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[[File:My response NZ request for comment.pdf|thumb|alt=Submitted to Proposal to clarify how nicotine levels for vaping products are expressed in the Smokefree Environments and Regulated Products Regulations 2021 Submitted on 2023-06-14 23:07:05 Your details 1 What is your name? Name: Richard Pruen 2 What is your email address? Email: richard@pruen.co.uk 3 Are you submitting on behalf of an organisation? Yes If so, what is your organisation?: Safer Nicotine wiki 4 What ethnicity/ethnicities do you identify with? Other European, Not applicable (eg, I'm submitting of behalf of an organisation or group) 5 What Iwi do you affiliate to? What Iwi do you affiliate to?: 6 I am, or I represent, the following category or categories (select all that apply) Other (please specify) Other: Citizen science project (wikipedia clone on tobacco harm reduction) Proposal questions 7 Do you agree with our proposal to set the maximum allowable nicotine concentration at 28.5mg/mL for reusable vaping products that contain nicotine salts? No 8 Please explain your reasoning. If No, please explain.: Based on the available science, the limit should be set at a level that provides protection from poisoning, while allowing sufficient for a heavy smoker to DIY mix liquid that will satisfy their needs. Having reviewed the recent science, it is only nicotine concentrations at or above 100mg/ml that have resulted in very few fatal poisonings with orally ingested nicotine. Concentrations below 80mg/ml have as far as can be found, never resulted in death or serious harm. Therefore a limit of 75mg/ml would provide protection from poisoning while being high enough to allow DIY mixing of liquid to suit a low-power pod vaping device, which would satisfy even a heavy smoker. This provides maximum safety in that 75mg/ml will cause the body to vomit before damaging amounts of nicotine can be ingested. Even suicide attempts by simply drinking the liquid would fail. Yet allows even heavy smokers to obtain sufficient nicotine, and thus switch more easily to a vastly safer product. 9 Is there anything else you would like to tell us at this time? Is there anything else you would like to tell us at this time?: Issues have been found with the UK limit of 20mg/ml, heavy smokers find switching difficult, this requires the use of a nicotine patch and vaping, which significantly increases friction to switching, this costs the lives of smokers who would otherwise stop smoking. The UK 20mg limit was based on poor science (an estimated LD50 based on one scientist's self-administration of nicotine IV) and the assumption that all the ingested nicotine would be instantly absorbed. Looking at real data and better LD50 data gives a better understanding. Declarations and privacy 10 Publishing submissions You may publish this submission 11 Do you have commercial interests? I do not have any commercial interests in smoked tobacco or other regulated products (vaping products, other notifiable products) 12 Commercially sensitive information This submission does not contain commercially sensitive information 13 Protection from commercial and other vested interests of the tobacco industry Please provide details of any tobacco company links or vested interests below.: No links to any industry, government, or commercial interest of any kind, and no funding from any tobacco or vaping industry nor taxes or fees collected from tobacco or other companies. All funding is from the individual volunteers who contribute to the project.|My response NZ request for comment.pdf]] | [[File:My response NZ request for comment.pdf|thumb|alt=Submitted to Proposal to clarify how nicotine levels for vaping products are expressed in the Smokefree Environments and Regulated Products Regulations 2021 Submitted on 2023-06-14 23:07:05 Your details 1 What is your name? Name: Richard Pruen 2 What is your email address? Email: richard@pruen.co.uk 3 Are you submitting on behalf of an organisation? Yes If so, what is your organisation?: Safer Nicotine wiki 4 What ethnicity/ethnicities do you identify with? Other European, Not applicable (eg, I'm submitting of behalf of an organisation or group) 5 What Iwi do you affiliate to? What Iwi do you affiliate to?: 6 I am, or I represent, the following category or categories (select all that apply) Other (please specify) Other: Citizen science project (wikipedia clone on tobacco harm reduction) Proposal questions 7 Do you agree with our proposal to set the maximum allowable nicotine concentration at 28.5mg/mL for reusable vaping products that contain nicotine salts? No 8 Please explain your reasoning. If No, please explain.: Based on the available science, the limit should be set at a level that provides protection from poisoning, while allowing sufficient for a heavy smoker to DIY mix liquid that will satisfy their needs. Having reviewed the recent science, it is only nicotine concentrations at or above 100mg/ml that have resulted in very few fatal poisonings with orally ingested nicotine. Concentrations below 80mg/ml have as far as can be found, never resulted in death or serious harm. Therefore a limit of 75mg/ml would provide protection from poisoning while being high enough to allow DIY mixing of liquid to suit a low-power pod vaping device, which would satisfy even a heavy smoker. This provides maximum safety in that 75mg/ml will cause the body to vomit before damaging amounts of nicotine can be ingested. Even suicide attempts by simply drinking the liquid would fail. Yet allows even heavy smokers to obtain sufficient nicotine, and thus switch more easily to a vastly safer product. 9 Is there anything else you would like to tell us at this time? Is there anything else you would like to tell us at this time?: Issues have been found with the UK limit of 20mg/ml, heavy smokers find switching difficult, this requires the use of a nicotine patch and vaping, which significantly increases friction to switching, this costs the lives of smokers who would otherwise stop smoking. The UK 20mg limit was based on poor science (an estimated LD50 based on one scientist's self-administration of nicotine IV) and the assumption that all the ingested nicotine would be instantly absorbed. Looking at real data and better LD50 data gives a better understanding. Declarations and privacy 10 Publishing submissions You may publish this submission 11 Do you have commercial interests? I do not have any commercial interests in smoked tobacco or other regulated products (vaping products, other notifiable products) 12 Commercially sensitive information This submission does not contain commercially sensitive information 13 Protection from commercial and other vested interests of the tobacco industry Please provide details of any tobacco company links or vested interests below.: No links to any industry, government, or commercial interest of any kind, and no funding from any tobacco or vaping industry nor taxes or fees collected from tobacco or other companies. All funding is from the individual volunteers who contribute to the project.|My response NZ request for comment.pdf]] | ||
