UserWiki:Richardpruen: Difference between revisions

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[[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]]

[[File:Email-response-reply-DHSC-26-oct-2024-draft2.pdf.pdf|thumb|alt=Thank you for the reply, please find my response inline. On Thu, 2024-10-24 at 17:26 +0000, Department of Health and Social Care wrote: > Our ref: DE-1529395 <cut> We also remain fully committed to our Swap to Stop scheme, which sees up to one million adult smokers being encouraged to ‘swap to stop’, swapping cigarettes for vapes under the national scheme – the first of its kind in the world. Very glad to hear this, as suggested before I hope you would consider putting extra focus on reaching older cigarette users, they are the group most directly facing health harms, and the generational ban does nothing for them ever. The possibility exists to eliminate a huge amount of disease and death. With savings to the NHS year on year because cancer treatments are expensive. On the subject of the tobacco and vapes bill, I don't see the big rush the likes of ASHuk promote, by the time the legislation has any effect the 2030 smoke free deadline will have passed. IMHO it is better to take the time and get it right, than to rush through damaging regulations. Clive Bates provides good reasons here: https://clivebates.com/uk-tobacco-and-vapes-bill-a-misfire-and-a-backfire/   In addition, NHS programmes delivering nicotine replacement therapy are helping thousands of adults each year to live healthier lives with adult smoking rates dropping by more than half in the last three decades. Good, the more low risk options available the more likely people will find an acceptable one, and thus not die. Whilst vapes can be an effective quit aid for adult smokers, we are concerned about the worrying rise in vaping among children, and there are legitimate concerns about the unknown long-term harms from vaping. There has not been a significant rise in regular use of vapes (once a week or more) certainly nothing sudden or panic worthy. The Please see this graph: With 20 years of use, biomarker data, 16 years of popular use mostly in ex cigarette users, you are vastly overstating the remaining risk. Vaping is not likely to cause cancer of any kind (cancer potential 0.004% of smoking, a robust body of evidence https://safernicotine.wiki/mediawiki/index.php/Nicotine_-_Myth_-_Nicotine_Causes_Cancer) At this stage any possible risks are sure to be minor, the type that may cause discomfort or be annoying, but extremely unlikely to be life threatening. Science has moved on since cigarettes where found harmful, there is also real world population data from Sweden on reduced risk products and the effect. No need for modelling, there has been enough time to see the results in the eurobarometer. Vapes can do the same in the UK, or legalise Snus and copy Sweden, either way would work. As long as the you do not ban the good, while trying to achieve the perfect (resulting the disaster of more cigarettes). Ideally legalise Suns alongside vapes and transition those who will not vape to that, and cut deaths faster. Disposable vapes play a significant role in driving youth vaping with 54 per cent of current vapers aged 11-to-17 in Great Britain using them. They are easily available, cheaply priced and come in enticing colours and flavours. Additionally, they cause significant environmental harm with five million disposable vapes being either littered or thrown away in general waste every week. Given the level of environmental harm, the Department for Environment, Food and Rural Affairs is reviewing proposals to restrict the sale and supply of disposable vapes and will shortly outline its plans. Reusable and refillable products will remain available to help support smokers to switch and we do not have any plans to restrict vapes, for instance, to prescription only channels. There is absolutely no reason to punish the thousands of adults who will be put off from vaping, for 54% of 0.8% (youth vapers who never used cigarettes). Half of those adults not switching will die, while the youth will need to taper off nicotine using refillable vapes built in off ramp, cigarettes do not have that. Meanwhile according to NHS digital 2022 (graph below) 8% of 11-16 year old's have been drunk 3 or more times, vape are very effectively kept out of young peoples hands compared to that. There is no mass moral panic about alcohol, alcohol is far more deadly than vapes You need to sort priorities out, because the evidence doesn't support the focus on vapes. Enforcement of our regulations is vital. This is why we will ensure that the Tobacco and Vapes Bill contains new powers for trading standards, to take more immediate action to prevent the sale of vape to children and stop illicit products. That is great, underage sales need to be kept low, so does the illegal sale of unregulated vapes. In addition to local enforcement action, we are also providing £3million of funding over two years for Operation Joseph to reduce the sale of illegal vapes and nicotine containing vapes to under 18s. Operation Jospeh has been increasing funding at ports to ensure trading standards can conduct large seizures of illicit vapes before they enter the