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January 23rd, 2015:

MPs vote on plain packaging signals industry defeat – but there may be a sting in the tale

 

The government’s decision to allow MPs to vote on standardised packaging before the general election will finally bring to an end the tobacco industry’s three-year campaign to prevent regulation of cigarette packs in the UK. A campaign, our research shows, in which they used misleading evidence on both the illicit tobacco trade and the health benefits of standardised packaging as a tool to delay legislation.

That MPs will have the opportunity to vote on standardised packaging has been widely welcomed by health advocates and the medical community – and strongly criticised by tobacco industry-supported organisations such as Forest and the Institute of Economic Affairs, which said it was a “gross infringement of the right of companies to use their trademarks and design their own packaging”.

But a wealth of evidence from the independent review by Sir Cyril Chantler, indicates that that this important measure is likely to help reduce the number of children and young people taking up smoking. It is hoped that this will reduce the number of deaths from smoking-related diseases, which currently stands at around 100,000 a year in the UK.

If introduced, standardised packaging regulations will prohibit all on-pack branding, except the name and brand variant, printed in a standard font. In place of branding, packs will feature written and graphic health warnings, covering a minimum of 65% of the pack, in line with the new EU Tobacco Products Directive.

The vote

The decision to allow a parliamentary vote before the election is hugely important. Despite broad cross-party support for the measure, there would inevitably have been a significant delay before standardised packaging made it back on to the parliamentary agenda – whether the government had changed after the election or not – if this decision hadn’t happened now.

It seems likely that standardised cigarette packaging will now be passed by parliament without any further delay. In a whipped vote last year, MPs showed their support for the idea in principle, with only 24 MPs not voting for the measure. The House of Lords has also shown its support by tabling the amendment to the Children and Families Bill in 2013 which allowed the first vote to take place.

The tobacco industry’s response

This decision signals the death knell to the tobacco industry’s campaign but it may yet mark the start of a new battle if tobacco companies take the issue to the courts.

In addition to their arguments about a rise in illicit trade and the questioning of health benefits, tobacco companies have also claimed that it is an infringement of their intellectual property. They have funded front groups, such as Forest and Hands Off Our Packs, using them as a vehicle to promote these arguments to the general public. And they have commissioned research of their own in a bid to undermine the evidence base for standardised packaging.

But research conducted by myself and colleagues at the University of Bath and the UK Centre for Tobacco and Alcohol Studies last year exposed the misleading nature of tobacco industry evidence on both the illicit trade and the health impacts of standardised packaging.

The government’s decision to progress standardised packaging to a vote in the House of Commons seems to show that while the legislative process may have been protracted by tobacco industry opposition, it has not ultimately been undermined by it.

The vote’s significance

If – or, as seems likely, when – MPs vote for standardised packaging, the UK will be one of the first countries to implement the measure in Europe – Ireland is also progressing legislation – and only the second or third globally, following in Australia’s footsteps. This ground-breaking innovation in tobacco control legislation illustrates the UK’s commitment to the health of its population and of its children: every year more than 200,000 11 to 15-year-olds start smoking in the UK (around 170,000 in England).

It is to be hoped that the devolved assemblies will also follow Westminster in introducing the measure and that the UK, like Australia, will stand firm against any legal action the tobacco companies may now undertake. This important measure will be worth defending: it will contribute to a reduction in the impact of smoking on our – and our children’s – health.

Plain packaging for cigarettes will see the end of some wickedly wonderful marketing

http://www.independent.co.uk/life-style/health-and-families/features/plain-packaging-for-cigarettes-will-see-the-end-of-some-wickedly-wonderful-marketing-9996615.html

Another nail in the coffin for the tobacco industry, then, if not for its untapped markets. Should the Government get its way, the ability to buy the smoke you prefer – already hampered in supermarkets by shuttered cabinets that prevent you from viewing the full range – will be further curtailed by the introduction of plain packaging for fags and baccy. The idea is not to make smokers feel like social lepers, though brown wrappers do rather smack of the Soho sex shop, but to weaken the bonds of loyalty between addict and pusher; and to denude the products of any attractive associations that may still cling to them.

