GOVERNMENT OF CANADA
LEGISLATIVE 2022 REVIEW ON
THE TOBACCO & VAPING PRODUCTS ACT
Review Prepared By:
Bill Tarling (Age: 62)
BC, Canada
Status: Consumer (no conflicts of interest)
CONFLICTS OF INTEREST: None – I am strictly a consumer, and I have no financial
investments or position within the vaping industry.
MY PERSONAL BACKGROUND:
I am a Canadian Citizen, male, 62 years old (born April 23rd, 1960), currently residing in BC,
Canada with my wife and step daughter. I was a fairly heavy smoker [approximately 2 packs a
day] for over 37 years. I tried to stop smoking by cold turkey, Pharma approved nic gum,
nicotine patches, nicotine lozenges, doctor prescribed smoking cessation medicine,
acupuncture, and even 2 sessions of smoking cessation laser therapy – none of these
methods worked for me.
On February 6th, 2014 [when I was 53 years old]. I decided to purchase my first vape starter
kit [an EVOD open system], and from my first puff from the device, I have never smoked
again. I started on a 24mg (2.4% standard liquid nicotine base) simulated tobacco flavour eliquid,
and within a couple of weeks lowered it to 18mg (1.8% standard liquid nicotine base)
strength, at which level I vaped for about 1½ years, and then lowered my level to 12mg
(1.2% standard liquid nicotine base), and have been vaping zero nicotine e-liquids [or at least
until the BC Government banned retail sales of zero nicotine e-liquids, so now they may only
be purchase containing nicotine.
I continued to vape even the no nicotine e-liquids as it kept me from being going back to
smoking, or renewing smoking cravings.
While I started by using a simulated tobacco flavour, about a month and a half after I first
started vaping, I tried non tobacco flavours: grape, root beer, licorice, spearmint, orange
bubblegum, and assorted pastry flavour e-liquids. After trying the non tobacco flavors, I never
again vaped a simulated tobacco flavoured e-liquid again. In fact, having the more appealing
flavours left me with a distaste for tobacco.
Since switching to vaping, I noticed a huge health improvement (since I was able to stop
smoking thanks to the vape products), and no longer even needed my inhaler. About 6
months ago, I had a very extensive breathing and lung testing examination, and the results
came back as “exactly the range expected for someone my height, age, and weight as a nonsmoker”.
I continue to vape so that I never get cravings to start smoking again, but the performance
and illogical over regulating being considered and/or proposed by Health Canada has left me
very concerned – given they’re basing their regulations on mostly theoretical or hypothetical
study conclusions [including many which have been flawed, debunked, and some also based
on retracted studies] rather than Scientifically sound and peer reviewed. In fact, a number of
their claims are based on known flasehoods and/or sources and organizations whose
financial revenue is dependant on people continuing to smoke.
I’m including some perspective, for the review, including: flavours, accessibility, marketing,
misleading public information, and also youth usage. As well, I will include some possible
considerations or solutions to address some of the concerns.
TOBACCO AND VAPING PRODUCT ACT
During the BILL S-5 HESA Committee Hearing of April 12th, 2017
https://sencanada.ca/en/Content/Sen/Committee/421/SOCI/21EV-53253-E
SENATOR PETITCLERC ASKED:
“I will start with a question on flavouring because it is something we have heard about a lot. I know it’s
a concern of not only the vaping association but also individuals who were strongly attached to the
flavours.
Why is this very important? How confident do you feel it is effective in terms of protecting our youth?”
The Honourable Jane Philpott, P.C., M.P., Minister of Health (response):
“In terms of the question on flavours, there has been some clarification in your discussions around the
specifics of the legislation and the intention to develop regulations associated with it.
The goal would be not to restrict the ability to make various chemical flavourings. In fact there
are, as I understand, almost a limited number of flavours that could be used for vaping products, but to
limit the ability to promote a specific flavour which might be particularly appealing to youth. You
will see the theme, as you well know, in the legislation over and over again around protecting youth.
It may be that a particular flavour might be seen to be helpful for those who are attempting to
reduce smoking and wanting to be able to use a vaping product that has a palatable flavour.