country. Great, but ensuring a legal market of products people want and find acceptable will mean illegal sales are unprofitable, there is also no cost to the government to enforce that. Restricting adults choices of flavours and full plain packaging will result in demand, the proposed sin tax will increase profitability, Australia at the time of writing has had 130 firebombings in the vapes turf war, do not bring that sort of insanity here, learn from their mistakes. Marketing is already restricted, and no reputable company targets underage users, they would be boycotted out of existence by consumers because they will not put up with youth targeting (I have seen this several times and it is very effective). Any genuinely youth appealing marketing or packaging can be dealt with under existing rules against advertising the product. It is while consumers are on side you can rely on this, if like Australia restrictions mean the public support the illegal market, then things will go badly here, just like Australia. I also worry the focus on vaping will detract from youth alcohol and drug prevention. Both these cause significant deaths, vaping doesn't even intoxicate, nor will it cause young people to die. The Department has previously published a call for evidence, a policy paper and a response to the public consultation on tobacco and vaping measures. All of these contain published links to evidence the Government has used in formulating policy and are relevant to many of the points you have raised. In addition to this, we work closely with organisations such as Action on Smoking and Health, public health bodies, academics, local organisations and other relevant parties to ensure that policy is based on the most reliable evidence. With respect it would be best to rely more heavily on the reports that where done for OHID, and less on hearsay or anecdotal evidence that may be brought up in parliament. Views should be heard, but must never take precedence over a report based on evidence and backed by science. We will be undertaking further consultations before the introduction of vaping regulations once the Tobacco and Vapes Bill has completed its parliamentary stages, and I would encourage you to respond to those consultations when they launch. Yes thank you. You can be sure I will be taking part in such consultations where possible. I am however just a consumer and care for my Mum who has vascular dementia, I hope this reply is helpful. Yes thank you, it makes it clear that risk is not an easy concept, and I hope the information presented helps to provide better perspective. Please feel free to ask any questions I will do my best to clarify any points or provide extra evidence if needed. Yours sincerely, Correspondence Officer Ministerial Correspondence and Public Enquiries Department of Health and Social Care --------------------------------------------------------------------- ---------------------------------------------------- Please do not reply to this email. To contact the Department of Health and Social Care, please visit theContact DHSC section on GOV.UK To receive news about DHSC: sign up to our monthly newsletter This e-mail and any attachments is intended only for the attention of the addressee(s). Its unauthorised use, disclosure, storage or copying is not permitted. If you are not the intended recipient, please destroy all copies and inform the sender by return e-mail. Any views expressed in this message are not necessarily those of the Department of Health and Social Care. Please note: Incoming and outgoing email messages are routinely monitored for compliance with our policy on the use of electronic communications. -- Richard Pruen <richard@pruen.co.uk>|Email response to DHSC draft 2]]

[[File:Email-dhsc-20-nov-2024.pdf|thumb|alt=Hi folks, Since the government promised to be evidence led, I thought this new evidence was vital for vaping policy. In this paper the authors examined respiratory symptoms in e-cigarette users without a history of smoking from the VERITAS cohort. While vapers reported slightly more frequent symptoms than non-vapers on the Respiratory Symptom Experience Scale, the difference was not clinically significant. Disposable e-cigarettes were the most common device type, with fruit flavors preferred by most users. https://www.nature.com/articles/s41598-024-80221-8 The VERITAS cohort https://veritascohort.coehar.org/ aims to provide long term data on vaping in never cigarette users <100 cigarettes in their life, and is important because most vapers are past cigarette smokers and significant confounding exists due to this. The first data above shows 'the difference between groups was not clinically significant', further proof that in the long term, vaping is vastly safer than smoking, and the effects on non-smokers are tiny, not clinically significant. It is vital that you factor this information into policy because adults who are convinced not to switch face death 50% of the time. Adolescent nicotine use is falling, and if they do use any product, then smoking should be the least available to them, as it is the most harmful. Vaping in adolescents is lower than alcohol use, and alcohol is far more toxic in both the short and long term. The current age of sale laws means