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[[File:20240908122716 FAO- Wes Streeting, Potential risk reductions.pdf|thumb|alt=Dear Wes Streeting, Given the abundance of poor information circulating in Parliament, I thought I should provide an easy to understand example of what a 95% reduction is risk product can do to cancer rates. Unlike the modelling and assumptions that appear to prop up the tobacco and vapes bill, I will provide real population data from Sweden (they started using a harm reduction strategy with snus years ago, enough that real world data is available). You can verify these graphs by visiting https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Main_Page The use of nicotine in Sweden is roughly the EU average at 22%, but much of that is a product that is similar in risk to vaping, snus is also 95% or better less risky than cigarettes. Sweden in allowing some uptake by young people has seen the reductions above, snus has substituted for a much more harmful product and overall risk has fallen dramatically as seen above. The 'not without risk' aspect of nicotine and vaping is massively overplayed, it is certainly less risky than alcohol. As you can see above so far the UK has avoided the surge in adolescent vaping seen elsewhere, there has been a rise, but according to the latest ASH data 0.8% of frequent (> once per week) users are tobacco naive, so most of the increase is diversion from smoking (a good thing since if you never inhale tobacco smoke, it cannot harm you). This begs the question; if it seems to be working, why fix it? Further restrictions will drive the product to illegal sales, and like has been seen in Australia, that results in more sales to youth, and less access for adults, exactly the opposite of the desired outcome. We already have an illegal market in oversized/over strength products roughly 30% of the market, changes will cause it to step up and supply more if it becomes profitable. Big hint here that the proposed 'sin tax' on nicotine is guaranteed to increase illegal sales. Is the tax take in the short term favourable, with the increase in illegal sales it will prompt, compared to maximising the savings to the NHS? I would strongly suggest not! Extending the swap to stop scheme, particularly to target older cigarette users will have a huge effect on the NHS, reductions like those in the Sweden graph above, would save more than 500 million a year (up to 1 billion, if we can match Sweden in 50% reduction in lung cancer). https://www.brunel.ac.uk/news-and-events/news/articles/How-much-could-the-NHS-save-if-people-had-healthier-lifestyles-Hundreds-of-millions-according-to-research#:~:text=One%20of%20my%20studies%20indicates,mouth%20cancer%20and%20heart%20disease. The reduction would help cut waiting lists by 2029 as you have promised, especially if targeting the older at risk population with swap to stop. The tobacco part of the tobacco and vapes bill, that won't have had any effect by that point, and it is likely by the time it does the cigarette market will have collapsed/changed beyond recognition. I am not sure about it collapsing, but it is becoming obvious that big changes are afoot, and it will not be good for Big Tobacco of old. I would like to ask you to be cautious of changing regulations that we already have, and that appear to be working. Also to ensure that any further measures are well though out. The tobacco generational ban, I don't think will do any vast harm at least, it might have been a really good idea if implemented 20 years ago. I would also draw your attention to this regarding misinformation https://safernicotine.wiki/mediawiki/index.php/File:Email_6th_sept_DHSC_reply.pdf I have to wonder if misinformation on vaping is from tobacco companies, since as above vaping is doing a number on them? It seems this misinformation is stated without evidence usually or highly speculative evidence (rodent studies that are unsupported by the real world data). However I am happy to provide evidence for what I have said, and welcome any questions you may have, please feel free to ask. Thank you for your time. -- Richard Pruen <richard@pruen.co.uk>|Email FAO- Wes Streeting, Potential risk reductions]] | [[File:20240908122716 FAO- Wes Streeting, Potential risk reductions.pdf|thumb|alt=Dear Wes Streeting, Given the abundance of poor information circulating in Parliament, I thought I should provide an easy to understand example of what a 95% reduction is risk product can do to cancer rates. Unlike the modelling and assumptions that appear to prop up the tobacco and vapes bill, I will provide real population data from Sweden (they started using a harm reduction strategy with snus years ago, enough that real world data is available). You can verify these graphs by visiting https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Main_Page The use of nicotine in Sweden is roughly the EU average at 22%, but much of that is a product that is similar in risk to vaping, snus is also 95% or better less risky than cigarettes. Sweden