What we don’t want to see are products that promote themselves to be bubblegum flavour, for
example, in a way that young children and youth might feel that this would be a product they would
particularly enjoy. Anything we see as an inducement to encourage youth to take up something that
would seem to be particularly attractive because of the name of the flavour is something that we
would seek to limit.”
During the BILL S-5 HESA Committee Hearing of April 13th, 2017
https://sencanada.ca/en/Content/Sen/Committee/421/SOCI/21EV-53262-E
SENATOR EGGLETON ASKED:
“I understand from what you said in your original response to Senator Petitclerc that it’s in
the advertising and in the promotion where you might prohibit them saying chocolate
or bubblegum or candy, but actually you’re not going to prohibit any of those flavours
for any adult who wants to have them as part of a cessation program. Is that
correct?”
The Honourable Jane Philpott, P.C., M.P., Minister of Health (response):
“Yes, that’s correct. You’re absolutely right that this will be done largely through regulations and there
will be, as with any regulation, opportunity for consultation in that process.
My officials may want to clarify this further, but because of the chemical structure of flavouring it would
be almost impossible, as I understand it, to actually list what a specific taste is like. There are many
types of tastes that something could have, so there would not be anything to prohibit
something tasting in a palatable, appealing way which might allow, as you said, someone who is
currently a smoker to find it easier to switch to a less harmful product. Again, it’s in the spirit of
protecting youth to not give these flavours names that would make it sound like they were
something appetizing and appealing to young people.”
REVIEW NOTE: Names and flavour descriptors, as well as label imagery have now been restricted
correctly, as well as restrictions to promoting such flavours. However, Health Canada is now proposing
to not only restrict the various chemical flavourings which make the product, but are limiting it to a very
short list of which flavouring chemicals may be used (in order to make them less palatable) – including
limiting them to some chemicals which aren’t even used in making the products.
TOBACCO AND VAPING PRODUCT ACT
During the BILL S-5 HESA Committee Hearing of April 13th, 2017
https://sencanada.ca/en/Content/Sen/Committee/421/SOCI/21EV-53262-E
Suzy McDonald, Director General, Tobacco Products Directorate, Health Canada:
“Again, vaping products are not tobacco products. “
REVIEW NOTE: Agreed, Vaping Products ARE NOT Tobacco Products – However, Health Canada
continues to conflate the products by eliciting data and hazards from tobacco products as if they were
the same data and dangers as pertains to nicotine based vape products.
Even The Honourable Jane Philpott, P.C., M.P., Minister of Health conflated vaping with smoking and
tobacco products during the Bill S-5 HESA Committee Hearing of April 12th, 2017 by opening with a
long list of data and deaths from smoking as her preamble to the subject being debated: Vaping
Health Canada also misleads the facts by conflating alternative vape products [e.g. cannabis or THC
based products] with the unrelated nicotine based version of vape products, by combining them as
shared data under a catch-all general term of “vaping” rather than specifying what portion of data and
figures is representative of the separate product type categories.
Nicotine based e-liquid products are not only completely different products compared to cannabis or
alternative vape type products; they’re also intended and marketed to unrelated markets and customer
targets.
It’s also very concerning that, while Health Canada usually includes smoking data and warnings as if
they’re applicable to nicotine based vape products; they also prohibit the vape products from making
any comparative claims: e.g. Health Canada prohibits the claim “vaping is safer than smoking”, even
though there are plentiful professional scientific and medical studies which have proven that claim to
be true. [Note: the professional vape industry says “safer”, not “safe”]
During the BILL S-5 HESA Committee Hearing of April 13th, 2017
https://sencanada.ca/en/Content/Sen/Committee/421/SOCI/21EV-53262-E
RE: Permitted Claims
SENATOR PETICLERC:
“We have heard a lot of concern that this clause was too restrictive and that it would be very difficult
for retailers or manufacturers to effectively communicate health risk information about vaping products
to their customers.
Quite simply, this would allow via regulation a list of authorized messages. Whether it is this product is
less harmful or this product contains chemicals or something like that, a list of authorized messages
could be used to inform Canadians. That’s basically what this is trying to do.”
SENATOR SEIDMAN:
“I think this is a very effective response to a lot of the testimony that we heard, including the testimony
from Dr. Britton and Dr. Hammond, which was extremely credible.