the UK has the lowest regular use of vapes in underage in the world; we should keep doing that, but be aware that there is little harm from vaping when you compare that to the death faced by cigarette smokers. The tax and ban policy will not work; it will lead to illegal markets, just like Australia has seen; once control is lost, it will be harder to regain. Sweden, on the other hand, did not reduce nicotine use, which is average for the EU, but has seen reductions in smoking-related diseases and cancer. They have also achieved the smoke-free goal 17 years early: The UK will reduce death and disease more rapidly being more like Sweden than like Australia. I would like you to focus on reducing death and disease quickly, and without sacrificing the older cigarettes smoking population, this is possible, if Sweden can do it, so can the UK. Thank for your time. -- Richard Pruen <richard@pruen.co.uk>|Email to DHSC 20 nov 2024]]

DRAFT: [[File:Letter minister for health 11th Feb 2025.pdf|thumb|alt=Subject: Ongoing Vaping Policy Dear Ashley Dalton, I am contacting you as a vaping consumer and advocate for saving lives; vaping saved my life (I am happy to share medical records to prove that), and I aim to pass that on to as many as possible. I am not paid in any way by anyone to do so. I have worked in the vaping industry, helping to develop standards and testing against them (I ran BTC battery testing until 2016). This was good for consumer safety, but the industry did not necessarily favour it. I am also part of a group funded by ASH advocating for smoking cessation in people living with severe mental illness; 40% smoke cigarettes, double the national number. I was disturbed to hear some of the testimony given in parliament. Much of the information was incorrect or deliberately misleading. You must do better when debating a serious health matter; accurate and science-backed information is critical to saving lives. You should use the research OHID paid for using taxpayers' money, not anecdotal (often second-hand) accounts from teaching staff or parents frightened by the media. Consumers are not represented; I would ask you to consider involving NNA (New Nicotine Alliance) as they are a consumer-only group that is not funded by the industry. info@nnalliance.org Charity Registration Number: 1160481. It seems fair since UKVIA (industry trade association) and tobacco control NGOs were involved, but there was no one for consumers. Sadly, the media is almost all negative and presents harm because that sells papers; the truth is that in 12 years of monitoring by the MHRA yellow card early warning system, not one single disease/symptom has been detected as linked to vaping nicotine. There have been less than 20 admissions to hospital per year, and none fatal, compared to 15 per day for household cleaners (some sadly fatal). I agree that you should keep a close eye on frequent vaping among adolescents; thankfully, that remains low and does not show worrying trends (see graphs below). Experimentation with vaping is preferable to cigarettes, and still, too many are starting to smoke tobacco. Unlike tobacco, vaping is unlikely to cause deaths since 20 years of study shows no such issue. Vaping has (with open devices) the off-ramp of tapering nicotine slowly (around a third of folks quitting smoking with vapes also stop vaping this way; see ONS data that you must have access to). It is essential to accept the vastly lower risk from vaping when considering legislation that will steer adolescents in a particular direction. Assuming they will do extra homework if they can’t experiment is faulty. They will likely do something more risky instead, such as alcohol. Alcohol, for example, results in accidents, intoxication and deaths. This is sadly human nature, and harm reduction at least keeps the risks as low as possible. It is also vital to ensure that illicit vapes and illegal tobacco sales are kept to a minimum; buying vapes from ‘dealers’ opens all manner of unwanted possibilities, including other more harmful illegal drugs offered at the same time. Thus, great care is needed to avoid a ban on a product type resulting in supply shifting to criminal-controlled illicit sales. Australia is a perfect example of open gang war and fire bombings. A legally regulated market that renders illegal supply unprofitable is the best solution; there is no enforcement cost in that case, and consumers should be protected against entirely unregulated products. In Sweden, the use of nicotine is about the same as in the EU as a whole, but the rates of cancer are lower, particularly in men, since they switched earlier, and the trend is now apparent in the data. It is worth looking at Sweden because it has had a harm-reduction product for a long time, and trends and population data are readily available. It is obvious that nicotine is not the problem; combusted tobacco is the killer, particularly cigarettes; switching existing users to safer products is the priority; you can save vast numbers of lives and treatment costs. I suggest you research the history of THR in Sweden, allowing users to initiate nicotine use with a safer product works; they have the lowest cancer rates in the EU by a good margin. (see the following graphs) The UK can still do the same with vaping by not restricting it too much. Yours sincerely, Richard Pruen|Letter minister for health 11th Feb 2025]]

