The Worst Letter Ever Written?

About the author Oliver Kershaw Founder of e-cigarette-forum.com and co-founder of vaping.com

The entire public health establishment of the United States attempts to strong-arm the FDA into making unscientific decisions by lying to the President - read the letter here

Yup - they’re lying to the President. This is, no mistake, serious scandal at the very top and it needs to be called out.

Yesterday, the who’s who of US public health wrote to the President asking him to force the FDA to rush through its regulations, using hearsay and unsubstantiated talking points to do so. In doing so, they fail to even address a central issue: that rushed-through decisions have the potential to (indeed, are almost certain to) cause the early deaths of current smokers on an almost unimaginable scale.

And make no mistake - this is public health behaving exactly the same way the tobacco industry used to behave during the ignominious days of the tobacco wars. This is pure “merchants of doubt” stuff; absolutely textbook, and it’s almost the definiton of irony.

The FDA has not yet deemed the products for one simple reason: It’s not ready to - it quite clearly has zero confidence in any of the science to make decisions currently.

And rightly so - the science coming from its TCORS centres is trivial and biased as regards e-cigs (it looks only at threat, and not at potential), and there is not yet good data in the US (although contrast with the UK) to ascertain to what extent e-cigarettes are causing a population-level drop in overall smoking rates. The PATH study will be able to demonstrate this, but it’s not due to file until next year.

The letter-writers rely entirely on arguments that are mainly half truths, but sometimes wander into flat out lies of commission and ommission. What they rely on, in no way, shape or form, is anything approaching science.

Most insidiously, data from the CDC’s National Youth Tobacco Survey, which has also had much airing in the national and international press, is again misrepresented as demonstrating that there is a serious and troubling access and use by youth. This is a serious lie which originates from Tom Frieden, and he should be brought to book on it. Therein the letter demands a course of action that will limit the access of adult dependent smokers to products that may save their lives. Specifically, they demand the removal of flavorings - a facet that vapers have again, and again, stated unequivocally are a fundamental feature of the products which help them move away smoked tobacco.

Image: April 2015 ECF big survey of 10k vapers.

And, notably absent in the letter is any mention that cigarette smoking rates have absolutely plummeted in the last year amongst adolescents. And by plummeted, I mean, dropped through the floor. Check out this image from the FDA’s own infographic:

So we know, for sure, that e-cigarettes are not increasing smoking amongst adolescents overall, even if we can’t say for sure that e-cigarettes are the reason for the decline. But the public health groups didn’t even allude to this fact. This is lying through omission. Important questions that the NYTS cannot answer on e-cigarettes: How many adolescents use e-cigarettes with nicotine as opposed to without? How many adolescents are daily-dependent users of e-cigarettes? How many adolescents have started never having smoked, but gone onto become daily dependent users of e-cigarettes? The data cannot show the answers, because the CDC is not asking the right questions yet is presenting the data as if it is the same as the smoking data. It is not.

Now, it’s completely true that you cannot say that e-cigarettes are responsible for this decline. However, it’s also true to say two additional things - firstly, if harm reduction worked, and were real, this is precisely what one would see. Secondly, there have been no major new initiatives over the last year that would remotely explain this drop, a point David Sweanor has made elsewhere.

http://www.nytimes.com/2015/04/18/opinion/joe-nocera-peering-through-the-haze.html

The second, completely unsupported assertion is that the increase in e-cigarette use is due to flavors - and specifically ones such as “ cotton candy, gummy bear, bubble gum, and other flavors that appeal to kids” (with no evidence whatsoever that this is the case). It uses this assertion to demand that the FDA specifically remove flavors from the products.

Third, is just a decontextualised piece of scaremongering which also lies throughout: that poisonings have increased dramatically over the last few years.

What they actually refer to are calls to poison centres, but does not give ANY indication of the number of actual poisonings at all. Whatsoever. And in any case, look at the overall figures for calls to the poisoning centres and where e-cigarettes figure, right now, despite being in millions of homes across America.

Image: By Clive Bates, from APPC data - Counterfactual

And, finally, the worst lie of all: That the entire industry is simply the preserve of the Tobacco Industry: a new way for this long-time nemesis of the health of the nation to hook impressionable adolescents. As opposed to what it, right now, is on course to be - the very agent of its demise.

In fact, there’s an abundance of evidence that hundreds of thousands of smokers have transitioned fully to vaping devices. Possibly millions - and millions more clearly will if the devices are allowed to continue the path of innovation and disruption they’ve plowed for the last 7 short years. The tobacco industry has only a small stake in the overall market, and so far seems to have no clear strategy for competing in the truly interesting and disruptive open-vapor space.

I attended the lunchtime presentation at the FDLI annual conference last week, which was presented by Nancy A. Brown, one of the signatories of the letter and the CEO of the American Heart Association. She flagged up E-Cigarettes as one of the threats against the AHA’s plan for “perfect cardiovascular health for all” - a quixotic task, if ever one was said to exist, given that by their own standards only 1% of the US population currently have this wondrous pulmonary distinction. So, I was struck by something that’s perfectly obvious: Perfection is absolutely the enemy of the good. Presumably she expects other means than harm reduction to persuade the 40 million plus US smokers to stop smoking - a behaviour which unquestionably puts the greatest burden on the nations healthy-heart statistics. But, no, e-cigarettes are simply a threat to the youth (despite no evidence for this) and are, therefore, just a threat.

This, I think, is the source of the utter moral panic being exhibited by these groups. Smokers are a detested group - possible the last socially sanctioned outsider group - and they are being thrown under the bus in the pursuit of the Public Health groups’ vision of a perfect world. The president should ignore them, allow the FDA to do proper diligence and to come out with regulations that maximise the potential of these revolutionary devices. Right now, they are actively endangering the health of a huge chunk of the American population.

And, coincidentally, the UK's Smoking Toolkit Study results for the last quarter were published yesterday. Professor Robert West, UCL, who conducts the study suggests that last year 20k smokers quit using cigarettes who otherwise would not have quit. In the presentation, he also provides this graphic, which really underscores the tragedy of what's happening here:

If public health groups realized the puplic health opportunity, and stopped lying about the threat, this 20k in the UK would be so much more. This is real harm being inflicted at a population level by those same groups that are supposed to be protecting health.