1. Altria Client Services (on behalf of Nu Mark): "Nothing in the FSPTCA [Family Smoking Prevention and Tobacco Control Act] requires FDA to engage in all-or-nothing deeming for all purposes. Rather than deem an entire class of tobacco products categorically subject to the FSPTCA for all purposes, FDA has multiple options for proceeding in a reasoned, scientifically sound, and incremental manner. For example, FDA should exercise its statutory authority to deem e-vapor products commercially marketed before the Final Rule for certain purposes under the FSPTCA. Such products would be subject to age restrictions, warning labels, and disclosure requirements, without subjecting them to premarket authorization. Only those e-vapor products commercially marketed after issuance of the Final Rule would be subject to ... premarket authorization."

Many anti-smoking groups and advocates have been opposing electronic cigarettes on the grounds that these products perpetuate or even increase nicotine addiction, rather than decreasing it. But a new study presented at the 2014 annual conference of the Society for Research on Nicotine and Tobacco (SRNT) provides evidence that nicotine addiction levels are actually decreased, not increased, in smokers who have switched to electronic cigarettes.

Hopefully, the FDA will look towards a little higher level of scientific evidence and reasoning before it promulgates its final e-cigarette regulations.

Unfortunately, there have been numerous violations of this disclosure standard, as several commentators on electronic cigarette policy have failed to disclose their Big Pharma ties in published articles. I have highlighted many of these stories on my blog, but for one demonstrative example, see my on failed disclosures by an individual and an organization in the New York Times debate on electronic cigarettes.

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