The Long Game.

The WHO released the documents for the Convention of the Parties number 7. The COP is a little get together of all 180 signatories to the framework convention on tobacco control. They get together every two years and discuss tobacco control stuff. With 180 countries it must be like herding cats.

They are hyper paranoid about the tobacco industry finding out what they discuss, so they ban anyone and everyone who might be connected to the tobacco industry from attending. Last time they closed the doors, shut down wifi and kicked out all journalists from observing. This time, their paranoia has grown to the point where they are considering banning government representatives from the 180 countries from attending! It’s like they have something to hide!

 

Anyway, last time was the first time they looked at the issue of electronic cigarettes. Of course, they had to invent a scary acronym for what the rest of us just call E-Cigs and they adopted ENDS. Electronic.Nicotine.Delivery.Systems. Sounds broad enough and I’m sure they thought it would cover everything they felt needed to be covered.

Well, they sat and talked, listened to some sage counsel and still made a hames of it as far as e-cigs (or ends) are concerned. They wanted public use bans, advertising bans, bans on flavors and all sorts of tobacco control measures applied to what is not a tobacco product. I’m not sure what drove this, fear of tobacco industry taking over the market, fear of health risks or fear of nicotine becoming a hazard free consumer choice. Found this clue in the previous COP6 review.

Article 5.2(b) of the Convention commits Parties not only to preventing and reducing tobacco consumption and exposure to tobacco smoke but also to preventing and reducing nicotine addiction independently from its source. Therefore, while medicinal use of nicotine is a public health option under the treaty, recreational use is not.

Yeah, they don’t like it!

Snail Run Near The Finish Line

Anyway that was 2 years ago and science has moved on, the RSP report came out as did PHE’s review, the next COP, COP7 should reflect this advance. As they let us have a look at the report, I thought I give it a review to see what had changed.

Electronic Nicotine Delivery Systems and Electronic Non-Nicotine Delivery Systems (ENDS/ENNDS)

Well, that’s new! Electronic non-nicotine delivery systems? I guess ENDS wasn’t broad enough.  Now they have captured everything from e-cigs to the internet to voice mail, pretty comprehensive I’d call that.

This report builds on the last one without moving from the initial position of bans, bans and more bans, Oh, they added taxes this time. It’s spread over 33 points and I’m going to cover the main ones so this is going to be a long read. Sorry.

1 to 4. Introduction and explanation of terms. Fair enough!

5;

If the great majority of tobacco smokers who are unable or unwilling to quit would switch without delay to using an alternative source of nicotine with lower health risks, and eventually stop using it, this would represent a significant contemporary public health achievement. This would only be the case if the recruitment of minors and non-smokers into the nicotine-dependent population is no higher than it is for smoking, and eventually decreases to zero

This is just factually wrong. It would be a significant public health achievement whether or not it eventually decreased to zero. To say otherwise is ideology and diminishes the huge impact smoking has on health in favor of implicating nicotine.

6;  Mentions heat not burn. I wonder if they will need another acronym next time?

7 to 11; Is about toxicants and contains this;

long-term use is expected to increase the risk of chronic obstructive pulmonary disease, lung cancer, and possibly cardiovascular disease as well as some other diseases also associated with smoking

Increase from what? the level caused by smoking? from zero which does not exist? There is no evidence at all that this is expected to happen. None. Nil. Zero. In fact, the expectation is ENDS would reduce the risk by 95%  Why isn’t this in this report? The only mention of the PHE report oddly enough is The magnitude of these risks is likely to be smaller than from tobacco smoke which is an understatement of the 95% less harmful estimate.

12;  Nothing more than an argument, that as we can find no evidence of harm there may be no method to find, it must exist. Or some weird logic they only understand.

13 14 and 15; Second-hand exposure, it’s not just air, therefore…ban it!

16 and 17; Claims no evidence they help smokers quit. I’m not sure this is relevant one way or another, e-cigs are not being marketed as cessation therapy in the main. One e-cig has been granted a licence as a cessation product but hasn’t come to market yet.

 

18 19 and 20; The Gateway! Given we hear so much about this it’s surprising it only gets 3 small paragraphs. No evidence they say but strong indications.Of course for this exercise they include nicotine use as the other side of the gate rather than smoking. Might that be because youth smoking rates are falling like a lead balloon in markets where e-cigs are available?

21; Advertizing and marketing. No real meat here, mostly speculation.

22; The big bad wolf! Tobacco industry involvement and the threat to the precious FCTC. What’s interesting is they recognise that both the TPD and the FDA regulations are a boon to the tobacco industry, they seem to view this as inevitable and best to just treat the whole thing as a tobacco plot in the first place. Siege mentality at work.

