From: Michael Geoghegan
Sent: Monday, October 26, 2015 3:05 PM
Cc: Perry HLTH:EX Kendall ; HLTH.firstname.lastname@example.org ; email@example.com ; Andrew Weaver.MLA ; SBRT.Minister@gov.bc.ca ; Dylan Godfrey ; Dylan Godfrey
Subject: Consultation: Tobacco and Vapour Products Control Regulation
Thank you for the opportunity to respond to your attached proposed regulations which were written without any input from the BC Vapour Alliance nor as far as we can tell without reference to any scientific or medical study. In an email dated May 25, 2015 to myself, which I am happy to provide upon your request, BC Provincial Health Officer Dr. Perry Kendall stated that, “nicotine containing electronic delivery devices are in all likelihood far less dangerous to him/her and those in the immediate environment than are tobacco containing cigarettes.”
This view is in fact backed up by a British study which was endorsed and released by the British government that found that vaping is 94% less toxic than smoking. As the attached Guardian article notes, many believe that vaping could signal the end of cigarette smoking in our society: http://www.theguardian.com/society/2015/aug/19/public-health-england-e-cigarettes-safer-than-smoking
Despite these findings and the views of your own Provincial Health Officer you have decided to treat vaping exactly the same as smoking. Yet you have offered no credible scientific or medical research to back this up. I am very concerned that your draft regulations have more to do with the influence of big pharma than they do the safety of consumers.
Speaking of which a number of jurisdictions including the City of Calgary have recognized that it is important that consumers be able to see how to use these devices safely. As such they have provided vaping shops with an exemption which allows these stores to demonstrate how to safely assemble, fill and use these devices. This also makes sense as Dr. Kendall acknowledges, there are no proven health effects from breathing in second hand vapour. Yet your regulations make no provision for this not even if vaping juice containing no nicotine is utilised.
In our communication with the BC Minister of Health we proposed that vaping and e-cigarette type devices should not be sold from gas stations and convenience stores but from dedicated retail outlets where you have to be 19 years of age or older in order to enter. As far as I can tell your proposed regulations still allow for the sale of these devices from gas stations and convenience stores where kids can readily enter.
Perhaps most disturbing of all is that by ignoring clear scientific evidence that vaping is significantly less harmful than smoking your regulations will encourage people to keep smoking tobacco rather than vaping as many consumers will erroneously conclude that, “if it was any safer the government wouldn’t be regulating it as harshly as cigarettes.” For every smoker that concludes this, and there will be many, they will bear the burden of a much earlier death than if they had switched to vaping and you will bear the cost of treating their emphysema cancer and the like.
So far from protecting our children and consumers your proposed regulations do the opposite. Yes it may get a few smokers to switch to Nicorette or some other medication such as Zyban and Chantix, but it will cause many more who might have switched to vaping to keep smoking because of your misleading regulations. We therefore hope that rather than sticking to the medically and scientifically invalid position that vaping is the same as smoking you will actually engage in meaningful consultation with the BC Vapour Alliance in order to draft regulations that actually achieve an optimal outcome for consumers as opposed to just big Pharma who we are well aware of has been a generous contributor to this government:
We therefore hope that the lives of consumers as well as small business owners here in British Columbia who are providing a scientifically proven healthier alternative to smoking will take precedence over the political generosity of international pharmaceutical companies.