UserWiki:Richardpruen

Safer nicotine wiki Tobacco Harm Reduction
Revision as of 12:18, 6 July 2023 by Richardpruen (talk | contribs) (add letter to Health minister)
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The Site admin

Richard Pruen

Electrical and electronic engineer

Favorite band: Rush

Why spend so much time on this? It’s a fact that nicotine harm reduction (vaping and Snus) saved my life, this is my way to pay that forward, and pass along information on safer nicotine.

Running a site from the ground up, has proved interesting and worthwhile. Some of the things I have learned about Linux, and configuration of software for servers is only stuff you learn by doing.

I suspect the site will stick around, at least as long as it is required to provide links and info.

I might well put more info of my vaping / thr story here soon, this is just a test edit.

More test edit, and added some features, like babel to indicate users languages.


Site admin at Safer nicotine wiki.

Richard Pruen

ABOUT

Ecig user since 2008, consumer advocate for vaping and THR #VapingSavedMyLife #VapingSavesLives

Twitter @pruenrichard

Comment on R-U FDA review
Comment on R-U FDA review
My response TGA request for comment
My response TGA request for comment
Hi Mark, 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 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. The disposable vaping problem is not an easy one, because the product is in demand, a black market will form. A black market will be less regulated, even less concerned with the environment, and have no reuse or recycling plan, due to there being no incentives. Please see the situation in Australia if you have any doubts. I would suggest the following rule changes to start. All disposable devices should be rechargeable, and either contain enough liquid to last the lifetime of the atomiser (roughly 15-20ml), or be required to have a fill method (there are many ways to do this, including community 'hacks' that are available on the internet). If a refilling method was designed in, the extra cost is minimal to include a bung or device to allow re-fill). This would mean the atomiser is used for it's lifetime, and the battery recharged and used for much longer. Waste reduction by 1/10 (assuming 2ml  devices now, 10 such would be replaced by a single 20ml device)  My preferred solution is rechargeable and large capacity, for the following reasons. Large size, it becomes difficult to conceal a device with 20ml capacity, this will help reduce stealth use. As the lifetime is greater, plus content, the initial outlay will be higher putting the devices out of the purchacing power of youth, and doing so without adding to the cost per puff for the legitimate smoker wanting safer options. Smaller re-fillable and rechargeable devices have many of the same advantages, but remain easy to hide, and lower price. That might be problematic. This would depend on the lifting of the 2ml tank size, for a sealed for life device requiring tools to open, the 2 ml tank provides no protection to anyone. Even for refillable devices, in reality it increases fiddle and numbers of re-fills, and provides little protection (if any). Indeed it may be that the most dangerous time for ecigs is during filling, where child proof caps are removed etc, it might be argued that larger tanks would reduce risky refilling operations and be safer. At least a quick 'thought experiment' says that is quite possible and warrants further investigation. I have further suggestions, and would be happy to help if you would like, this is simply a start. I would imagine manufacturers will be reluctant to see rules that force them to be responsible about waste, disposables are highly profitable and allow walking away from disposal and environmental costs. This should be addressed however. As a consumer my thoughts are 'oh dear how very sad' but I am sure they will still manage to find a way to make a profit. Thanks for your time  
Email to APPG Vaping 28th Feb 2023
I heard your comment regarding the targeting of youth by possibly 'big tobacco', the vaping industry or some perceived, yet non-existent morph of the two. The same points are being made in the US, you are being fed a line Sir! I am a vaping consumer myself, well aware as an early adopter of vaping (2008), more than 15 years ago, that youth are not targeted. I have seen the industry develop flavours for adults to use, it gives the edge to make a complete switch, dissociating from the taste of tobacco. It is unfortunate that there is no flavour puberty, humans' basic taste preference is developed early, so targeting adults only is sadly not possible. Please see the graph linked here, showing the insanity of youth targeting, it just doesn't make any sense. https://safernicotine.wiki/mediawiki/index.php/Old_farts_vaping (this uses US data, the UK numbers are lower). I suggest you run things by someone who understands vaping and harm reduction before making a comment, to save embarrassment
Letter to PM re: Youth vaping
Subject: Smoking Harm Reduction: support safer alternatives – save lives Dear Lord Markham, I am sure you are aware that vaping has been a great success in reducing smoking, the NHS finding that with support 2/3 smokers successfully stop smoking with e-cigs. This is vastly more effective than NRT products that at best where 6% successful. Sweden has had longer with Snus as a harm reduction product, thus are looking at becoming effectively smoke free (< 5% smokers) this year or next. I see worrying signs in the media, and with the WHO both seem to be extremely hostile to vaping, when in fact it is doing immense good, not to mention saving the NHS vast sums (smoking is the leading cause of cancer) in preventing cancer and smoking related disease. A cancer prevented will require no detection, diagnosis or treatment; a triple saving in cost to the NHS and public. I would like to make my view known and hope you would support it, that the UK must hold it’s nerve, it must stay true to the scientific evidence from the Royal Collage Physicians, NHS Smokefree, Cochrane etc as detailed in the reports commissioned by PHE/OHID. We must also be aware of the situation in Australia where effective prohibition (the recommendation of the WHO) has been tried, and as predicted by myself and many others, seems to have resulted in an illicit market, with worse figures for youth uptake of smoking. Youth smoking in the UK, NZ and USA where vaping is available have all fallen (in the USA youth vaping became popular as a result youth smoking became all but non existent (<1% regular smokers). While youth vaping is not desirable, it remains more desirable than youth smoking, an important point to remember. Vaping is unlikely to result in deaths, open system vaping provides and off ramp in lowering nicotine and stopping (not so for smoking). If youth take up smoking and continue, then it is known at least half will die early because of it. This is also complicated by the fact that nicotine provides therapeutic benefits, thus I would like you to see this single link https://safernicotine.wiki/mediawiki/index.php/Nicotine_therapeutic_benefits it contains a lot of information, but it is important I feel to consider the benefits of safer sources of nicotine, without the harms of smoking. The following is my personal story, I do not insist you read it beyond knowing vaping saved my life. I am primarily a user of Electronic Cigarettes, and of Snus, as well as tobacco free nicotine pouches. I am also a consumer advocate for Tobacco Harm Reduction products (hereafter referred to as THR) for the simple reason that I firmly believe these products saved my life, and have a desire to pass that opportunity on to other smokers, many of whom will not be aware. I started vaping in 2008, primarily to vape where I could not smoke, I had no intention of giving up smoking, I had already tried every available method, some several times to no effect, and had given up any hope of stopping. However by early 2009 I discovered by happy accident, that I had not bought any tobacco for several weeks (at least 4) and thus had gained some funds budgeted for, but not spent. Unlike most folks who give up smoking I have no firm quit date, and don’t recall any difficulty in slowly switching from a vastly harmful product to a vastly safer one. The exact opposite of previous quit attempts. I learned on internet forums that this is not uncommon with vaping, but never happens to my knowledge with NRT. As part of my advocacy work I run the site https://safernicotine.wiki the intention to provide a repository of information on THR and links to science, resources for advocates, policy makers, doctors and indeed anyone interested in reducing the harm caused by smoking. I am not paid in any way for my advocacy, and in fact pay for the bandwidth and time required to maintain the site. Much of the content is provided by volunteers around the world. Please do not hesitate to contact me if you would like any further information, including the vast database of knowledge contained in the wiki site, or any assistance using the site. Sincerely Richard Pruen
Lord Markham letter
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
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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