The smoking lobby may argue that, however impressionable the youth, they can resist striking colours and distinctive typefaces, which are now just about their only means of communication with the public (and even then with grisly pictures of shrivelled lungs and terrible health warnings). Their opponents would reply that, if the branding doesn’t matter, then why not dispense with it?

This approach ignores the fact that, while smokers in dire need will pull on anything to reduce the craving, they are loyal to their brand’s taste as well as the “values” implied by its wrapping. (And yes, abstainers, different cigarettes do have different tastes, from the toasty hit of a Marlboro Red to the creamier feel of a blue Pall Mall.) It also relies for support on statistics from Australia that are hotly contested.

The plain brigade claims that the number of smokers on the continent who daily drag on tax-legal fags has declined. The tobacco giants reply that household expenditure on tabs has actually increased. The legit business says that tax-evading smuggling and (even more dangerous) counterfeiting are on the rise in Oz, the government disputes that. And your correspondent? I can’t help but feel nostalgic for the far-off Fifties, when cigarette marketing was unregulated: when Consulates were “cool as a mountain stream” and “more doctors smoke[d] Camel than any other cigarette”.

E-cigarettes ‘expose smokers to more formaldehyde than regular tobacco’

A preliminary study in the New England Journal of Medicine raises a new worry about electronic cigarettes – exposure to formaldehyde.

Under certain conditions, taking 10 puffs from an e-cigarette would expose a user to about 2.5 times as much formaldehyde as he or she would get from smoking a single tobacco cigarette, according to the study.

Formaldehyde is the pungent chemical that is used to preserve biological specimens, as well as embalm human bodies. It’s used as an industrial disinfectant and as an ingredient in permanent-press fabrics, plywood, glues and other household products, according to the National Cancer Institute.

It is also formed when the propylene glycol and glycerol in e-cigarette liquids and oxygen are heated together.

The World Health Organisation’s International Agency for Research on Cancer said formaldehyde can cause leukaemia and nasopharyngeal cancer.

The US Environmental Protection Agency considers the chemical a “probable human carcinogen.”

In experiments at Portland State University, researchers used a tank system type of electronic cigarette to produce nicotine vapour. The e-liquid vapour was captured in a tube and analysed using a technique called nuclear magnetic resonance spectroscopy.

Each sample consisted of 10 puffs of vapour (at three to four seconds per puff) collected over five minutes. When the e-cigarette was used on the “low voltage” setting of 3.3 volts, the researchers didn’t detect any formaldehyde in the vapour.

However, when the device was on the “high voltage” setting of five volts, they measured an average of 380 micrograms of formaldehyde per sample.

The research team then estimated an e-cigarette user who inhaled three milliliters of e-liquid per day would breathe in at least 14.4 milligrams of formaldehyde.

The actual daily exposure is probably higher, they wrote, because their experiments failed to capture all of the vapour.

A 2005 study in the journal Regulatory Toxicology and Pharmacology estimated that a person who smoked a pack of 20 cigarettes would inhale three milligrams of formaldehyde in the process.

The researchers calculated that the lifetime cancer risk incurred by inhaling formaldehyde would be five to 15 times higher for long-term e-cigarette users than for long-term tobacco smokers.

Proponents of electronic cigarettes were quick to criticise the study for testing the devices under conditions that don’t reflect actual use.

If a person were to take four-second puffs on a high voltage setting, they would experience a “very harsh and awful taste,” Bill Godshall, an adviser to the Consumer Advocates for Smoke-free Alternatives Association, said in a statement distributed by the American Vaping Association.

Gregory Conley, the group’s president, added that e-cigarette users take shorter puffs as they increase the voltage on their devices. “These are not settings that real-life vapers actually use,” he said.

