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One last point, the UN considers harm reduction for drug users to be a human right, and nicotine is a drug. This means that because harm reduction options exist, all with vastly lower risk than cigarettes, you must try to make them available to those at risk from the more harmful combusted tobacco. | One last point, the UN considers harm reduction for drug users to be a human right, and nicotine is a drug. This means that because harm reduction options exist, all with vastly lower risk than cigarettes, you must try to make them available to those at risk from the more harmful combusted tobacco. | ||
Please feel free to ask questions. I will always try to help if possible. Likewise, if you require evidence to support anything I have said, please ask. Alternatively, you can verify with your own research if you wish. Yours sincerely,Richard Pruen|Draft letter Wes Sweeting]] | Please feel free to ask questions. I will always try to help if possible. Likewise, if you require evidence to support anything I have said, please ask. Alternatively, you can verify with your own research if you wish. Yours sincerely,Richard Pruen|Draft letter Wes Sweeting]] | ||
[[File:Email 6th sept DHSC reply.pdf|thumb|alt=Sirs, Please find my reply inline in answer to your comments below. It is rather long, but a great deal of misinformation needs correcting. On Fri, 2024-09-06 at 10:51 +0000, Department of Health and Social Care wrote: Our ref: DE-1524319 Dear Mr Pruen, Thank you for your correspondence of 5 August about vaping. I have been asked to reply. I appreciate your concerns. The Government recognises the role that vapes can play as a smoking quit aid and it is not its intention to restrict the accessibility of vapes to adults in the upcoming Bill. Any measures brought forward through the upcoming Bill will be designed to curb youth vaping whilst having a minimal impact on adult vapers. The number of children vaping has tripled in the last three years, with one in five having used a vape in 2023, and the Government’s aim is to stop future generations from becoming hooked on nicotine. Regarding the number vaping, very small number tripled is a very small number, for comparison please see the following graph (30 day use for various places) this includes a lot of experimental use that does not lead to dependence, and is sadly a part of growing up, adolescents try adult things (including alcohol at higher rates than vaping, causing deaths). Vaping won't cause any deaths at least, unlike cigarettes (few but fires do happen). As can be seen the rates of infrequent use are the lowest in the UK, and highest in Australia (excluding the blip in the USA). I do not believe this is a coincidence, it reflects the regulation and illegal sales, the UK and Australia being at opposite extremes. Here in the UK vaping is regulated and most sales are legal, from shops that have every reason to restrict sales to adolescents. In Australia the product is illegal without prescription, and 92% of the supply is via illegal sales, leading to firebombings and gang warfare. Illegal sales have every incentive to break the law, and sell to anyone with the cash. Illegal products are entirely unregulated. We need to remain in control of sales, since it is working, the UK has the lowest use among adolescents. Changes risk sending more sales to the illegal market, and reducing control over sales. This will have the opposite effect to the one you intend and result in more sales being illegal and thus more sales to underage. More enforcement of the existing rules, and work to reduce illegal sales would be welcome, and I suggest more useful than further restrictions in remaining in control. Absolutely do not follow Australia, that method/type of control is proven a failure. In the data above from ASH, we can see that 0.8% young people are vaping regularly having not also been a smoker, vaping is vastly safer than smoking, diverting them from cigarettes is a highly positive outcome. Given the data, and we must rely on data and facts here, all but 0.8% are diverted from cigarettes, and that means virtually no smoking naive youth are going on to regularly vape. This quite near to the ideal situation, changes in legislation that might make this worse (by increasing illegal sales) should be avoided. If it is working, don't fix it? While it is certainly true that adults prefer fruit and sweet flavours, many flavours on the market are overly appealing to children.Evidence shows that children are attracted to the fruit and sweet flavours of vapes, both in their taste and smell, as well as how they are described. Many flavours have attractive wording and names that entice children to try vaping, such as ‘gummy bear’ and ‘rainbow burst’. Nonsense, gummy bears are a sweet from my childhood, they may exist still, but I would buy that, I contest that is targeted at memories of adults. You might have more information on this, you should speak to the actual consumers of the product before jumping