[[File:20250413114422 Cigarettes and Big tobacco.pdf|thumb|alt=I thought this Sobering analysis of the US cigarette market might be interesting. It looks like Big Tobacco is winning, while the only successful commercial alternative (vaping and other THR (tobacco harm reduction) products like tobacco-free pouches) are being further restricted. The UK is falling into the same trap. "Last August Barclays analysts updated the data to show how US cigarettes had become massively more profitable. Based on that Goldman Sachs report this week, the ever-accelerating price increases since last August will bring the gross profit on a pack of Marlboros to $4.50 and the operating profit to around $3.64. More than doubling profits per pack in less than five years, and on a product that costs a mere 40 cents to make." The entire report by David Sweanor, a well-known tobacco control expert from Canada, is attached. While no one wants young people to take up vaping, it is far more vital that they do not start smoking cigerettes. Youth vaping once a week or more is low and remains so (please see graph) The current government plans for a smoke-free generation will not help anyone currently smoking cigarettes; they also have the significant downside of forcing any young people insisting on using nicotine into the illegal market; the sin tax on legal vaping will mean the cheapest/most available product they encounter will be illegal cigarettes, likely they will use those. As we are well aware, cigarettes are not safe, and they are not better than vaping. Despite the ridiculous claims of the press and the rubbish spouted in Parliament, vaping has not been linked to any disease or syndrome. Twelve years of MHRA early warning monitoring would have detected anything serious (that is the reason for its existence). The data is available here: https://safernicotine.wiki/mediawiki/index.php/MHRA_yellow_card (or ask the MHRA). This government promised to be evidence-led, so please look at the evidence and do that. The overabundance of caution to prevent youth vaping will cause more youth to start smoking cigarettes, and that cannot be a good thing; it will cost lives. I would ask you to consider carefully because THR can save at least some of those lives. It may not be perfect or easy to regulate, but lives are important. I do not want to be able to say 'I told you so', I would much rather you did better and saved more lives, please! |Letter to DHSC 13 April 2024]]

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 [[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]]
+[[File:Email-response-reply-DHSC-26-oct-2024-draft2.pdf.pdf|thumb|alt=Thank you for the reply, please find my response inline.   On Thu, 2024-10-24 at 17:26 +0000, Department of Health and Social Care wrote: > Our ref: DE-1529395 <cut>  We also remain fully committed to our Swap to Stop scheme, which sees up to one million adult smokers being encouraged to ‘swap to stop’, swapping cigarettes for vapes under the national scheme – the first of its kind in the world.   Very glad to hear this, as suggested before I hope you would consider putting extra focus on reaching older cigarette users, they are the group most directly facing health harms, and the generational ban does nothing for them ever. The possibility exists to eliminate a huge amount of disease and death. With savings to the NHS year on year because cancer treatments are expensive.   On the subject of the tobacco and vapes bill, I don't see the big rush the likes of ASHuk promote, by the time the legislation has any effect the 2030 smoke free deadline will have passed. IMHO it is better to take the time and get it right, than to rush through damaging regulations. Clive Bates provides good reasons here: https://clivebates.com/uk-tobacco-and-vapes-bill-a-misfire-and-a-backfire/    In addition, NHS programmes delivering nicotine replacement therapy are helping thousands of adults each year to live healthier lives with adult smoking rates dropping by more than half in the last three decades.  Good, the more low risk options available the more likely people will find an acceptable one, and thus not die.   Whilst vapes can be an effective quit aid for adult smokers, we are concerned about the worrying rise in vaping among children, and there are legitimate concerns about the unknown long-term harms from vaping.  There has not been a significant rise in regular use of vapes (once a week or more) certainly nothing sudden or panic worthy. The Please see this graph:      With 20 years of use, biomarker data, 16 years of popular use mostly in ex cigarette users, you are vastly overstating the remaining risk. Vaping is not likely to cause cancer of any kind (cancer potential 0.004% of smoking, a robust body of evidence https://safernicotine.wiki/mediawiki/index.php/Nicotine_-_Myth_-_Nicotine_Causes_Cancer)   At this stage any possible risks are sure to be minor, the type that may cause discomfort or be annoying, but extremely unlikely to be life threatening. Science has moved on since cigarettes where found harmful, there is also real world population data from Sweden on reduced risk products and the effect. No need for modelling, there has been enough time to see the results in the eurobarometer.     