Clearly, this requested action brings up significant issues under the Compact Clause, issues which certainly do not qualify for an exception from this clause under the Supreme Court's decision in United States Steel. (For a detailed discussion of how enforcing the MSA on electronic cigarette companies would violate the Compact Clause, see the excellent submitted by the Competitive Enterprise Institute in S&M Brands.)

While the study must be viewed as providing only preliminary evidence and further confirmation is necessary, this is important research because it suggests that contrary to the assertions of many anti-smoking advocates, switching from tobacco cigarettes to electronic cigarettes decreases rather than increases the level of addiction to nicotine. Smokers who make the switch are less addicted and feel better prepared and better able to quit completely.

This study, although limited to only three brands of electronic cigarettes, provides reassuring evidence that there do not, at present, appear to be major concerns about substantial health hazards associated with secondhand exposure to electronic cigarettes.

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