gives the opinion that, "Inhaling nicotine cannot be nearly as dangerous as inhaling nicotine plus thousands of other chemicals, including more than 40 carcinogens. It doesn't take long-term studies to make that determination. As David Sweanor astutely pointed out, determining that a tobacco-free nicotine delivering product is safer than a product that delivers nicotine with thousands of tobacco smoke constituents is a fact of basic science, and anyone who challenges such a notion would probably benefit from a remedial course in basic sciences.
Whether electronic cigarettes are safer than conventional cigarettes is really a non-issue. The real questions are how effective the product is in helping smokers keep off cigarettes, how electronic cigarettes could figure into a long-term strategy for promoting smoking cessation, and what specific messages about electronic cigarettes and health would be appropriate to communicate to the public." (Source:
E-Cig Interview with Michael Siegel)

If you would like to discuss this further, CASAA welcomes the media to investigate the inconsistantand irrational claims against e-cigarettes, as well as those against other reduced-harm tobacco products. The public deserves to know the WHOLE truth.

Kristin Noll-Marsh
***-***-**** (phone)
CASAA | The Consumer Advocates for Smoke-Free Alternatives Association