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There is strong evidence that electronic cigarettes are much safer than tobacco cigarettes. These products contain no tobacco and do not involve combustion. Multiple studies have confirmed that there are only a few chemicals present beyond the nicotine, and so far, only trace or low levels of potentially concerning constituents have been detected - levels which are much lower than in real cigarettes. Users of these products generally report an immediate and dramatic reduction in respiratory symptoms. Moreover, there is strong evidence that electronic cigarettes can be effective in smoking cessation and that they may actually be more effective than traditional nicotine replacement products such as nicotine patches, gum, or lozenges. Even when not effective in promoting complete smoking cessation, these products generally help smokers cut down substantially on the amount they smoke, thus sharply curtailing tobacco cigarette sales.

"The findings demonstrated that manufacturers did not simply remove descriptors, to be in compliance with the law, but introduced new color-coded brand name descriptors which smokers were able to recognize and easily identify the formerly labeled "lights" brands. We did not examine the use of colors themselves, which may be protected by the First Amendment, but rather the use of color terms. The marketing materials examined make explicit the fact that the use of substituted color terms in brand names is similar to the dropped "descriptors, so that consumers will continue to recognize these brands as "lights"."

"The government has an obligation to carefully scrutinize any new consumer product that is presented as an alternative to smoking. But government agencies and public health officials have no business discouraging or disparaging e-cigarettes in the absence of any data that they are causing harm. This is especially the case when these products have so much potential to curb cigarette smoking, the public health scourge that still claims half a million lives a year."

With this disregard for the basic principles of science, the FDA is undermining literally decades of public education about the severe hazards of cigarette smoking. The FDA is negating the benefits we have accrued from the tobacco companies halting their own undermining of the public's appreciation of smoking's hazards because the agency is now doing that work for the tobacco companies.

b. Reduction in daily nicotine intake; and


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