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Twitter [http://twitter.com/pruenrichard @pruenrichard] | Twitter [http://twitter.com/pruenrichard @pruenrichard] | ||
Below are letters and documents sent in advocacy efforts, as a record and should anyone wish to use them for ideas. | |||
[[File:FDA comment.pdf|thumb|alt=Comment on R-U FDA review |Comment on R-U FDA review ]] | [[File:FDA comment.pdf|thumb|alt=Comment on R-U FDA review |Comment on R-U FDA review ]] | ||
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[[File:NSW Consult 30 sept.pdf|thumb|alt=Vaping is a direct substitute for smoking that is able to compete with cigarettes on the open market, it is unbeatable on cost compared to subsidised NRT, and far more effective, the UK NHS find 2/3 (66%) effective with support. With regulated vaping in UK youth: 0.5% use > once weekly and are never smokers (see ASHuk graph attached). Driving the product to illicit markets and criminal gangs seems to have resulted in greater access for Australian youth. While vaping is not entirely risk-free, it is known now that it poses a fraction of the risk of smoking (please see the attached risk map). Waiting for a perfect solution that may never be found is counterproductive, the reduction in risk is known to be large that much is proven (the unknown part is, is it 90% reduction in risk or 99%, to be sure will take time) While youth should not vape or smoke, some will end up doing both. If there is no safer alternative available they will all be smoking. It is also worth remembering dependence on nicotine while not desirable can be reversed, death is final, and it is smoking that kills. Like it or not vaping has a built-in off-ramp. Use an open-system vape, and use the liquid you need to prevent cravings. Then slowly reduce the nicotine strength at your own pace. On reaching zero nicotine, stop. This is also ample evidence it was developed by smokers, to help stop smoking, and then to stop vaping if that is desired. Would a tobacco company ensure a way out was built in? The population has resoundingly refused the prescription model, any of the many reasons pointed out repeatedly or all of them are to blame. They deserve a fair regulated market they can trust, if you cannot provide a better solution than criminal gangs, then that is a failure on your part. |NSW Vaping submission 30 september 2023]] | [[File:NSW Consult 30 sept.pdf|thumb|alt=Vaping is a direct substitute for smoking that is able to compete with cigarettes on the open market, it is unbeatable on cost compared to subsidised NRT, and far more effective, the UK NHS find 2/3 (66%) effective with support. With regulated vaping in UK youth: 0.5% use > once weekly and are never smokers (see ASHuk graph attached). Driving the product to illicit markets and criminal gangs seems to have resulted in greater access for Australian youth. While vaping is not entirely risk-free, it is known now that it poses a fraction of the risk of smoking (please see the attached risk map). Waiting for a perfect solution that may never be found is counterproductive, the reduction in risk is known to be large that much is proven (the unknown part is, is it 90% reduction in risk or 99%, to be sure will take time) While youth should not vape or smoke, some will end up doing both. If there is no safer alternative available they will all be smoking. It is also worth remembering dependence on nicotine while not desirable can be reversed, death is final, and it is smoking that kills. Like it or not vaping has a built-in off-ramp. Use an open-system vape, and use the liquid you need to prevent cravings. Then slowly reduce the nicotine strength at your own pace. On reaching zero nicotine, stop. This is also ample evidence it was developed by smokers, to help stop smoking, and then to stop vaping if that is desired. Would a tobacco company ensure a way out was built in? The population has resoundingly refused the prescription model, any of the many reasons pointed out repeatedly or all of them are to blame. They deserve a fair regulated market they can trust, if you cannot provide a better solution than criminal gangs, then that is a failure on your part. |NSW Vaping submission 30 september 2023]] | ||
[[File:Letter Steve Barclay 19th oct.pdf|thumb|alt=Subject: ‘Ton of bricks’ regulation of vaping and flavours Dear Steve Barclay, I am a consumer advocate, with no ties to industry at present (for full details see my previous letter). I await your reply to my last letter on 6th July, with the requested information, including reasoning for not including representatives of consumers in the enquiry. I would also like to know if the MPs where briefed on vaping or the vaping industry, if so by whom? The point itself is brief, two short paragraphs. After your comments on regulations, I would like to draw your attention to the following peer reviewed paper https://www.mdpi.com/1660-4601/20/20/6936 this strongly suggests that young people are being