If a company were to make such a claim, it would constitute a reduced exposure claim, which is prohibited under section 911. To make matters worse, such a claim can only be approved by the FDA if the company shows that if consumers hear that the product is free of tobacco, they will not be led to believe that the product is safer. In other words, to simply make the truthful and uncontroversial claim that your electronic cigarettes are free of tobacco, you would have to first demonstrate that consumers will not interpret the absence of tobacco as indicating that the product is any safer. But we know for a fact that consumers will interpret (and should interpret) the absence of tobacco as an indication that vaping is safer than smoking. Therefore, the deeming regulations place a de facto, permanent ban on electronic cigarette companies making the simple claim that their products do not contain tobacco.

This issue is particularly important because based on the arguments of these authors, the FDA should ban filtered cigarettes in order to protect the public's health. But in my opinion, such a move could be disastrous because it would result in a dramatic increase in tar delivery and possibly carcinogen dose, potentially leading to an increase, rather than a decrease in cancer.

You may wonder why I am calling these people - smokers who have quit smoking via electronic cigarettes - anecdotes.

The study concludes: "Among smokers who have attempted to stop without professional support, those who use e-cigarettes are more likely to report continued abstinence than those who used a licensed NRT product bought over-the-counter or no aid to cessation."

The Marini study demonstrates that electronic cigarettes do lead to a reduction in exhaled nitric oxide, which suggests that they have a mild respiratory irritant effect and induce some inflammation in the airways. This is a finding which has been reported previously in a number of studies. It is not surprising because propylene glycol is known to be a mild respiratory irritant.

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