in allowing some uptake by young people has seen the reductions above, snus has substituted for a much more harmful product and overall risk has fallen dramatically as seen above. The 'not without risk' aspect of nicotine and vaping is massively overplayed, it is certainly less risky than alcohol. As you can see above so far the UK has avoided the surge in adolescent vaping seen elsewhere, there has been a rise, but according to the latest ASH data 0.8% of frequent (> once per week) users are tobacco naive, so most of the increase is diversion from smoking (a good thing since if you never inhale tobacco smoke, it cannot harm you). This begs the question; if it seems to be working, why fix it? Further restrictions will drive the product to illegal sales, and like has been seen in Australia, that results in more sales to youth, and less access for adults, exactly the opposite of the desired outcome. We already have an illegal market in oversized/over strength products roughly 30% of the market, changes will cause it to step up and supply more if it becomes profitable. Big hint here that the proposed 'sin tax' on nicotine is guaranteed to increase illegal sales. Is the tax take in the short term favourable, with the increase in illegal sales it will prompt, compared to maximising the savings to the NHS? I would strongly suggest not! Extending the swap to stop scheme, particularly to target older cigarette users will have a huge effect on the NHS, reductions like those in the Sweden graph above, would save more than 500 million a year (up to 1 billion, if we can match Sweden in 50% reduction in lung cancer). https://www.brunel.ac.uk/news-and-events/news/articles/How-much-could-the-NHS-save-if-people-had-healthier-lifestyles-Hundreds-of-millions-according-to-research#:~:text=One%20of%20my%20studies%20indicates,mouth%20cancer%20and%20heart%20disease. The reduction would help cut waiting lists by 2029 as you have promised, especially if targeting the older at risk population with swap to stop. The tobacco part of the tobacco and vapes bill, that won't have had any effect by that point, and it is likely by the time it does the cigarette market will have collapsed/changed beyond recognition. I am not sure about it collapsing, but it is becoming obvious that big changes are afoot, and it will not be good for Big Tobacco of old. I would like to ask you to be cautious of changing regulations that we already have, and that appear to be working. Also to ensure that any further measures are well though out. The tobacco generational ban, I don't think will do any vast harm at least, it might have been a really good idea if implemented 20 years ago. I would also draw your attention to this regarding misinformation https://safernicotine.wiki/mediawiki/index.php/File:Email_6th_sept_DHSC_reply.pdf I have to wonder if misinformation on vaping is from tobacco companies, since as above vaping is doing a number on them? It seems this misinformation is stated without evidence usually or highly speculative evidence (rodent studies that are unsupported by the real world data). However I am happy to provide evidence for what I have said, and welcome any questions you may have, please feel free to ask. Thank you for your time. -- Richard Pruen <richard@pruen.co.uk>|Email FAO- Wes Streeting, Potential risk reductions]] | ||
[[File:APPG for Responsible Vaping Call for Evidence Form - 10 October 2024.pdf|thumb|alt=APPG for Responsible Vaping Inquiry on Vaping – Autumn 2024 CALL FOR EVIDENCE Those wishing to submit evidence to the inquiry should use this form. Submissions should be sent by email to info@responsiblevapingappg.org by 31 October 2024. Responses to individual questions should be kept to 500 words. Supporting information and evidence will also be accepted (see section 6). The APPG for Responsible Vaping is committed to transparency. The names of those organisations providing evidence, together with their submission, will be acknowledged in the final report and made available on the APPG for Responsible Vaping website. Personal information will not be released. All information gathered will be treated in accordance with the APPG’s GDPR policies. The APPG for Responsible Vaping has no links, connections or other engagement with the tobacco industry. If any tobacco company provides a submission to the APPG inquiry, as per guidance on requirements of article 5.3 of the World Health Organization (WHO) Framework Convention on Tobacco Control (FCTC), it will not be considered. About your organisation Q. Please provide your name and the name of the organisation that you are representing including contact details. Please indicate if you are responding in a personal capacity. I am representing myself as a consumer Q. Please outline your organisation’s field of interest/area of expertise in vaping including the relevant sector you represent e.g. public health, retail, manufacturer, regulator etc. I am a consumer of vaping products, I wish to present a consumer view Key Lines of Inquiry 1. The health impact of vaping including current application and usage 1a. Please provide comment and evidence to show the health impact of vaping including how, when and by whom such products are used, and their effectiveness or otherwise. Vaping provides a vastly safer alternative to combustible tobacco, both for current cigarette users, and for anyone who would start using riskier forms of tobacco. 