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While the deeming regulations pretend to acknowledge that there is "a continuum of nicotine-delivering products" in terms of their health risks, the truth is that the agency fails to acknowledge that the most hazardous product along that continuum - cigarettes - are any more hazardous than the least dangerous product (non-tobacco electronic cigarettes).

Here, they find a correlation between e-cigarette use and higher and more sustained levels of smoking. But because this is a cross-sectional study, they cannot determine which came first. In other words, what is the direction of the causal relationship? Does the e-cigarette use precede, and cause, the smoking? Or does the smoking precede, and cause, the e-cigarette use?

Hopefully, the New York City Council will vote down this proposal. If policy makers are interested in protecting kids from electronic cigarettes, they should focus on regulating the sale and marketing of these products - just as we do with the real cigarettes. It makes no sense to ban the entire product category, especially when we know these products are helping many smokers quit or cut down and when there is no evidence that the use of these products is causing youth to become addicted to smoking, or even to e-cigarette use itself.


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