But study co-author James Pankow, a chemistry professor at Portland State University, said the line between e-cigarettes and tobacco cigarettes was growing fuzzier by the day.

“No one should assume e-cigarettes are safe,” he said.

“For conventional cigarettes, once people become addicted, it takes numerous years of smoking to result in a high risk of lung cancer and other severe disease; it will probably take five to 10 years to start to see whether e-cigarettes are truly as safe as some people believe them to be.”

Source URL (modified on Jan 23rd 2015, 10:27am): http://www.scmp.com/news/world/article/1689378/e-cigarettes-expose-smokers-more-formaldehyde-regular-tobacco

Montague, Leverett raise purchase age for tobacco, Franklin County Fair going ‘mostly’ smoke free

http://www.masslive.com/news/index.ssf/2015/01/montague_leverett_raise_purchase_age_for_tobacco_franklin_county_fair_going_mostly_smoke_free.html

Two Franklin County health boards voted Wednesday night to increase to 21 the age for the purchase of tobacco products, and the Franklin County Fair board of directors has “voted unanimously to become a (mostly) smoke free fair starting in 2015.”

“I think personally that this is one of the most important regulations that has happened in tobacco regulations in the last 20 years,” said Gina McNeely, health director for the Town of Montague, where the three-member health board also voted to ban the sale of flavored cigarettes, except for mint and menthol, that are allowed by the FDA, to those not 21.

Citing government statistics that most smokers start before the age of 18, McNeely said she felt the increased purchase age would “cut down quite a bit” the exposure of students to cigarettes from older students. She noted that she got her first cigarette at age 10, from an older brother and smoked for 18 years.

The Leverett health board also voted to raise the tobacco purchase age to 21 from 18, and banned the sale of alternative produces such as electronic as well as single cigarettes to those under 21. Board chair Fay Zipkowitz said the regulations are being finalized, along with the permit process covering enforcement, and would be in place March 1.

“I feel very good about this,” Zipkowitz said. “I am asthmatic and so I am very concerned about the ongoing effects of tobacco products, but this is particularly a serious health issue with young people and that is why the board of health is interested.”

Zipkowitz said the only opposition registered prior to the vote was graffiti on advertisements for the meeting, saying, “You can be 18 and die for your country, but you cannot smoke.”

“You don’t sell alcohol unless someone is 21, and you don’t sell someone under 21 tobacco products for the same reasons,” Zipkowitz said.

The board of Greenfield’s Franklin County Fair announced its decision in an email to media, and cited the “countless visitors who have requested this policy over the past several years.”

“After months of discussion and consideration, the Franklin County Fair Board of Directors voted unanimously to become a (mostly) smoke free fair starting in 2015, and thus banning smoking in almost all areas of the fairgrounds,” the announcement states. It adds that four areas on the grounds have been designated for smokers. These include the demolition derby staging area, near the midway restrooms and adjacent to the midway, and near the Fish and Game building.

I think personally that this is one of the most important regulations that has happened in tobacco regulations in the last 20 years.

Montague’s McNeely noted that she was Holyoke’s first tobacco control officer back in 1993 when the legislature’s .25 cent tax on cigarettes helped fund anti-tobacco education.

“I have been doing this sort of tobacco work for 20 years,” McNeely said. “I can remember going into restaurants and bars and there was no place to sit away from smokers. Now, my nieces and nephews go to bars and restaurants and there is no exposure, so the next huge step is raising the purchase age to 21.”

Both board of health votes were prompted by proposals from the Franklin and Hampshire Substance and Tobacco Prevention Partnership.

Montague’s regulations take effect July 1, and McNeely said the town is “very happy to be the leader” in Franklin County with such regulation.

“We think it is really important, and we are hoping other communities will follow and think that they will,” said McNeely, who has been Montague’s health director for 15 years.

More than 100 Massachusetts cities and towns have enacted their own expanded regulations on the age of sale for tobacco products, a trend growing across the country.