Vapes can do the same in the UK, or legalise Snus and copy Sweden, either way would work. As long as the you do not ban the good, while trying to achieve the perfect (resulting the disaster of more cigarettes). Ideally legalise Suns alongside vapes and transition those who will not vape to that, and cut deaths faster.  Disposable vapes play a significant role in driving youth vaping with 54 per cent of current vapers aged 11-to-17 in Great Britain using them. They are easily available, cheaply priced and come in enticing colours and flavours. Additionally, they cause significant environmental harm with five million disposable vapes being either littered or thrown away in general waste every week. Given the level of environmental harm, the Department for Environment, Food and Rural Affairs is reviewing proposals to restrict the sale and supply of disposable vapes and will shortly outline its plans. Reusable and refillable products will remain available to help support smokers to switch and we do not have any plans to restrict vapes, for instance, to prescription only channels.  There is absolutely no reason to punish the thousands of adults who will be put off from vaping, for 54% of 0.8% (youth vapers who never used cigarettes). Half of those adults not switching will die, while the youth will need to taper off nicotine using refillable vapes built in off ramp, cigarettes do not have that.  Meanwhile according to NHS digital 2022 (graph below) 8% of 11-16 year old's have been drunk 3 or more times, vape are very effectively kept out of young peoples hands compared to that. There is no mass moral panic about alcohol, alcohol is far more deadly than vapes  You need to sort priorities out, because the evidence doesn't support the focus on vapes.      Enforcement of our regulations is vital. This is why we will ensure that the Tobacco and Vapes Bill contains new powers for trading standards, to take more immediate action to prevent the sale of vape to children and stop illicit products.  That is great, underage sales need to be kept low, so does the illegal sale of unregulated vapes.  In addition to local enforcement action, we are also providing £3million of funding over two years for Operation Joseph to reduce the sale of illegal vapes and nicotine containing vapes to under 18s. Operation Jospeh has been increasing funding at ports to ensure trading standards can conduct large seizures of illicit vapes before they enter the country.  Great, but ensuring a legal market of products people want and find acceptable will mean illegal sales are unprofitable, there is also no cost to the government to enforce that. Restricting adults choices of flavours and full plain packaging will result in demand, the proposed sin tax will increase profitability, Australia at the time of writing has had 130 firebombings in the vapes turf war, do not bring that sort of insanity here, learn from their mistakes.  Marketing is already restricted, and no reputable company targets underage users, they would be boycotted out of existence by consumers because they will not put up with youth targeting (I have seen this several times and it is very effective).  Any genuinely youth appealing marketing or packaging can be dealt with under existing rules against advertising the product. It is while consumers are on side you can rely on this, if like Australia restrictions mean the public support the illegal market, then things will go badly here, just like Australia.   I also worry the focus on vaping will detract from youth alcohol and drug prevention. Both these cause significant deaths, vaping doesn't even intoxicate, nor will it cause young people to die.   The Department has previously published a call for evidence, a policy paper and a response to the public consultation on tobacco and vaping measures. All of these contain published links to evidence the Government has used in formulating policy and are relevant to many of the points you have raised. In addition to this, we work closely with organisations such as Action on Smoking and Health, public health bodies, academics, local organisations and other relevant parties to ensure that policy is based on the most reliable evidence.  With respect it would be best to rely more heavily on the reports that where done for OHID, and less on hearsay or anecdotal evidence that may be brought up in parliament. Views should be heard, but must never take precedence over a report based on evidence and backed by science.   We will be undertaking further consultations before the introduction of vaping regulations once the Tobacco and Vapes Bill has completed its parliamentary stages, and I would encourage you to respond to those consultations when they launch.   Yes thank you. You can be sure I will be taking part in such consultations where possible. I am however just a consumer and care for my Mum who has vascular dementia,   I hope this reply is helpful.   Yes thank you, it makes it clear that risk is not an easy concept, and I hope the information presented helps to provide better perspective. Please feel free to ask any questions I will do my best to clarify any points or provide extra evidence if needed.   