E-CIGARETTES - LETTER TO HEALTH CANADA

July 28/09 - You will find follow-up to this letter at: CORRESPONDENCE WITH HEALTH CANADA ON THE E-CIGARETTE BAN


May 12, 2009

Health Products and Food Branch Inspectorate
Health Canada
Address Locator: 2003C
Ottawa, Ontario K1A 0K9

Sir/Madam,

It is beyond comprehension to see that Health Canada is calling for a ban on the sale and distribution of electronic cigarettes (e-cigarettes) in this country.

In our opinion, this decision is totally counterproductive to the efforts of Health Canada, who have long been in the vanguard internationally in the reduction of tobacco consumption. While the results of Canada’s sustained efforts through educational campaigns have generally been positive in reducing smoking prevalence right up to and including the year 2004, the decreasing trend has halted and smoking rates in Canada have remained the same ever since draconian smoking bans were instituted in many provinces (1). As history has taught us, coercive methods have never yielded positive results.

Apart from the public reacting negatively to coercion, another likely reason why the remaining citizens who smoke may be reluctant to quit their habit is the lack of realistic alternatives to the act of smoking itself. Public health authorities tend to see smoking as a function of addiction to nicotine, and pharmaceutical companies have cashed in on that perception by marketing various nicotine replacement therapy (NRT) devices. These products, in the form of variously flavored chewing gum in colorful packaging, or lozenges, patches, or even inhalers, are advertised extensively in all media. No doubt NRT sales are high and profitable, but the long term success rate of quitting smoking by use of NRT products as they are marketed now is a dismal 1.6% (2 & 3).

Electronic cigarettes are seen by many as a more attractive alternative to the NRT products available from the pharmaceutical industry and a viable alternative to those who wish to continue profiting from the benefits of nicotine. The use of the e-cigarette simulates the physical acts and sensations characteristic of smoking, including holding a cigarette-shaped device, inhaling nicotine vapor from it, and exhaling propylene glycol vapor. This vapor is a relatively inert gas which is odorless and does not linger in the air around the e-smoker. There is no environmental smoke produced by e-cigarettes therefore there is no annoyance to by-standers.

The popularity of the e-cigarette has spread virally through means such as word of mouth and internet forums. Large numbers of people around the world claim that use of e-cigarettes has helped them quit or cut down on their smoking and that it provides a degree of comfort, satisfaction, and convenience to those who do not wish to give up nicotine intake for various reasons.

In light of all of this, it is beyond disappointing to see that Health Canada is calling for a ban on the sale and distribution of electronic cigarettes in this country. We as a group representing smokers find it absurd that Health Canada would keep it legal to smoke tobacco and ban the marketing of e-cigarettes, which offer an effective alternative and we are not alone to feel this way (4).

Contrary to conventional cigarettes emissions, E-cigarette vapor only contains two chemicals: nicotine and glycol propylene. Nicotine is generally accepted as relatively harmless by authorities, and is an approved legal substance. After all, NRT products, some of which are inhaled nicotine, are allowed to be freely marketed over the counter with no legal age for purchase and Health Canada has either authorized or is in the process of authorizing clinical trials of such nicotine products on pregnant women (5). Propylene glycol is approved as an additive for various foods, is used as a preservative substance to maintain moisture in products, and has been animal tested (including on simians, not just laboratory rats) as relatively harmless when inhaled. (6 & 7)

The electronic cigarette is in essence a nicotine delivery device in the same mould as pharmaceutical NRT products. What is it in the combination of nicotine and propylene glycol that has Health Canada thinking that e-cigarettes are more hazardous than tobacco and NRT products such as inhalers? Surely e-cigarettes, which are neither tobacco products nor pharmaceutical products, should be permitted to be marketed and distributed freely providing they are not advertized as therapeutic devices.

Unable to comprehend what motivated Health Canada to ban e-cigarettes while keeping tobacco and pharmaceutical nicotine replacement therapy as well as the dangerous drug Chantix legal, we are forced to conclude that the only parties worthy of protection from Health Canada are the pharmaceutical and tobacco industries whose profits are threatened with the advent of this smart invention that had the potential of reestablishing harmony between smoking and non-smoking citizens and bringing much needed business back in our hospitality sector.

We strongly urge Health Canada to rethink their e-cigarette policy immediately, in the interest of the people they represent as opposed to the financial interests of powerful corporate lobbies.

Sincerely,


Iro Cyr
for:
C.A.G.E., Citizens for Civil Liberties and mychoice.ca

Disclaimer: C.A.G.E, Citizens for Civil Liberties and mychoice.ca* are grassroots non-profit organizations with no financial ties to the Tobacco, Pharmaceutical or e-cigarette industries.

References:

1) Canadian Tobacco Use Monitoring Survey - The Daily Monday, August 25, 2008 http://www.statcan.gc.ca/daily-quotidien/080825/dq080825b-eng.htm

2) Effectiveness and safety of nicotine replacement therapy assisted reduction to stop smoking: systematic review and meta-analysis - BMJ 2009;338:b1024 Published 2 April 2009, doi:10.1136/bmj.b1024 http://www.bmj.com/cgi/content/abstract/338/apr02_3/b1024

3) New Study Demonstrates How Conflicts of Interest with Big Pharma Influence Reporting of the Effectiveness of Smoking Cessation Drug Treatment - Tobacco Analysis blog by Dr. Michael Siegel, professor Social and Behavioral Sciences, Boston University School of Public Health.http://tobaccoanalysis.blogspot.com/search?q=Conflicts+of+Interest+with+Big+Pharma+Influence+Reporting

4) Absurdity Gone Wild: Health Canada Asks Smokers Not to Use E-Cigarettes Because of Safety Concerns, But Not to Refrain from the Known Toxic Ones - Tobacco Analysis blog by Dr. Michael Siegel, professor Social and Behavioral Sciences, Boston University School of Public Health. http://tobaccoanalysis.blogspot.com/search?q=Absurdity+Gone+Wild

5) Correspondence between C.A.G.E. and Mr. Yadvinder Bhuller, Manager - Clinical Group II , Office of Clinical Trials and Mr. William King, Chief of Staff, Ministry of Health. http://www.cagecanada.ca/index.php?pr=Nicotine_Replacement


6) Safety Report on the Ruyan® e-cigarette Cartridge and Inhaled Aerosol - Murray Laugesen Health New Zealand Ltd Christchurch, New Zealand. - 30 October 2008 http://healthnz.co.nz/RuyanCartridgeReport30-Oct-08.pdf

7) Preclinical safety evaluation of inhaled cyclosporine in propylene glycol. - PMID: 18158714 [PubMed - indexed for MEDLINE] http://www.ncbi.nlm.nih.gov/pubmed/18158714?ordinalpos=1&itool=EntrezSystem2.PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum

*Please note that as of January 1, 2009, mychoice.ca no longer receives any funding from the tobacco industry.