MPs vote on plain packaging signals industry defeat – but there may be a sting in the tale

http://theconversation.com/mps-vote-on-plain-packaging-signals-industry-defeat-but-there-may-be-a-sting-in-the-tale-36622

The government’s decision to allow MPs to vote on standardised packaging before the general election will finally bring to an end the tobacco industry’s three-year campaign to prevent regulation of cigarette…

Put you off? That’s the point. Ella Pickover/PA

Put you off? That’s the point. Ella Pickover/PA

The government’s decision to allow MPs to vote on standardised packaging before the general election will finally bring to an end the tobacco industry’s three-year campaign to prevent regulation of cigarette packs in the UK. A campaign, our research shows, in which they used misleading evidence on both the illicit tobacco trade and the health benefits of standardised packaging as a tool to delay legislation.

That MPs will have the opportunity to vote on standardised packaging has been widely welcomed by health advocates and the medical community – and strongly criticised by tobacco industry-supported organisations such as Forest and the Institute of Economic Affairs, which said it was a “gross infringement of the right of companies to use their trademarks and design their own packaging”.

But a wealth of evidence from the independent review by Sir Cyril Chantler, indicates that that this important measure is likely to help reduce the number of children and young people taking up smoking. It is hoped that this will reduce the number of deaths from smoking-related diseases, which currently stands at around 100,000 a year in the UK.

If introduced, standardised packaging regulations will prohibit all on-pack branding, except the name and brand variant, printed in a standard font. In place of branding, packs will feature written and graphic health warnings, covering a minimum of 65% of the pack, in line with the new EU Tobacco Products Directive.

The vote

The decision to allow a parliamentary vote before the election is hugely important. Despite broad cross-party support for the measure, there would inevitably have been a significant delay before standardised packaging made it back on to the parliamentary agenda – whether the government had changed after the election or not – if this decision hadn’t happened now.

It seems likely that standardised cigarette packaging will now be passed by parliament without any further delay. In a whipped vote last year, MPs showed their support for the idea in principle, with only 24 MPs not voting for the measure. The House of Lords has also shown its support by tabling the amendment to the Children and Families Bill in 2013 which allowed the first vote to take place.

The tobacco industry’s response

This decision signals the death knell to the tobacco industry’s campaign but it may yet mark the start of a new battle if tobacco companies take the issue to the courts.

In addition to their arguments about a rise in illicit trade and the questioning of health benefits, tobacco companies have also claimed that it is an infringement of their intellectual property. They have funded front groups, such as Forest and Hands Off Our Packs, using them as a vehicle to promote these arguments to the general public. And they have commissioned research of their own in a bid to undermine the evidence base for standardised packaging.

But research conducted by myself and colleagues at the University of Bath and the UK Centre for Tobacco and Alcohol Studies last year exposed the misleading nature of tobacco industry evidence on both the illicit trade and the health impacts of standardised packaging.

The government’s decision to progress standardised packaging to a vote in the House of Commons seems to show that while the legislative process may have been protracted by tobacco industry opposition, it has not ultimately been undermined by it.

The vote’s significance

If – or, as seems likely, when – MPs vote for standardised packaging, the UK will be one of the first countries to implement the measure in Europe – Ireland is also progressing legislation – and only the second or third globally, following in Australia’s footsteps. This ground-breaking innovation in tobacco control legislation illustrates the UK’s commitment to the health of its population and of its children: every year more than 200,000 11 to 15-year-olds start smoking in the UK (around 170,000 in England).

It is to be hoped that the devolved assemblies will also follow Westminster in introducing the measure and that the UK, like Australia, will stand firm against any legal action the tobacco companies may now undertake. This important measure will be worth defending: it will contribute to a reduction in the impact of smoking on our – and our children’s – health.

Smoke and fire over e-cigarettes

As nations adopt regulatory measures for e-cigarettes, it is imperative to understand how approaches to risk, cost-benefit, and trade-offs have shaped interpretations of evidence.