1b. How should the government and others in public health treat vaping as part of the Smoke Free 2030 strategy and other health interventions? Vaping has a vastly lower and different risk profile to tobacco, the rules for tobacco are suitable for tobacco only (due to the extreme harm, and long lead time to that harm). Vaping must be treated separately and law must reflect the fact that it is at least twenty times safer than cigarettes. The risk is actually substantially lower, given use over 15 years has shown little problem. Vaping is capable of displacing cigarettes from the market, this has already begun.1c. And what are the barriers to this happening at present and in the future? focus on the generational ban as the go to policy, this will not do anything in time for the 2030 strategy, and the vapes part of it needs to avoid preventing switching, and any further restrictions favour expanding the illegal market. 2. Challenges facing the vape sector, including youth access and the environment 2a. How should we tackle issues relating to youth vaping? Please provide details of your experiences and supporting evidence including examples of effective interventions or other work, including from other sectors or countries. What else should the government, regulators, retail and vape sectors be doing in this regard and what does an effective strategy look like? Youth are already prevented from legally purchasing vapes, and the uptake of regular use > 1 time a week is 0.8% and not trending quickly in any direction. Keeping legal vapes on the market and available more freely than illegal ones is key, illegal vapes will only be sold if profitable, the cheapest control for illegal sales is to have legal products that prevent illegal products being profitable. Vaping is at least 20 times safer than cigarettes, and has an off ramp in tapering, while use is undesirable, it is still very much better than cigarettes for those determined to use nicotine. 2b. How should we tackle issues relating to the environmental impact of vaping. Please provide comment and evidence on the effectiveness of the current environmental legislative regime, such as the WEEE Directive, whether this is fit for purpose or what changes need to occur. I wrote to APPGVaping before with some ideas here is the letter from 28th feb 2023 this would also help suppress the illegal oversize devices, and reduce waste by a factor of ten times. https://safernicotine.wiki/mediawiki/index.php/File:Email_to_appg_vaping_28th_Feb _2023.pdf 2c. What other measures or schemes could be considered to improve the environmental impact of vaping? Is there, for example, a need to consider innovative take-back schemes together with financial penalties or incentives on the consumer, retailer and manufacturer, and what is the role for government and regulators? disposables should be discouraged, having a rewarded return scheme, and improving the design. For example I released a metal free pod that the part thrown away is entirely safe to throw away, the two tiny graphite contacts are the only parts that do not biodegrade quickly https://x.com/PruenRichard/status/1729128256329154749 It is dedicated to public domain so anyone can use for any purpose. 2d. Will the government’s likely proposal to ban single use or disposable vapes be beneficial in tackling youth vaping and the environmental impact of vaping? Are there potential consequences that need to be understood and explored? Please explain and evidence yourcomments. No it will likely drive all disposable sales to illegal markets (30% is already oversized/strength disposables) This will result in easier availability to underage due to no age of sale law being followed and greater risk due to untested products. This needs to be considered, a ban will increase danger. 2e. How can challenges relating to the growth of the illicit vape market be addressed and what role is there for government, regulators, law enforcement, retail, vape manufacturers etc? The regulated legal market is the best way to ensure it is not profitable to sell illegally, this has zero cost to implement. Ensure legal products are desirable and useable enough and there is no profit in illegal products. 2f. In recent years, there has been a significant increase among smokers believing that vaping is as harmful as tobacco use. Why has this come about, what are the risks with this and how can such misconceptions be addressed and corrected? Media focus on harms. This needs media and facts targeted particularly at older adults to get them facts and encourage then to switch as soon as possible. There is no other policy that can reach the most at risk population, older adults facing smoking related issues, the sooner they switch the better. 