CSUR study of FDA deeming regs predicts rise in ‘black market’ products

The UK’s Centre for Substance Use Research (CSUR) recently conducted a survey of 9,040 current e-cig users in the United States only to find that the FDA deeming regulations are leading to an increased interest in black market vaping.  The study was led by Drs. Christopher Russell and Neil McKeganey, and the purpose of the online survey was to identify how the new regulations might ultimately effect vaping behaviors and public health in America and elsewhere. 

Like many scientists before them, Russell and McKeganey believe that the FDA is significantly misrepresenting the many health benefits of e-cigs as a smoking cessation alternative.  They are also quick to point out that the FDA still has not offered any public recommendations to the nearly 8.34 million current e-cigarette users in the United States for how to avoid the pitfalls of traditional cigarettes once their vaping products are no longer available. 

“However, FDA has made no statement about what it expects these 8.34 million current e-cigarette users will do if and when they are no longer able to legally buy the e-cigarette products they currently use, and more importantly, whether these future behaviours will increase or decrease these individuals’ risk for exposure to toxicants. That is, while FDA’s pre-market tobacco application (PMTA) process will require manufacturers who wish to keep an e-cigarette product on the market after August 8th 2018 to provide estimates of how population toxicant exposure will change as a result of introducing the product into the market – by conducting research on the product’s toxicity and likelihood of uptake by population sub-groups – FDA has not publicly stated the extent to which population toxicant exposure is anticipated to change as a result of withdrawing the majority of e-cigarette products from the licit market after August 8th 2018.”

- From CSUR’s soon-to-be-released report:
  Intended Responses of 9,040 Current E-Cigarette Users to the U.S. Food

 According to CSUR, the FDA is more concerned with wiping out the American vaping industry than in protecting its citizens from the toxins of smoked tobacco.  If e-cigs and vaping devices are ultimately eliminated from the marketplace, as the FDA deeming regulations clearly are attempting to do, then what do these millions of e-cig users do next?  If they return to smoking tobacco cigarettes, “population toxicant exposure” will only return to the levels of the early 2000s.  And since vapers don’t want to return to smoking, they might begin buying their products through more unconventional methods.

Black Market Vaping and the FDA deeming regulations

CSUR sent an email to each of the 9,040 participants stating that the survey led to four rather interesting predictions.  The entire letter is copied below:

To be clear, CSUR is not saying that over 60% of current e-cig users are considering turning to black market products as an alternative.  Black market vaping is only one of four possibilities that appear to be the most popular.  However, the other possible changes in behavior are just as startling.  According the survey results, a large percentage of vapers are considering making their own e-juices at home.  And even more are considering returning to smoking tobacco, at least partially, if they cannot find their preferred products. 

According to the soon-to-be-released report:

  • 15% of 8,451 former smokers expressed an interest in returning to smoking
  • 9% of 307 never-smokers expressed an interest in starting to smoke for the first time.
  • 33% of 282 people who currently combine smoking and e-cig use express an interest in smoking more in the future.

Mixing home-grown e-juices can be very dangerous, just as experimenting with DIY vape mods and RBAs is considered extremely unsafe, as well.  The FDA deeming regulations are stifling technological innovation while increasing the likelihood of e-juice poisoning and vaping “explosions” at the same time.  Unfortunately, they are also driving nearly 8.34 million people back into the arms of Big Tobacco, according to the CSUR report.  Vapers know this, which is why so many are considering the black market.  The question is:  Why doesn’t the FDA?

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