23 to 32; Regulatory options. “Parties that have not banned the importation, sale, and distribution of ENDS/ENNDS may consider the following options:” because banning is the prefered option but some pesky vapers fought that and so we must respond with as strict a regime as possible.

a. Banning the sale and distribution of ENDS/ENNDS to minors;

b. Banning the possession of ENDS/ENNDS by minors;

c. Banning or restricting advertising, promotion and sponsorship of ENDS/ENNDS (see FCTC/COP/6/10 Rev.1);

d. Taxing ENDS/ENNDS at a level that makes the devices and e-liquids unaffordable to minors in order to deter its use in this age group. In parallel, combustible tobacco products should be taxed at a higher level than ENDS/ENNDS to deter initiation and reduce regression to smoking;

e. Banning or restricting the use of flavours that appeal to minors;

f. Regulating places, density and channels of sales; and

g. Taking measures to combat illicit trade in ENDS/ENNDS

Banning possession? That’s not even done for cigarettes or alcohol! Taxing ends/ennds and raising tobacco taxes to maintain the gap! A gap they say exists the other way earlier in this report! Banning flavors that appeal to minors. Which flavors exactly and what about the effect this has on uptake by adults? Channels of sale? I suppose they mean restricting to licenced tobacco vendors. Banning cross border and internet sales, you know the kind of stuff that gives the market to their sworn enemy the tobacco industry.

i. Testing heated and inhaled flavourants used in the e-liquids for safety, and banning or restricting the amount of those found to be of serious toxicological concern such as diacetyl, acetyl propionyl, cinnamaldehydes or benzaldehyde;

ii. Requiring the use of ingredients that are not a risk to health and are, when allowed, of the highest purity;

iii. Regulating electrical and fire safety standards of ENDS/ENNDS devices;

iv. Regulating the need for manufacturers to disclose product content to government; v. Regulating appropriate labelling of devices and e-liquids;

vi. Requiring manufacturers to monitor and report adverse effects; and

vii. Providing for the removal of products that do not comply with regulations.

This is all obvious stuff, the devil will be in the detail. No ii is interesting as they clearly state all ingredients pose a risk to health earlier in the report so I’m guessing they meant to say “Ban them”

i. Prohibiting by law the use of ENDS/ENNDS in indoor spaces or at least where smoking is not permitted;

ii. Requiring health warnings about potential health risks deriving from their use. Health warnings may additionally inform the public about the addictive nature of nicotine in ENDS; and

iii. Reducing the risk of accidental acute nicotine intoxication by a) requiring tamperevident/child resistant packaging for e-liquids and leak-proof containers for devices and e-liquids and b) limiting the nicotine concentration and total nicotine amount in devices and e-liquids.

More bans. The first one has no justification under any definition of public health. Though I have seen Ruth Malone try to shoehorn annoyance as a public health issue. The last, iii, is already standard industry practise and law in the EU and the US.

a. Prohibiting implicit or explicit claims about the effectiveness of ENDS/ENNDS as smoking cessation aids unless a specialized governmental agency has approved them;

b. Prohibiting implicit or explicit claims that ENDS/ENNDS are innocuous or that ENDS are not addictive; and

c. Prohibiting implicit or explicit claims about the comparative safety or addictiveness of ENDS/ENNDS with respect to any product unless these have been approved by a specialized governmental agency.

I have a real problem with C. E-cigs are prohibited from comparative risk claims unless a gov agency has approved them. What does this mean? That e cigs can not  quote the RCP report, that unless you apply for permission to quote PHE you can be prosecuted for telling the truth? TBH it sounds like guff stuck in to cover all bases.

a. Raising awareness about potential industry interference with Parties’ tobacco control policies;

b. Establishing measures to limit interactions with the industry and to ensure transparency in those interactions that do take place;

c. Rejecting partnerships with the industry;

d. Taking measures to prevent conflicts of interest for government officials and employees;

e. Requiring that information provided by the industry be transparent and accurate; f. Banning activities described as “socially responsible” by the industry, including but not limited to activities described as “corporate social responsibility”;

g. Refusing to give preferential treatment to industry; and

h. Treating State-owned industry in the same way as any other industry.

The real objective; public health and specifically tobacco related public health is our ball. No one else can play.

All of the above serving suggestions come with the preamble “Parties that have not banned the importation, sale, and distribution of ENDS/ENNDS may consider the following options;” Just in case they didn’t make it clear enough that banning them outright is the prefered option.

This is not going to be over soon, the WHO are playing a long game, slowly maneuvering the vaping industry under its remit by forcing regulation that hands the emerging industry to big tobacco, shifting goal posts to nicotine cessation and capturing nicotine as a medicinal produce. That last goal may be the end game they are playing for. Much more than the stated goal of “combating the tobacco epidemic”

Well, it got me thinking and not happy thoughts about unicorns!

 

 

 

 

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