3. The economic impact of vaping towards public health, retail sector and wider economy 3a. What evidence can you share that highlights the economic impact of vaping, both positive and negative, towards the various sectors listed above. Having it be cheaper for the consumer is another reason to switch, the risk reduction is enormous so a large incentive is warrented to incentivise switching. 3b. What impact will the government’s likely course of legislative action (proposed ban on single-use vapes, banning advertising and branding as well as potential restrictions on vape flavours and retail display) on vaping have on the economic impact of vaping? Youth regular vaping is 0.8% and it might reduce that to 0.5% at best, meanwhile it will prevent many adults from switching, the adults still smoking face death 50% of the time. None of the youth starting will face death from vaping in the short or medium term, and unlikely to face death in the long term. The youth gain little for a lot of adult death. An annoying dependence VS 50% chance of death, these need to be weighted properly. 4. Proposed government legislative measures including flavours, packaging, display, excise and a ban on certain vaping products 4a. Please comment on the government’s likely proposed measures for regulating the vapesector including a ban on single-use vapes and a graduated excise regime – please indicate where you support or oppose such steps and your views on their likely consequences. as above the risk to youth and adults must be propperly considered. The risk of increasing illegal sales as well, it can be seen from Australia that demand exists and supply will meet it. Far better legal regulated vapes than illegasl ones. Flavours are vital for adults and any youth determined to try vapes will use whatever is available, it is unlikely to change the decision they make. 4b. Please comment on the government’s potential measures around packaging, display and flavours – please indicate where you support or oppose such steps including your views on their likely consequences (the APPG recognises that the government is still to publish full details around a number of these measures). Packaging/flavours should be no more restricted than the far worse alcohol, or other adult goods, if age of sale is acceptable for alcohol, and yet deaths occur in under 18s then a product without deaths and unlikely in the extreme to cause any, it doesn’t make logical sense. one puff in 30 days but 0.8% regular use indicates vapes are not as sticky as cigarettes, as most trials do not proceed to regular use. Risk reduction, because risk elimination is not possible. 4c. What are the risks, if any, to achieving the government’s Smoke Free 2030 ambition with its likely course of legislative action? The potential to increase the share of illegal sales, thus increasing availabity to youth, while causing adults to thing vaping is as harmful as cigarettes. Restrictions have a huge potential to cause harm, and little to do good on a whole population basis. 5. Better regulating the vape sector in the UK 5a. Please set out what in your view what would constitute a better regulated vape sector, with reference to examples from other sectors or countries. Where available, provide evidence to highlight how a particular route or measure has achieved its goals in delivering better regulation and the desired outcome. This could include responsibilities for government, regulators, retail and manufactures and both legislative and non-legislative routes. The existing rules are not too bad, they have led to the lowest youth vaping in the world and no spike in use as seen in the USA. Better enforcement of age of sale and keeping the illigal market suppressd, it would be very easy to do worse than continue as things are. 5b. Would a licensing scheme for vaping provide a better regulated sector and how could such a model work? Please provide any evidence to substantiate your comments including examples from other sectors or countries, and what would specifically need to occur to make this a feasible & effective scheme? 500 words No vapes should be available wherever cigarettes are available and with preferably less restrictions. The existing laws are good as they are, slightly favouring display of vapes over tobacco. Restrictions on vapes will make tobaccomore appealing in comparison, and tobacco is 20 times worse. 6. Other 6a. Please use this space to set out any other information or comments that you like to submit that you do not feel have been adequately covered by the above. Respondents can also submit an attachment. 500 words general supporting evidence attached Youth vaping is well under control and there are no sudden or worying trends or fad use. This is possibly as good as it gets, more restrictions are lilkey to make things worse (increasing illegal markets) Regular use very low and has been the same for several years|Response to APPG call for evidence]] | |||