By Amy L. Fairchild *and Ronald Bayer

In advance of a critical Framework Convention on Tobacco Control (FCTC) held in October 2014, two groups of scientists and public health experts launched a global battle royal over electronic cigarettes—devices that heat liquid nicotine but involve no tobacco.

Leaked documents appearing in the late spring indicated that the World Health Organization (WHO) was preparing to take an uncompromising stance against e-cigarettes at the FCTC meeting, treating them as a threat equal to tobacco cigarettes. This set the stage for 53 researchers from 18 nations, dominated by the United Kingdom, United States, and Australia, to send an urgent appeal to Dr. Margaret Chan, Director- General of WHO, on 26 May 2014.

It was critical, they argued, to remain open to evidence regarding “low-risk noncombustible nicotine or tobacco products that may become viable alternatives to smoking in the future” as a potential harm-reduction strategy ( 1).

There was “no evidence at present of material risk to health from vapour emitted from e-cigarettes” nor “credible evidence” that e-cigarettes would serve as a gateway to tobacco smoking. “We hope,” concluded the letter that “WHO will be in the vanguard of science-based, effective and ethical tobacco policy, embracing harm reduction.”

Three weeks later, on 16 June 2014, a response was sent to Dr. Chan, organized by American researcher Dr. Stanton Glantz ( 1) and cosigned by 129 experts from more than 24 countries. E-cigarettes, the letter stated, were little more than a Trojan horse promoted by an industry bent only on “increasing profits” through “predatory” practices.

The first letter to Chan, it charged, had made assertions about marketing, emissions, and harms that were “either contradicted by available evidence or for which no evidence is currently available.” Indeed, the letter warned, the harm-reduction advocates had not cited “a single scientific study” ( 1).

Charges and countercharges continued.

How can two groups, both of which seek to reduce the terrible burden of morbidity and mortality attributable to smoking, both of whom embrace the centrality of  evidencebased policy, come to such different conclusions?

To be sure, the strength of the current evidence and the basic soundness and logic of extrapolation based on that evidence are central. It may be years before these disagreements over the evidence—which involve profound contention over whether e-cigarettes will serve as “gateway” drugs, particularly for youth; whether “dual” use with tobacco cigarettes will undercut any morbidity and mortality benefits; and whether this potentially disruptive technology will prove to be an effective cessation tool—will be resolved.

But it is not evidence alone that accounts for this pitched battle. The opposing letters reflect very different understandings of what the protection of public health requires.

Those who called upon WHO to remain open to the possibility that e-cigarettes could reduce the toll of smoking explicitly embraced harm reduction as an organizing principle.

In contrast, the judgments of the second letter, while focused primarily on the science, were shaped implicitly by a precautionary impulse.

HARM REDUCTION AND PRECAUTION.

Harm reduction—an approach that embraces a posture of pragmatism and accepts that people will use drugs—has explicitly informed the position of those open to the use
of e-cigarettes as a means to limit the toll of smoking-related morbidity and mortality ( 1).

Some advocates argue that elimination of a habit like smoking should always be the goal; others maintain that risk minimization is sufficient ( 2). But regardless of how advocates position themselves on the question of cessation, the bar that must be met is not whether an alternative carries any risk, but whether there is enough evidence to suggest that the risks are less consequential than those of the behaviors in question. From this perspective, even uncertain evidence justifies action when the status quo—in the case of smoking, a projected one-billion deaths this century if left unchecked—is sufficiently threatening. Harm reduction requires that every piece of evidence be viewed against this deadly backdrop, including the harms of limiting or denying access to alternatives to tobacco cigarettes.

A very different approach informs those who want to ban or impose severe restrictions on ecigarettes.

For tobacco-control advocates taking a precautionary stance, those who would accept lesser harms are being duped by the industry, serving as little more than “naïve” pawns in a grand scheme to take back lost ground in the long battle over smoking ( 3). Given the long history of tobacco industry deception, such advocates assert that there can be no room for compromise when it comes to a product in which Big Tobacco has any interest.

