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June 25 2019

Gottlieb: A Little Too Late on E-Cigarettes

by Julie Gunlock

In this morning’s Wall Street Journal, former FDA commissioner Scott Gottlieb tangles with the question of how the FDA should regulate e-cigarettes.  In “The FDA’s Challenge on E-Cigs: Minimize the danger to minors while preserving a smoking-cessation tool,” Gottlieb acknowledges e-cigarettes are less harmful than traditional cigarettes and then goes on to explain the challenges faced by the FDA, asking how the agency can preserve e-cigarettes as a tool to help adult smokers while also reducing teen vaping.

Yet Gottlieb was the head of the FDA for years and did nothing to create a regulatory system that validated e-cigarettes as a smoking cessation tool for adult smokers. While heading the agency, Gottlieb didn’t create a “pathway” for a better regulatory system. Instead, he downplayed the benefits of e-cigarettes as a cessation tool and stoked fears about teen smoking—which he continues to do in this article. 

Of course, everyone wants the rate of teen use of all of these products -- e-cigarettes, combustible cigarettes, marijuana, etc. -- to be zero.  However, given that teens are likely to continue to experiment, it’s important to consider the relative health risks they pose (vaping flavored liquid is certainly less harmful than smoking combustible cigarettes) and not use a misleading terms like “teen epidemic,” when, as shown by the CDC data, a very small percentage of teens habitually vape.

Gottlieb bases his “teen epidemic” statement on a CDC study of teen e-cigarette use called “Notes from the Field: Use of Electronic Cigarettes and Any Tobacco Product Among Middle and High School Students — United States, 2011–2018.” Look at this paragraph (emphasis mine): 

Among high school students, current e-cigarette use increased from 1.5% (220,000 students) in 2011 to 20.8% (3.05 million students) in 2018 (p<0.001) (Figure). During 2017–2018, current e-cigarette use increased by 78% (from 11.7% to 20.8%, p<0.001). The proportion of current e-cigarette users who reported use on ≥20 of the past 30 days increased from 20.0% in 2017 to 27.7% in 2018 (p = 0.008). Among high school students, during 2017–2018, current use of any flavored e-cigarettes increased among current e-cigarette users (from 60.9% to 67.8%, p = 0.02); current use of menthol- or mint-flavored e-cigarettes increased among all current e-cigarette users (from 42.3% to 51.2%, p = 0.04) and current exclusive e-cigarette users (from 21.4% to 38.1%, p = 0.002).

It’s true that e-cigarette use among teens increased, but note that the 78 percent figure is only possible because the CDC defines “current e-cigarette use,” as any teen who vaped once in a 30-day period. Vaping once, twice, even five times a month does not make one a habitual e-cigarette user. This type of use is more likely reflective of a teen who wants to look cool at a party or fit in with his or her friends. Of course, that’s behavior that all parents would prefer didn’t happen, but it is also worth considering that, if vaping wasn’t an option, these teens might instead experiment with more harmful combustible cigarettes instead.  

In addition, the CDC did not ascertain if these users were using vaping liquid with nicotine or without nicotine, so many of these incidents could have involved nicotine-free vape liquid, meaning they weren’t vulnerable to physical addiction.

The biggest concern for the CDC and public health officials should be habitual teen smokers. And thankfully that number is very low. Here are the real figures.

According to the CDC, the total number of high school students in 2018 was approximately 14,663,461. Of those, 20.8 percent or 3.05 million were “current e-cigarette users” which the CDC defines as using an e-cigarette once or more in 30 days. Yet, the CDC also says that, of that 3.05 million, 27 percent or about 845,000 are habitual e-cigarette users (vaping more or equal to 20 times per month). That means, around 5.7 percent of all high school students regularly vape. 

It’s certainly a worthy goal to try to dissuade that 5.7 percent from vaping, but it should also be kept in perspective. 

Gottlieb also leaves out some pretty important data on teen behaviors, including that, while vaping has increased, the rate of smoking combustible cigarettes has declined. In 2018, only 4 percent of tenth graders smoked in the last 30 days—that’s down from a high of 28.8 percent in 1976! And teen smoking (of traditional cigarettes) is at a historic low. 

This week, the city of San Francisco—the home of harm reduction—is set to ban e-cigarettes entirely inside city limits. But you know what will still be available in the marketplace? Cigarettes. That’s right. San Francisco is outlawing a safer product while allowing a cancer-causing product to stay on store shelves.

This action by the San Francisco city council is partly due to the moral panic about e-cigarettes and teen use that Gottlieb helped create.   

He could have set the tone at the FDA by encouraging agency regulators to take a nuanced approach to this new technology, but he didn’t, and made life harder for smokers trying to quit.   His Wall Street Journal piece asking for a measured approach to regulation comes a little too late. 

 





Independent Women's Forum is an educational 501(c)(3) dedicated to developing and advancing policies that aren’t just well intended, but actually enhance people’s freedom, choices, and opportunities. IWF is the sister organization of the Independent Women’s Voice.​
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