My question has to do with how the messages are going to be constructed. Who will construct them?”
Suzy McDonald, Director General, Tobacco Products Directorate, Health Canada:
“In a situation like this we would have to set out the regulatory authority that would allow us to create
that list. In setting out that regulatory authority, we would need to be very clear about how that list
would be constructed and who would be doing it.
To be honest, we haven’t sorted through all of the details of exactly what that looks like, but our
minister spoke yesterday about the fact that we with CIHR, the Canadian Institutes of Health
Research, are putting in place an expert science advisory body to look at the evidence. We would
expect that would play some form in how this moves forward.”
REVIEW NOTE: To date, there is still no detailed list of permissible claims. In fact, it would be
illegal for vape products to include on product labels or elsewhere “Intended For Adult Use Only –
Keep Out Of Reach Of Children” since Health Canada has not approved it – yet this claim should be
on every vape bottle… Instead, Health Canada requires a large “POISON” warning [covering approx.
30% of the label front] even though even Canadian detergents, bleaches, medicines, cleaners, and
even many pesticides aren’t required to include predominantly on the face of their labels, if at all on
the front.
INTENDED FOR ADULT USE ONLY
KEEP OUT OF REACH OF CHILDREN
HEALTH CANADA VERY AWARE THEIR REGULATIONS
WILL ENCOURAGE A RETURN TO SMOKING
PRODUCT NICOTINE CONCENTRATION RESTRICTIONS
Canada Gazette, Part I, Volume 154, Number 51: Concentration of Nicotine
in Vaping Products Regulations [Dec 19,2020]
https://gazette.gc.ca/rp-pr/p1/2020/2020-12-19/html/reg3-eng.html
“Qualitative costs
3. Costs to vaping industry as a result of vapers transitioning back to smoking
About 38% of current vapers (past 30-day use) aged 15 and above are dual users (i.e. individuals who
vape and smoke cigarettes). Total profit loss to vaping industry members who are also manufacturers
of tobacco products may be mitigated by substitution of tobacco purchases from dual users who
would go back to smoking and adult smokers who would continue to smoke instead of
switching to vaping products at 20 mg/mL nicotine or below.
After the proposed Regulations come into force, it is anticipated that some dual users who currently
use vaping products above 20 mg/mL nicotine would not substitute their vaping product purchases
with lower concentrations of nicotine. They would choose to purchase more cigarettes, hence
offsetting the loss of sales of vaping products above 20 mg/mL nicotine. However, Health Canada
does not have the data necessary to quantify these costs.”
“5. Costs to adults who smoke and dual users
There may be some incremental cost impacts on adults who smoke and adult dual users who use
vaping products above 20 mg/mL nicotine. Some current smokers who would try vaping products may
find that vaping products at 20 mg/mL nicotine or below are not satisfying to them and could
therefore end up being dual users or remain smokers. These persons would continue to be
exposed to harmful chemicals from the long-term use of tobacco products.
It is also anticipated that certain dual users could relapse to smoking only as a result of the
proposed Regulations. However, benefits of vaping by people who smoke are only accrued if they
completely switch to vaping.”
HEALTH CANADA VERY AWARE THEIR REGULATIONS
WILL ENCOURAGE A RETURN TO SMOKING
PRODUCT FLAVOUR RESTRICTIONS
CANADA GAZETTE Part 1 – Vol. 155, No. 25 [page 140]
https://gazette.gc.ca/rp-pr/p1/2021/2021-06-19/pdf/g1-15525.pdf
“10. Costs to vaping industry as a result of dual users modifying their smoking behaviour
About 46% of current vapers (past-30-day use) aged 20 years and older are dual users
(i.e. individuals who vape and smoke cigarettes). The total profit loss to the vaping industry that also
manufactures tobacco products may be mitigated by the substitution of tobacco purchases from
dual users who would go back to smoking and adults who smoke who would continue to
smoke instead of switching to tobacco or mint/menthol flavoured vaping products.
After the proposal comes into force, it is anticipated that some dual users who currently use
flavoured vaping products would not substitute their purchases with tobacco and
mint/menthol-flavoured vaping products. They would choose to purchase more cigarettes,
hence offsetting the loss of sales of tobacco- and mint/menthol flavoured vaping products.”
