The biggest problem with Stan's approach is that when you examine e-cigarette users who are not using the product to quit, you are introducing a huge sampling bias. For example, why might someone use e-cigarettes, but not to quit? Most likely, the majority of vapers who are using e-cigarettes for a purpose other than cessation are using e-cigarettes to cut down on the amount they smoke. They are likely to derive benefits from smoking reduction. However, they are almost assuredly not going to quit smoking because they are not trying to quit, nor do they have such a desire.

The methods of the study were as follows: "Individuals were recruited at e-cigarette retail locations in a large metropolitan city in the midwestern portion of the United States in July 2013. A total of 159 participants completed a brief 29-item self-report measure that assessed behaviors and perceptions of use."

The FDA's Center for Tobacco Products simply does not have the capacity to review 22,000 new product applications. After all, it has taken more than 4 years for the agency to even begin to process the more than 3,500 substantial equivalence applications submitted by tobacco companies, and as of this date, there are still thousands of those applications pending. It is easy to see that the proposed deeming regulations would create a bureaucratic nightmare.

In a submission to the FDA regarding the proposed deeming regulations, Stan Glantz and colleagues have called on a by electronic cigarette companies: namely, stating that electronic cigarettes are safer than tobacco cigarettes. The authors of this comment want the FDA to expressly prohibit electronic cigarette companies from informing consumers that vaping is safer than smoking.

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