diverted from smoking, vaping is at least 95% safer than them smoking, thus while not ideal vaping reduces harm. Dependence to nicotine is also not ideal, but only 0.5% youth regularly use vapes who did not first smoke. Meanwhile you risk stopping millions of adult smokers switching to vapes by eliminating flavours, these are an important thing for adults. Please read this from Clive Bates (ex ASH Director) https://clivebates.com/documents/FlavoursBriefingV1July2022.pdf. You should of course ban candyfloss and sweet flavoured alcohol, as such flavours are aimed only at children? One last point Vaping is already illegal for children, if the existing rules cannot be enforced, then further legislation will presumably not be enforced either, how would that help? Yours sincerely, Richard Pruen|Letter Steve Barclay 19th oct]] | |||
[[File:Letter to cop 10 repersentitives.pdf|thumb|alt=Subject: COP 10 WHO FCTC Dear Rosanna O’Connor, I am a consumer advocate for vaping, and do not use disposables beyond experimenting to see what they are like. I am also an engineer. I have worked in the vaping industry previously testing compliance with the standards for vaping products, and owned a now closed company BTC Battery Testing LTD (closed 2016). Currently I care for my mother who suffers vascular dementia, and as such volunteer my spare time to the cause of Tobacco Harm Reduction. I believe that consumers should be present at the COP 10 meeting, it is consumers who have the most to gain from stopping the use of combustible tobacco, and the lived experience of trying to do so. Many millions have found a way to eliminate almost all the risk via THR products. The phrase ‘Nothing about us without us’ springs to mind. Why then are the public and press excluded. I would like to see the proceedings live streamed, so those effected can see what is being done. In no way could this effect the discussions, thus is reasonable transparency. I would like an answer regarding the possibility, please. Many countries already found harm reduction useful, critical even. Be that low risk Snus (Sweden has the lowest cancer rate in Europe, and will be smoking free this year (>5%)). Vaping that the UK NHS finds almost 66% effective with support, as stated on their website. New Zealand has seen similar results, especially in native populations, reducing disparities. Japan has seen huge drops in cigarette sales due to reduced harm heated tobacco products. Please see the letter from the Lancet from Robert Beaglehole and Ruth Bonita. They were both senior officials at WHO and are now at the University of Auckland. Robert was formerly Director of the Department of Chronic Disease and Health Promotion at WHO. Ruth was formerly the Director of Surveillance in the Noncommunicable Disease Cluster at WHO. I wish to add my support for their recommendations, the article is attached (also link here https://doi.org/10.1016/S0140-6736(24)00140-5) please make sure these points are discussed at the COP 10 meeting. Yours sincerely, Richard Pruen P.S Please ensure the representatives listed on the next page can discuss before the metting and forward more widely if you agree with the sentiment. Katherine Sands Tobacco Control Team Leader Department for Health and Social Care Martin Dockrell Tobacco Control Programme Lead Department for Health and Social Care Alison Walker Senior Tobacco Control Policy Lead Department of Health and Social Care Esther Lawrence Deputy Head of Global Health UK Mission to the UN, Geneva Please find attached a letter from [THELANCET-D-24-00371] S0140-6736(24)00140-5|Letter to cop 10 representatives]] | |||
[[File:Letter PM 16th Feb 2024-draft.pdf|thumb|alt=Subject: The ban on disposable cigarettes Dear Prime Minister, I am a consumer advocate for vaping (15 years and vaper for 16), and do not use disposables beyond experimenting to see what they are like. I am also an engineer. I have worked in the vaping industry previously testing against the standards for vaping products, and owned a now closed company BTC Battery Testing LTD (closed 2016). Currently I care for my mother who suffers vascular dementia, and as such volunteer my spare time to the cause of THR. Regarding the subject. Might I remind you that Australia has already taken this path, over 50 fire bombings, at least 3 gang style murders, and a rampant illegal trade has resulted. I am aware you have children, and they are potentially at the age to start experimenting with adult products. The prohibitionist faction may have played on this, and convinced you that a ban is enforceable, sadly if Australia cannot do it, the proximity of Europe means less chance here. This is simply being realistic. The best, perhaps only, way to control the illicit trade to to make sure there is a legal trade that makes it less profitable,the US abandoned alcohol prohibition in favour of this. Please however remain focused on preventing harm, having the only source of disposable vapes (sorry to say this but it