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• Response to Noel et al re Electronic Cigarettes
  Joel L Nitzkin
  Published on: 5 January 2011

• Published on: 5 January 2011

  Response to Noel et al re Electronic Cigarettes

  • Joel L Nitzkin, Principal Consultant

  The commentary by Noel, Rees and Connolly on E-cigarettes is truly remarkable. They appear to draw the conclusion that E-cigarettes represent a potentially substantial hazard to the American public that requires "efforts . . . to counteract e-cigarette industry marketing and inform regulatory strategies," then urge research to justify the conclusions they have already reached. All this was done without considering the res...

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  The commentary by Noel, Rees and Connolly on E-cigarettes is truly remarkable. They appear to draw the conclusion that E-cigarettes represent a potentially substantial hazard to the American public that requires "efforts . . . to counteract e-cigarette industry marketing and inform regulatory strategies," then urge research to justify the conclusions they have already reached. All this was done without considering the research already done by the E-cigarette industry and others relative to the chemical quality of their products and marketing policy.

  Questions related to the quality of manufacture or marketing of E- cigarettes can be resolved by FDA regulating them as the tobacco products they are intended to be. Under the new FDA tobacco law, FDA has all the authority it needs to assure quality and consistency of manufacturing and to regulate marketing as needed to prevent sales to minors. The fact that FDA has not taken such action is the fault of FDA, not the E-cigarette manufacturers or vendors. E-cigarettes are intended as a substitute for cigarettes for smokers unwilling or unable to quit, yet desiring to all- but-eliminate their exposure to the other toxic substances in cigarette smoke.1

  From February of 2007 through February of 2010, I served as Co-Chair of the Tobacco Control Task Force of the American Association of Public Health Physicians. In that context I explored policy options for rapidly and substantially reducing tobacco-related illness and death among current American tobacco users. This research led to the conclusion that almost all tobacco-related illness and death in the United States is due to the smoking of cigarettes and that alternative smokeless tobacco and nicotine products, including but not limited to snus, E-cigarettes and the pharmaceutical NRT products, pose a risk of tobacco-related death less than 2% the risk posed by cigarettes.2,3 In this context, it seemed clear that a harm reduction initiative based on informing smokers of the difference in risk posed by the different types of tobacco/nicotine products, accompanied by effective FDA regulation of the manufacture and marketing of all such products held the best possible hope for securing rapid and substantial reductions in tobacco-related illness and death among current smokers while minimizing initiation of tobacco use by teens in the USA.

  The "informed public health response" recommended by Noel et al can be provided by regulation of E-cigarettes by FDA as the tobacco-based products they are intended to be.

  Joel L. Nitzkin, MD

  References

  1. Nitzkin JL, jln-md@mindspring.com. Citizen Petition (to FDA) to Reclassify E-Cigarettes from "drug-device combination" to "tobacco product" [<http://www.aaphp.org/special/joelstobac/2010/Petition/20100207FDAPetition1.pdf>]. 2. Nitzkin JL, Rodu B. AAPHP Resolution and White Paper: The Case for Harm Reduction for Control of Tobacco-related Illness and Death [http://www.aaphp.org/special/joelstobac/20081026HarmReductionResolutionAsPassed1.pdf]. 3. Rodu B, Nitzkin JL, jln-md@mindspring.com. Update on the Scientific Status of Tobacco Harm Reduction, 2008-2010 Prepared for the American Association of Public Health Physicians [http://www.aaphp.org/special/joelstobac/2010/harmredcnupdatejuly2010.html]

  Conflict of Interest:

  None declared

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  Conflict of Interest:
  None declared.

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