[[File:Letter Steve Barclay 6th jul.pdf|thumb|alt=Subject: Health Select Committee meeting on Vaping Dear Steve Barclay, I am a consumer advocate, with no ties to industry at present (for full details see the APPG letter linked below). I note that industry was present at this meeting but no one representing consumers of the product, why was this? As the people most likely to be impacted, why are we not included? I have further comments below and a suggestion to include at least one consumer org. Vaping is less dependence forming than smoking, science says so. See: https://safernicotine.wiki/mediawiki/index.php/ENDS_Public_Health#Dependence_(Addiction,_Abuse)_vs_Harm_/_Harm_Reduction_-_Ecigs_and_Nicotine Youth brain harms are reversible and only found in rats. Human youth smokers never experienced such harms. A huge number of people smoked in the 60s-80s, many from a young age the population is huge, any effect would have been seen (yes, people have looked, negative research is rarely published, but nothing was found). I can however provide evidence in the form of quotes from experts in tobacco and nicotine, please feel free to request such information. No UK legal vape delivers more nicotine than a cigarette, some of the illegal disposables do and are attractive to hardened smokers. Legal vapes should be allowed to use more than 20 mg/ml, see also my letter to APPG Vaping on the 28th Feb this year https://safernicotine.wiki/mediawiki/index.php/File:Email_to_appg_vaping_28th_Feb_2023.pdf . The US Juul product (containing 58 mg salt nicotine) produces blood plasma concentrations lower than a cigarette, but closer to the same level (This is why it worked so well in adults who smoke). Estimating that all nicotine is absorbed by the vaper by the amount exhaled is flawed, nicotine is destroyed by heating and oxidation while in the device and vapour. Cigarettes are delivering 1-2 mg per cigarette, but start out with 250 mg per pack of 20 (delivering only 20-40 mg to the user). Far better to stick with measured blood plasma levels in comparison to cigarettes, since this data is available. e.g. https://pubmed.ncbi.nlm.nih.gov/33486526/ I Agree with points on advertising to children, industry should not target the product at them, but targeting their smoking parents is absolutely going to save lives. Children must be told the truth, the product is not for them, but might mean they do not lose their parents to cancer. We know with absolute certainty that vaping is safer than smoking, there is no doubt; the only doubt is the magnitude of the difference (the lowest estimate 60% the highest 99.5%, current science says 95%+ and is climbing each year, as well as gaining certainty). Was it necessary to brow-beat the industry representatives? They where asked if they targeted children, and responded that they did not, with good reasons for the answer, including that the owner of one business wanted to help existing smokers, as vaping helped him, not gain youth customers. I have not seen legitimate businesses from the UK targeting underage users, that has been rouge overseas traders, and some Chinese companies. Those selling genuinely child appealing products or advertising to youth on social media, where any influence can be had, since they are not UK based, then yes, they should be stopped as far as possible. Taxation is not going to help, illicit markets will avoid the tax and make the environmental situation worse, as well a safety. The illicit market exploded in Australia with 90% of the 1.1 million vapers buying from the illicit market. Flavours targeted at adults, including their memories of sweets available when they where young. Human flavour preference is done by age 2 approximately, targeting flavours at youth is not actually reasonable, humans like nice flavours. Please see: https://safernicotine.wiki/mediawiki/index.php/ENDS_Cardiovascular_System#Flavors_(Flavours) The illicit market vapes are not regulated and may contain contaminants, this is not a surprise, and would suggest that regulation that works to reduce the illicit trade (not increase it) would be beneficial. The loophole that allows giving vapes to kids (not selling them) is not used, no reputable company does this, or would do so. It is actually a complete non issue, since no one does it. I have never heard of this, and I asked and no one else has either. Please can you forward to me the data that shows this is happening, and where? As advocates we would like to know of problems, and if possible help, thanks for your assistance. Popcorn lung is not caused by vaping see: https://safernicotine.wiki/mediawiki/index.php/ENDS_Flavors including the risk of inhaling flavours. No regulated UK product contains the chemical, it is banned. Another reason not to expand the black market, unregulated products would not be tested for banned flavours. That this was brought up, and seriously considered shows that the ministers failed to research the subject. You should include a purely user organisation such as the UK Charity NNA (New Nicotine Alliance) https://nnalliance.org/ , they have no industry affiliation and work for the users of the product. You might also consider INNCO (International Network Nicotine Consumer Organizations) https://innco.org/ As a user of these products; I would request MPs be better informed, before considering legislation that could impact my health, thank you! If you want to price youngsters out of the market without detriment to adult smokers see the letter to APPG vaping mentioned above. It contains some ideas that would reduce waste 10 fold, and increase the initial outlay without increasing cost per puff, a win for the environment and adult smokers with less spending power. Yours sincerely, Richard Pruen Cc: APPG-Vaping P.S. I await your reply 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?|Letter Steve Barclay 6th jul]] | |||
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