This position echoes the Wingspread Statement of 1998, one of the foundational documents in the history of precautionary thinking: “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically” ( 4).

The Wingspread authors were particularly concerned that assessment of risks be conducted in advance of allowing the introduction of new products or practices. This, of course, is the logic that supports the system of drug regulation in Europe and the United States, which requires that products be proven “safe and effective”—not in absolute terms, but, as in the case of harm reduction, in a kind of risk-risk calculus—before being allowed onto the market. Nicotine replacement therapies—such as the patch and nicotine gum, for which the field has accepted the potential risks of long-term use—are tolerable given the consequences of smoking and comfortably fit within this model.

There are multiple understandings of the Precautionary Principle, some of which acknowledge the necessity of trade-offs and risk-benefit analysis. Other versions find the very notion of trade-offs morally offensive ( 5, 6). The question is, then, which version of the Precautionary Principle is at issue here?

In its strictest interpretation—sometimes called “deep green” precaution, reflecting the concept’s roots in environmental protection— the principle holds that any suspicion of harm should be sufficient to trigger prohibition, even “in the absence of any scientific evidence” and “without regard to cost” ( 6, 7).

Deep green precaution has the virtue of consistency, demanding and prohibiting certain courses of action when evidence is contested or unavailable. In the recent clash, the fiercest opposition to e-cigarettes has reflected a logic resembling a “deep green” version of the Precautionary Principle. Opponents of this perspective, most notably Cass Sunstein, have referred to the Precautionary Principle as the “paralysis principle” ( 8), arguing that it substitutes intuitive fear for scientific proof and that its hostility to cost-benefit analysis would impose regulatory standards that, in the end, would be both socially costly and harmful. Indeed, in 2000, the European Commission offered guidelines that clearly sought to address the “mixed, and sometimes contradictory views” on precaution.

What was essential in confronting risk, the guidelines stated, was “finding the correct balance” as a way to “avoid unwarranted recourse to the precautionary principle, as a
disguised form of protectionism” ( 9).

Not all the supporters of a precautionary approach embrace an uncompromising conception of precaution. For example, the economist Frank Chalupka [who signed a letter from the opponents of harm reduction] maintains that his views are best reflected in the “middle ground” American Heart Association guidelines on e-cigarettes that he coauthored. This policy statement offers a nuanced view of the evidence ( 10) and suggests a balanced regulatory approach, much like that being vetted by the U.S. Food and Drug Administration (FDA), which acknowledges scientific uncertainty and tries to draft a flexible framework with the capacity to add regulation over time, in response to emerging evidence.

Like their harm reduction counterparts, those committed to precaution have been open about the role that values play in their judgments. Stanton Glantz, one of the chief antagonists of e-cigarettes, brings to the debate an intimate, unparalleled knowledge of tobacco industry documents that leaves no room for illusions about deception on the part of the tobacco companies. For Glantz and other signatories of the second letter to Dr. Chan, the “fundamental and irreconcilable conflict of interest” between tobacco and public health demands an unyielding stance ( 1). What such a strong position does not acknowledge is that this perspective also entails a cost: It only recognizes the potential benefits of erecting barriers to e-cigarettes without considering the potential toll measured by lives lost to combustible products.

In a world of multiple risks, argues Jonathan Weiner, “precaution against one risk may induce other countervailing risks” and their associated burdens ( 5). Dr. Kenneth Warner, a signatory of the harm-reduction letter, argued in the 1990s, that it is critical to “recognize that what divides us are those judgments about trade-offs” ( 11).

CONCLUSION. Harm-reduction advocates, although not surprised, were bitterly disappointed, after the October 2014 FCTC meeting in Moscow, when WHO called on nation states to adopt very restrictive precautionary measures, urging that countries consider prohibiting e-cigarettes and banning advertising ( 12). Very different has been the response to the first Cochrane Review on ecigarettes published on 17 December 2014.