Yours sincerely,   Correspondence Officer Ministerial Correspondence and Public Enquiries Department of Health and Social Care   --------------------------------------------------------------------- ----------------------------------------------------  Please do not reply to this email. To contact the Department of Health and Social Care, please visit theContact DHSC section on GOV.UK  To receive news about DHSC: sign up to our monthly newsletter     This e-mail and any attachments is intended only for the attention of the addressee(s). Its unauthorised use, disclosure, storage or copying is not permitted. If you are not the intended recipient, please destroy all copies and inform the sender by return e-mail. Any views expressed in this message are not necessarily those of the Department of Health and Social Care. Please note: Incoming and outgoing email messages are routinely monitored for compliance with our policy on the use of electronic communications.  --  Richard Pruen <richard@pruen.co.uk>|Email response to DHSC draft 2]]
+[[File:Email-dhsc-20-nov-2024.pdf|thumb|alt=Hi folks,  Since the government promised to be evidence led, I thought this new evidence was vital for vaping policy.  In this paper the authors examined respiratory symptoms in e-cigarette users without a history of smoking from the VERITAS cohort. While vapers reported slightly more frequent symptoms than non-vapers on the Respiratory Symptom Experience Scale, the difference was not clinically significant. Disposable e-cigarettes were the most common device type, with fruit flavors preferred by most users.  https://www.nature.com/articles/s41598-024-80221-8  The VERITAS cohort https://veritascohort.coehar.org/ aims to provide long term data on vaping in never cigarette users <100 cigarettes in their life, and is important because most vapers are past cigarette smokers and significant confounding exists due to this.  The first data above shows 'the difference between groups was not clinically significant', further proof that in the long term, vaping is vastly safer than smoking, and the effects on non-smokers are tiny, not clinically significant.  It is vital that you factor this information into policy because adults who are convinced not to switch face death 50% of the time. Adolescent nicotine use is falling, and if they do use any product, then smoking should be the least available to them, as it is the most harmful. Vaping in adolescents is lower than alcohol use, and alcohol is far more toxic in both the short and long term.  The current age of sale laws means the UK has the lowest regular use of vapes in underage in the world; we should keep doing that, but be aware that there is little harm from vaping when you compare that to the death faced by cigarette smokers.  The tax and ban policy will not work; it will lead to illegal markets, just like Australia has seen; once control is lost, it will be harder to regain. Sweden, on the other hand, did not reduce nicotine use, which is average for the EU, but has seen reductions in smoking-related diseases and cancer. They have also achieved the smoke-free goal 17 years early:    The UK will reduce death and disease more rapidly being more like Sweden than like Australia.  I would like you to focus on reducing death and disease quickly, and without sacrificing the older cigarettes smoking population, this is possible, if Sweden can do it, so can the UK.   Thank for your time.  --  Richard Pruen <richard@pruen.co.uk>|Email to DHSC 20 nov 2024]]
+DRAFT: [[File:Letter minister for health 11th Feb 2025.pdf|thumb|alt=Subject: Ongoing Vaping Policy Dear Ashley Dalton,  I am contacting you as a vaping consumer and advocate for saving lives; vaping saved my life (I am happy to share medical records to prove that), and I aim to pass that on to as many as possible. I am not paid in any way by anyone to do so. I have worked in the vaping industry, helping to develop standards and testing against them (I ran BTC battery testing until 2016). This was good for consumer safety, but the industry did not necessarily favour it. I am also part of a group funded by ASH advocating for smoking cessation in people living with severe mental illness; 40% smoke cigarettes, double the national number.  I was disturbed to hear some of the testimony given in parliament. Much of the information was incorrect or deliberately misleading. You must do better when debating a serious health matter; accurate and science-backed information is critical to saving lives. You should use the research OHID paid for using taxpayers' money, not anecdotal (often second-hand) accounts from teaching staff or parents frightened by the media. Consumers are not represented; I would ask you to consider involving NNA (New Nicotine Alliance) as they are a consumer-only group that is not funded by the industry. info@nnalliance.org Charity Registration Number: 1160481. It seems fair since UKVIA (industry trade association) and tobacco control NGOs were involved, but there was no one for consumers.    