The Importance of Supporting Reasonable Regulation
Posted on 18 August 2015
It's no secret that the vaping community and FDA are at odds. The technology we love and support is under the eye of public scrutiny, and before too long federal regulations will be in effect. Advocacy groups such as CASAA and SFATA are working tirelessly to ensure regulations are reasonable and allow vaping as we know it to continue. While most of us know the importance of defying restrictive (read: prohibitionist) regulation, actually supporting the FDA can be a little counter-intuitive.
Regulations are coming whether we like it or not. Part of making sure we get reasonable regulations is to work with the FDA, rather than against them, in finding the correct solution. When they propose flavor bans and pre-market approval, we explain why that's bad for the public and hope they listen. When the FDA writes good rules, we need to give these rules our full support. This isn't haggling, and it isn't compromising. It's about showing the FDA we can work with them, so they in turn can work with us.
Such is the case with their newest ANPRM, which seeks to add nicotine warning labels and childproof packaging as requirements for all e-liquid products and some "other tobacco products". While we aren't fond of being lumped in with tobacco, these are good, reasonable regulations that most of the industry already follows. Adding warning labels and childproof caps are a benefit to the vaping community, as well as the public at large. In addition to actually benefiting the public, having and following regulations gives vaping a better name. For these reasons, Vapejoose was eager to submit a comment on the proposed rules, and we suggest you also do so. As CASAA mentions, it is best to support the good while protesting the bad. Let them know you support reasonable regulation, but won't stand for the elimination of the vaping industry as we know it. Be sure to submit your comment soon, as August 31st is the last day they will be accepted.
-The Vapejoose Team
I am commenting on ANPRM “Nicotine Exposure Warnings and Child-Resistant Packaging for Liquid Nicotine, Nicotine-Containing E-Liquid(s), and Other Tobacco Products” (Docket No. FDA-2015-N-1514)
As a startup e-liquid manufacturer, we look to provide the best consumer experience possible. As part of this experience, we feel safety is a major concern. Our labels display a warning to keep out of reach of children and a reminder that e-liquid products are only for persons over the age of 18. In addition, all products we ship are sealed with child resistant caps, and we are in the process of transitioning all products to include tamper evident seals.
Vapejoose, Inc. strongly supports reasonable regulation by the FDA, and the proposed exposure warnings and child resistant packaging are excellent steps towards this goal. Warnings on e-liquid should include information equivalent to products with similar risks, such as household cleaners. A poison control number and “Keep away from children and pets” label should be sufficient to warn consumers of the acute health risks nicotine can pose, and give them a resource for emergency assistance.
We also feel that child resistant packaging should be a requirement for the vaping industry. As 100% of our customers are over the age of 18, there is no reason not to take every precaution to keep young children out of e-liquid products. Once again, we fully support the FDA in the case of these reasonable and necessary regulations.
Furthermore, Vapejoose, Inc. would like to take this opportunity to ask the FDA to reconsider deeming regulations on existing e-liquid products. As an industry primarily comprised of small businesses, thousands of jobs and millions of consumers will be affected by overregulation of an industry in its infancy. Unless there is compelling evidence that vapor devices pose a significant and measurable risk to the public, we ask that regulations focus on purity and safety of product, rather than a prohibitive premarket approval process.
Thank you for your consideration.
The Vapejoose Team