Although noting the need for more research, the review concluded that current evidence underscores the potential of e-cigarettes as cessation tools. Said one of the study’s authors, “None of the studies in this review found that smokers who used electronic cigarettes short-term (2 years or less) had an increased health risk compared to smokers who did not use electronic cigarettes. We did not find any evidence from observational studies that people who used electronic cigarettes at the same time as using regular cigarettes were less likely to quit smoking” ( 13).

The clash between harm reduction and precaution is not limited to e-cigarettes. The comment period on Swedish Match’s application to the FDA for Snus to be regarded as a Modified-Risk Tobacco Product (MRTP) remains open until 23 February 2015 ( 14).

The current battle lines for this smokeless tobacco product are very much marked by the two letters to Dr. Chan over the summer.

Warning labels on Snus and other smokeless tobacco products currently hew to precautionary syntax, stressing, “This product is not a safe alternative to cigarettes.”

Variants warn of gum disease, tooth loss, and oral cancer. If this first MRTP application is successful, the language of harm reduction with its emphasis on making clear both risks and benefits would prevail, with revised labels reading “No tobacco product is safe, but this product presents substantially lower risks to health than cigarettes” ( 15).

Ultimately, decisions about how to proceed will be made in the face of evolving evidence and the undeniable burden imposed by tobacco cigarettes. Decision-making may draw on elements of both precautionary thinking and harm reduction, but weighing the risks and benefits is unavoidable. It is imperative to recognize that deep precaution precludes that possibility. It has served as a kind of trump argument, hostile to the notion of trade-offs, seeing in them perilous compromise. Such a posture does not serve either science or policy well.

REFERENCES AND NOTES

1. Letters to WHO on nicotine science and public policy; http://nicotinepolicy.net/n-s-p/2003-glantz-letter-towho-the-importance-of-dispassionate-presentation-andinterpretation-of-evidence.
2. A. Fairchild, J. Colgrove, Am. J. Public Health 94, 192 (2004).
3. S. Chapman, M. A. Wakefield, Tobacco Control 22 (suppl. 1), i33 (2013).
4. Science and Environmental Health Network, www.sehn.org/state.html.
5. J. B. Weiner, in Human and Ecological Risk Assessment: Theory and Practice, D. J. Paustenbach, Ed. (Wiley, New York, 2002), pp. 1509–1531.
6. N. A. Ashford, in Protecting Public Health and the Environment: Implementing the Precautionary Principle, C. Raffensperger and J. Tickner, Eds. (Island Press,
Washington, DC, 1999), pp. 198–206.
7. A. Jordan, T. O’Riordan, in Protecting Public Health and the Environment: Implementing the Precautionary Principle, C. Raffensperger and J. Tickner, Eds. (Island Press, Washington, DC, 1999), pp. 20, 25.
8. C. R. Sunstein, Laws of Fear: Beyond the Precautionary Principle (Cambridge Univ. Press, New York, 1995).
9. Commission of European Communities, “Communication from the Commission on the Precautionary Principle” (CEC, Brussels, 2000).
10. A. Bhatnagar et al., Circulation 2014, 1 (2014).
11. Cited in M. Pertschunk, Smoke in Their Eyes: Lessons in Movement Leadership from the Tobacco Wars (Vanderbilt Univ. Press, Nashville, TN, 2001), p. 119.
12. WHO, FCTC/COP/6/A/R/2, Item 4.4.2 (WHO, Geneva, 2014), pp. 8–9.
13. New Cochrane evidence shows that electronic cigarettes facilitate smoking cessation, 17 December 2014, [press release]; https://www.cochrane.org/features/
new-cochrane-evidence-shows-electronic-cigarettesfacilitate-smoking-cessation.
14. Modified Risk Tobacco Product Applications, www.regulations.gov/#!documentDetail;D=FDA-2014-N-1051-0001.
15. M. Richtel, D. Jolly, New York Times, 30 November 2014, p. BU1.