is true) that your children could possibly buy, being from a ‘dealer’ who might supply other illicit substances, that is not safer! At least if they are from a shop selling tested, safe devices, then that is a huge reduction in harm already, avoiding interaction with drug dealers. I would prefer the shop followed the law, but as we know not everyone will. Your children might also sample smoking, especially if they sensibly avoid illicit substance dealers, this too is not exactly a win, smoking being deadly and carcinogenic. You are not the only one being pressured, please see the tweet linked here: https://x.com/ASHNZ2025/status/1757930273751363892?s=20 “Disappointing that @HealthCoA lump ASH in with tobacco industry in an OIA request rather than ask us. Is a smear campaign coming our way? On the record ASH has no $$ or COI with tobacco, vape, alcohol, gambling, pharmaceutical, retail, food, or billionaire philanthropist” <a letter from the NZ government is attached to the tweet> I apologise for the somewhat robust and direct letter, but I feel you are about to make a huge mistake. I would regret it on behalf of current cigarette smokers, some of whom will die, and those who return to smoking because they use a banned product, some of those too will die. Meanwhile it will not help your children, or anyone else's to drive all sales to illicit/criminal markets. Please see the attached graph, so far regular use is not high and may be displacing cigarettes, sensible regulations to keep it that way, those would be welcome. A few truths to bear in mind: Infrequent trial use isn’t the best indicator of dependence, vaping doesn’t kill children nor is it likely ever to do so, smoking cigarettes does kill adults, reasonable regulation results in overall lowest harm. I would like to hear your thoughts, I will be happy to provide evidence to support what I have said, if required for any point please let me know. Thank you for your time, and please do not take this lightly! Yours sincerely, Richard Pruen |Letter PM 16th Feb 2024-draft]] | |||
[[File:For Attention APPG Smoking and health.pdf|thumb|alt=Dear Rt. Hon. Bob Blackman, I am contacting you as you are the contact for APPG Smoking and Health. There have been worrying sudden changes in government policy, primarily related to vaping and talk of taxes and bans on a vastly safer product, vaping, that has been successfully displacing smoking. Please see my previous letter to APPG vaping on why the disposable ban is likely to backfire; simply put, it will hand the entire market to illicit sales (these are already a problem, with oversized and higher-than-legal nicotine content). Illegal sales will likely increase sales to youth since they are already ignoring the law, and the situation in Australia with more than 50 fire bombings and three murders so far in the 'Nicotine turf wars' might be repeated here. As per my letter above, the best way to deal with illegal disposables is to have the legal market out-compete them; at least shops and retailers have fixed premises, and trading standards can take action if they don't follow the law. It is much harder to police some bloke at the pub or other informal sales. You also lose out on VAT charged on legal sales. Whatever you think about vaping, it saved my life; I started 16 years ago, very early when it was a new thing, and since then, there has been a vast amount of science (some good, some sadly terrible). Last week, 51 peer-reviewed papers and over 8,000 total papers were published. By now, vaping/nicotine is likely the most studied consumer drug ever. I had an MRI 15 years vaping (stopping smoking) of my head and upper torso. The doctors were able to confirm all the smoking damage had healed, and on explicitly asking if they could see any sign I vape, they could not (despite having found previously healed fractured ribs). Such experiences are not uncommon. A list of links to approximately 100,000 people reporting in their own words how vaping helped them. Tobacco control has a problem; please do not let that upset the government's plans to help people stop smoking with the best available harm-reduced product to date. The NHS finds it 2/3 (66%) effective, far better than NRT at around 15% with the same support (easily found on their vaping to stop smoking web page). Please ensure that the UK policy isn't derailed by click bait media, or the following: Extract from Clive Bates (former director ASH) essay:Tobacco Control's Nervous Breakdown Fourth, the existential threat to the tobacco control complex. The public discussion of the emerging landscape of low-risk consumer products seldom focuses on the interest group that is most vulnerable to disruption: the mainstream of tobacco control. It is a complex of interests comprising nonprofit activists, academics, medical and health societies, major institutions (such as the World Health Organization or the U.S. Food and Drug Administration), philanthropists and research-funding bodies. The