well, back from holiday and back to it....
As I was off to Spain I received an email from the E-Cigarette team at the MHRA, requesting input on their submission of ideas around the "e-cigarette submission portal" and its annex. As you may know, this is where all manufacturers will be required to submit (well ahead of time) full details of their product in order for it to be approved.
As suspected the document, as with the rest of the TPD, fails to appreciate what vaping really is and how we use it. I thought you might like to read my response;
Dear E-Cigarette team,
Apart from the oddity of having a consumer product administered by the MHRA I find the questioning around products confusing and very worrisome. I am not part of the vaping/e-cigarette industry but I have been a user for 7 years, tobacco free for 5 years and currently use a vaping device recreationally.
It would appear from reading the document that there is little if any understanding of how vaping/e-cigarette products actually function beyond the very limited/primitive devices of 5+ years ago or indeed those proffered by the tobacco/pharmaceutical companies.
My reasoning for this statement is derived from wording within the TPD itself, the submission and the annex. It is apparent that the separate status of tank, “mod” (power unit), liquids, coils etc. have not been appreciated and it has obviously been assumed that they are somehow single manufacturer or unitary devices, which is almost never the case apart from the previously mentioned tobacco/pharma devices.
These are typically referred to as Generation (Gen) 1 or 2 devices and are largely ineffective in keeping many off tobacco, including myself as these were the devices I tried during the first 2 years of vaping, while I was still dual-using with tobacco.
A manufacturer may well only produce the power unit, with no associated batteries, atomiser/tank or liquids. Or just a liquid, or perhaps an atomiser/tank. This makes the concept of effective dose meaningless and unattainable. It is also not necessarily useful as most users self-titrate in terms of nicotine level and it is almost impossible to over dose through normal usage.
Other items are also pointless as they forgo or ignore the users ability to modify devices, re-coil or indeed self –build coils. These are for many attractive points and indeed form a significant part of the “vaping” culture. This culture is not only responsible for helping users adopt and maintain their tobacco free status but is in itself responsible for a large amount of product development and testing. The culture also embodies its own regulatory/policing action in terms of product safety and claims.
I feel the current submission fails to account for the reality of usage, the evolved nature of the products currently available and the status of the devices as non-medicinal consumer products.
I also feel that this submission, along with the TPD Article 20 amendments themselves, pander to a slew of misrepresented and poor quality “scientific” studies which were used to engineer a misleading image of vaping products and hence an unjust legal tool was created.
I would be happy to enter into further discussions around my statements and would welcome the opportunity to be involved with further planning.
John SummersSo, you're probably wondering what we can do about this. Well, you're more than welcome to reply to them as well :-)
I urge you, please, join in supporting the Article 20 Legal Challenge and this petition for the UK government to refuse to implement the TPD article 20 amendments.