to easy sounding conclusions. New Nicotine Alliance are a charity funded exclusively by consumers and represent them, they would be a great point of contact. A consumer only org eliminates possible issues with manufacturer or even tobacco company influence. The Government is aware that vape flavours are an important consideration for adult smokers when seeking to quit smoking and it will carefully consider any restrictions to avoid unintended consequences. The primary purpose of the Tobacco and Vapes Bill is to reduce smoking rates by bringing forward a generational ban on the sale of tobacco, making it an offence for anyone to sell tobacco products to anyone born on or after 1 January 2009. This policy is not being implemented for vapes because the health advice is clear that vaping is less harmful than smoking; however, vaping is not risk-free and nor is the consumption of nicotine. https://x.com/JonathanFoulds/status/1829195343780819169 The tobacco part of the bill is irrelevant according to this, and economists everywhere, cigarettes are going away. By the time the generational ban has any effect, there will have been no uptake of smoking for some years, and thankfully that will result in faster reductions in death and disease. The Generational ban is too slow, no effect for more than 20 years, but thankfully, THR (tobacco harm reduction) will have more effect and way faster, it has already begun as above. Nicotinecauses addiction rapidly and can increase the risk of developing conditions such as cardiovascular disease, gastrointestinal disorder and more rapid development of some cancers. Giving up nicotine is very difficult, and withdrawal symptoms can include cravings, irritability, anxiety, trouble concentrating, headaches and other mental symptoms. Evidence also suggests that the brain in adolescence is more sensitive to the effects of nicotine, so there could be additional risks for young people. That is why it is vital that vapes are only used as a smoking cessation tool. Vapes are an effective quit tool for smokers, particularly when combined with behavioural support. Therefore, it is important that vapes remain accessible to adult smokers. The Government remains fully committed to the Swap to Stop scheme, which involves swapping cigarettes for vapes. This part is shocking, and awful both at the same time. The misinformation presented to government is terrible. There is no good evidence that nicotine outside smoking increases the risk of cardiovascular disease, in fact long term studies in Sweden show nicotine from Snus is not associated with increase in cardiovascular risk, nor with any sort of cancer. Since Snus has been popular for a long time the evidence is based on studies of the actual population, much more reliable than e.g. extrapolation from cell or animal studies. Would you provide the source of this disinformation (Cardiovascular desease, gastrointestinal desease, cancer risk), and who presented it, please? This is important, the government needs true and up to date information, and sources of poor/disinformation need to be tackled. Further there is good evidence that nicotine can treat some gastrointestinal problems, please may I have the source for your claim it is a cause. I present some peer reviewed papers below, none are industry funded. I can present more if you would like? https://academic.oup.com/ntr/advance-article-abstract/doi/10.1093/ntr/ntae193/7727428 "Despite different mechanisms of action, both ENDS and CCs attenuated on-going colon inflammation, enhanced healing and ameliorated recovery of injured intestines of DSS-treated mice and UC patients." Citation: Kastratovic N, Markovic V, Arsenijevic A, Volarevic A, Zdravkovic N, Zdravkovic M, Brankovic M, Gmizic T, Harrell CR, Jakovljevic V, Djonov V, Volarevic V. The effects of combustible cigarettes and electronic nicotine delivery systems on immune cell-driven inflammation and mucosal healing in ulcerative colitis. Nicotine Tob Res. 2024 Aug 5:ntae193. doi: 10.1093/ntr/ntae193. Epub ahead of print. PMID: 39101540. https://www.frontiersin.org/articles/10.3389/fimmu.2022.826889/full Analysis of several studies - some animal. In general, nicotine is beneficial in ulcerative colitis; in particular, nicotine transdermal patches or nicotine enemas have shown significantly improved histological and global clinical scores of colitis, inhibited pro-inflammatory cytokines in macrophages, and induced protective autophagy to maintain intestinal barrier integrity. Citation: Zhang W, Lin H, Zou M, Yuan Q, Huang Z, Pan X and Zhang W (2022) Nicotine in Inflammatory Diseases: Anti-Inflammatory and Pro-Inflammatory Effects. Front. Immunol. 