problem for the mainstream of tobacco control is that without serious harm, the whole movement loses its purpose and its reason to exist. When it comes to low-risk alternatives to smoking, this complex is profoundly confronted by the threat of having nothing to control, no case for intervention and no reason to be. It is a powerful incumbent interest group challenged by new technology, new suppliers and new consumer confidence. As a result, the mainstream of this interest group has rejected tobacco harm reduction as a strategy for addressing its own notional goals of reducing death and disease from tobacco use. Instead, it has mounted a rear-guard defense based on a range of strategies, including the following: Falsely implying that noncombustible products are no less risky than cigarettes, that data is too uncertain or short-term, or asserting that reduced risk is no more than a marketing claim of tobacco companies. Asserting that harm reduction is merely a commercial strategy of tobacco companies. The aim here is to attach the reputational baggage of “Big Tobacco” to these new developments. Yet, many independent experts support tobacco harm reduction, and it is good if tobacco companies adopt a business model aligned with reducing health impacts. Excluding or stigmatizing contrarian opinions and creating sealed bubbles open to groupthink. The WHO Framework Convention on Tobacco Control has taken this to new extremes. Shifting emphasis to problematize nicotine rather than the “tar” of cigarette smoke that is the cause of nearly all tobacco-related disease. We are hearing more about “addiction” and less about cancer. Yet, a dependence only meets the definition of addiction if there is serious net harm to the user. A relentless focus on the supposed interests of children without recognizing that would-be smokers among adolescents also benefit from low-risk products and that the demand for nicotine has persisted across generations for hundreds of years. Young people have an interest in the health of the significant adults in their lives as carers, breadwinners and role models. Pressing for prohibitions or equivalent regulation to cigarettes, often with manipulation of language to imply equivalent risk, for example, by stating that heated-tobacco products produce “smoke” or that all tobacco products should be treated the same even though they have very different risks. A blunt refusal to face trade-offs (for example, between the interests of youth and adults) or unintended consequences (for example, increases in smoking) arising from favored policy positions. I have watched on in horror as the leadership in tobacco control, albeit with many honorable exceptions, has dogmatically denied and suppressed the opportunity to radically reshape the recreational nicotine market to cause vastly reduced harm and avoid hundreds of millions of premature deaths. It looks like a nervous breakdown is developing in tobacco control in response to profound disruptive innovation. I doubt they will survive it. See also my Letter PM 16th Feb 2024 particularly the graph that shows frequent youth use is not increasing, trials and infrequent use have, for perspective however, vaping has been far less popular and less harmful than youth drinking. Please do what you can to ensure legislation is well thought out, measured and does not result in people being forced back to deadly smoking. Thank you for your time and urgent attention!|Email APPG Smoking and health-4 March 2024]] | |||
[[File:Letter sec state health and social care 14 March 2024.pdf|thumb|alt=Subject: Youth vaping Please see the above graph, so far regular use (greater than once a week) is not high and may be displacing cigarettes, cigarettes are the worlds most deadly consumer product. Infrequent and trial use (once in 30 days, or ever use) while undesirable does not lead to dependence, only those in the graph above can possibly be ‘hooked’, but not all will be. I do not think young people should be encouraged to vape, but I would like to know your answer to one question, please. If a young person is determined to use nicotine, would you advise them to smoke cigarettes instead of safer alternatives, and a what age should harm reduction products like vaping be made available. I look forward to receiving your answer. Please feel free to ask others what they think should be done. Personally I feel the situation in Sweden is close to the best balance, accepting some use of low risk Snus, in order to reduce the uptake of deadly smoking. This will take effect far faster than the generational tobacco ban, Sweden will be a non smoking nation this year, although nicotine use remains, they have the lowest cancer rate in Europe. The UK can easily and quickly achieve the same with vaping. I note also Sweden reduced the tax on Snus to accelerate uptake. Yours sincerely, Richard Pruen|Letter sec state health and social care 14 March 2024]] | |||
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