Sadly, the media is almost all negative and presents harm because that sells papers; the truth is that in 12 years of monitoring by the MHRA yellow card early warning system, not one single disease/symptom has been detected as linked to vaping nicotine. There have been less than 20 admissions to hospital per year, and none fatal, compared to 15 per day for household cleaners (some sadly fatal).    I agree that you should keep a close eye on frequent vaping among adolescents; thankfully, that remains low and does not show worrying trends (see graphs below). Experimentation with vaping is preferable to cigarettes, and still, too many are starting to smoke tobacco. Unlike tobacco, vaping is unlikely to cause deaths since 20 years of study shows no such issue. Vaping has (with open devices) the off-ramp of tapering nicotine slowly (around a third of folks quitting smoking with vapes also stop vaping this way; see ONS data that you must have access to).   It is essential to accept the vastly lower risk from vaping when considering legislation that will steer adolescents in a particular direction. Assuming they will do extra homework if they can’t experiment is faulty. They will likely do something more risky instead, such as alcohol. Alcohol, for example, results in accidents, intoxication and deaths. This is sadly human nature, and harm reduction at least keeps the risks as low as possible. It is also vital to ensure that illicit vapes and illegal tobacco sales are kept to a minimum; buying vapes from ‘dealers’ opens all manner of unwanted possibilities, including other more harmful illegal drugs offered at the same time. Thus, great care is needed to avoid a ban on a product type resulting in supply shifting to criminal-controlled illicit sales. Australia is a perfect example of open gang war and fire bombings. A legally regulated market that renders illegal supply unprofitable is the best solution; there is no enforcement cost in that case, and consumers should be protected against entirely unregulated products.    In Sweden, the use of nicotine is about the same as in the EU as a whole, but the rates of cancer are lower, particularly in men, since they switched earlier, and the trend is now apparent in the data. It is worth looking at Sweden because it has had a harm-reduction product for a long time, and trends and population data are readily available. It is obvious that nicotine is not the problem; combusted tobacco is the killer, particularly cigarettes; switching existing users to safer products is the priority; you can save vast numbers of lives and treatment costs.   I suggest you research the history of THR in Sweden, allowing users to initiate nicotine use with a safer product works; they have the lowest cancer rates in the EU by a good margin. (see the following graphs) The UK can still do the same with vaping by not restricting it too much.     Yours sincerely,  Richard Pruen|Letter minister for health 11th Feb 2025]]
+[[File:20250413114422 Cigarettes and Big tobacco.pdf|thumb|alt=I thought this Sobering analysis of the US cigarette market might be interesting. It looks like Big Tobacco is winning, while the only successful commercial alternative (vaping and other THR (tobacco harm reduction) products like tobacco-free pouches) are being further restricted.  The UK is falling into the same trap.    "Last August Barclays analysts updated the data to show how US cigarettes had become massively more profitable. Based on that Goldman Sachs report this week, the ever-accelerating price increases since last August will bring the gross profit on a pack of Marlboros to $4.50 and the operating profit to around $3.64. More than doubling profits per pack in less than five years, and on a product that costs a mere 40 cents to make." The entire report by David Sweanor, a well-known tobacco control expert from Canada, is attached.  While no one wants young people to take up vaping, it is far more vital that they do not start smoking cigerettes. Youth vaping once a week or more is low and remains so (please see graph)      The current government plans for a smoke-free generation will not help anyone currently smoking cigarettes; they also have the significant downside of forcing any young people insisting on using nicotine into the illegal market; the sin tax on legal vaping will mean the cheapest/most available product they encounter will be illegal cigarettes, likely they will use those. As we are well aware, cigarettes are not safe, and they are not better than vaping.  Despite the ridiculous claims of the press and the rubbish spouted in Parliament, vaping has not been linked to any disease or syndrome. Twelve years of MHRA early warning monitoring would have detected anything serious (that is the reason for its existence). The data is available here: https://safernicotine.wiki/mediawiki/index.php/MHRA_yellow_card (or ask the MHRA). This government promised to be evidence-led, so please look at the evidence and do that.   The overabundance of caution to prevent youth vaping will cause more youth to start smoking cigarettes, and that cannot be a good thing; it will cost lives. I would ask you to consider carefully because THR can save at least some of those lives. It may not be perfect or easy to regulate, but lives are important.  I do not want to be able to say 'I told you so', I would much rather you did better and saved more lives, please! |Letter to DHSC 13 April 2024]]