13:826889. doi: 10.3389/fimmu.2022.826889 Acknowledgements: This work was supported by the National Natural Science Foundation of China (grant number 81903319), Natural Science Foundation of Guangdong Province of China (grant number 2021A1515011220), Administration of Traditional Chinese Medicine of Guangdong Province of China (grant number 20211008), Special Fund for Young Core Scientists of Agriculture Science (grant number R2019YJ-QG001), Special Fund for Scientific Innovation Strategy—Construction of High-Level Academy of Agriculture Science (grant number R2018YJ-YB3002), Top Young Talents of Guangdong Hundreds of Millions of Projects of China (grant number 87316004), the foundation of director of Crops Research Institute, Guangdong Academy of Agricultural Sciences (grant number 202205) and Outstanding Young Scholar of Double Hundred Talents of Jinan University of China. https://www.hindawi.com/journals/grp/2008/237185/ Smoking has a detrimental effect in Crohn's disease (CD), but this may be due to factors in smoking other than nicotine. Given that transdermal nicotine benefits ulcerative colitis (UC), and there is a considerable overlap in the treatment of UC and CD, the possible beneficial effect of nicotine has been examined in patients with Crohn's colitis. In this relatively small study of patients with active Crohn's colitis, 6 mg nicotine enemas appeared to be of clinical benefit in most patients. They were well tolerated and safe. PDF Version Citation: J. R. Ingram, J. Rhodes, B. K. Evans, and G. A. O. Thomas, Hindawi Publishing Corporation, Gastroenterology Research and Practice, Volume 2008, Article ID 237185, 6 pages, doi:10.1155/2008/237185 Acknowledgements: J. R. Ingram was supported by the Gastrointestinal Foundation Trust. SLA Pharma gave financial support to the project. The authors are indebted to Dr. J. T. Green (of Cardiff and Vale Hospitals Trust) who referred patients, and to Professor G. T. Williams (GTW) who performed all histological assessments. Regarding nicotine addiction, the DSM requires significant harm as well as the difficulty in stopping use, the safer forms of nicotine do not pose sufficient risk/harm by that definition. Tobacco when smoked certainly does pose sufficient risk, thus addiction is justified. Loss of autonomy is not sufficient harm, though it does require consideration, if it where caffine in coffee would be addictive, not the more reasonable dependency forming. For the dependency of nicotine, your information appears out of date, I will deffer to Karl Fagerstrom, world leading expert and inventor of the most used dependency test for nicotine. Karl Fagerstrom | 14 December 2013 "We used to believe that nicotine is very dependence producing, but the evidence suggests that there are a number of problems with this statement. For example, animals do not self-administer nicotine as readily as they do other dependence producing drugs such as amphetamine, cocaine, and heroin (Villegier et al. 2003); nicotine is a relatively weak reinforcer in human laboratory studies (Perkins et al. 2001); abstinent smokers seem to prefer a much reduced or nicotine free e-cigarette rather than other - often stronger - nicotine-containing products like gum; and although nicotine replacement treatment is an effective aid for quitting smoking, its efficacy is moderate even in doses that replace most or all nicotine from the cigarettes formerly used (Dale et al. 1995). There is very little to no evidence for the abuse of nicotine when not delivered in a tobacco vehicle." https://nicotinepolicy.net/authors/karl-fagerstrom/dependence-on-tobacco-and-nicotine/ The above link contains more information expanding on the above, with references. The Vaping Products Duty did not form part of the previous Government’s Tobacco and Vapes Bill. Taxation is the responsibility of HM Treasury, which ran a public consultation on the proposals for the duty from 6 March to 29 May. HM Treasury and HM Revenue and Customs are currently considering responses to that consultation. There are no plans to introduce any tax changes as part of the upcoming Bill. I hope this reply is helpful. Thank you for the reply, it remains to be seen how useful this conversation is, it depends on your willingness to accept the evidence. Evidence is changing rapidly in tobacco and nicotine, this was not always the case, for a long time tobacco was the only source of nicotine in popular use, now that has changed (for the better with safer products, mostly not from the tobacco industry of old, I would argue). Regarding the tax, it need to be considered alongside policy, it as proposed is a 'sin tax' and will result in significant increase in illegal sales as tax avoidance adds to profitability, thus crime and sales to youth, as well as dissuading adults who smoke cigarettes from switching to a product that is likely to save their life. I would remind you that 30% of vape sales are illegal, I have previously written to explain some ways to reduce the impact of vapes on the environment (by a significant ten fold) and at the same time allow regulated products to out-compete the illegal products (making illegal sales nonprofitable is the easiest/cheapest control). A link o my previous letter https://safernicotine.wiki/mediawiki/index.php/File:Email_to_appg_vaping_28th_Feb_2023.pdf 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>|reply from DHSC and reply sent]] | |||