“11. Costs to adults who smoke and dual users
There may be some incremental cost impacts on adults who smoke and adult dual users who use
flavoured vaping products. Some adults who smoke who would try tobacco and mint/mentholflavoured
vaping products may find these vaping products are not pleasant or palatable and
could therefore end up being dual users or remain smokers. These persons would continue to be
exposed to harmful chemicals from the long-term use of tobacco products.
It is also anticipated that certain dual users would relapse to smoking only as a result of the
proposal. However, benefits of vaping by people who smoke are only accrued if they completely
switch to vaping.”
UNINTENDED CONSEQUENCES OF A
DE FACTO FLAVOUR BAN / PROHIBITION
While Health Canada might say it isn’t prohibiting vape products [which were supposedly
made legal during the Bill S-5 sessions]; they are, in fact, forcing most shops and
manufacturers [except perhaps for the products manufactured and marketed by the Big
Tobacco companies] out of business.
These forced business closures and job losses aren’t hypothetical – if a store suddenly has
almost 90% of its legal product and stock deemed illegal, then they have nothing to sell.
Granted the usual response is that shops can simply diversify and sell other types of
products, but that not a solution for professional vape shops whose primary clientele and
customer base is specifically for those who have switched from smoking to nicotine based
vape products.
While some shops have had to hybrid and carry products normally not intended for their
target customer [such as by having to also sell cannabis products] just to keep their doors
open; that’s still disregarding that nicotine based products customer markets are completely
unrelated to those other product categories.
Yes, gas stations, convenience stores, headshops, and other multi-purposed general stores
won’t be as troubled over having fewer nicotine based vape products to sell – but then again
they aren’t specialized shops, specifically catering to transitioning smokers away from
tobacco and cigarettes.
“SMOKERS” are the main target market and customer base by dedicated and specialized
nicotine based vape products. Cannabis shops cater to people who use cannabis – nicotine
based vape shops caters to Smokers wanting to switch away from smoking.
How long do you thing a grocery store would last if it had to empty all its shelves, and only sell
a couple of types of plain tofu and some anchovies?… and how long would customers be
satisfied with that being the only available meal? That would be the same result with making
over 90% of the available products [which are legal] suddenly illegal – and all over the
pretense of “to protect the children” (except even by Health Canada’s own admission, as well
as proven through multiple studies, is not really as “epidemic” as purported).
NOTE: the term “Youth Vaping Epidemic” was based on any professional scientific report or study; it
came from a U.S. FDA focus group in determining what frightful term to increase the public support
against an unseen enemy – in the U.S., smoking funds most large Health organizations and many
governmental agencies (if people stop smoking, they lose their funding and revenue stream). Yet
Health Canada immediately adopts any negative term the U.S. deems desirable to instill control over,
and they even use the same talking points and debunked claims. It’s reached the point where we must
almost question whether our Canadian agencies are actually just branch extensions from America?
There are 2 main types of vape products: Closed Systems (e.g. single use disposable vape
devices/products such as JUUL, Puff Bar, etc. – often available in general or convenience
stores), and Open Systems [the customizable vape products that are refillable and should
really only be sold through specialized vape shops].
WHICH CATEGORY DO YOUTH USE MOST?
The devices most often confiscated from youth and teens are widely available Closed System
disposables or those with replaceable throw away pods. They’re easier to hide, less
conspicuous, available at almost any convenience store or local gas station, easy to use,
need no maintenance, and most importantly – they’re cheap to buy.
Open systems, with larger devices, and more specialized functions and designs are far more
costly. The reason they should really only be sold in specialized vape shops is because they
require more attention and servicing for the specific needs on the individual customer. Much
more attention is needed to help ensure safe and proper usage (as well as maintenance),
providing knowledgeable staff who can help tailor the products to the specific needs of the
transitioned or transitioning smoker, educate them on safety habits. The intent is to trying
helping that customer from wanting to go back to smoking.
In easiest terms, Closed Disposable Systems are like a bicycle – Open Specialized Vape
Systems are like a motorcycle: they’re more expensive, more powerful, and require a lot more
care and understanding to handle it.
PROBLEMATIC ISSUES WITH HEALTH CANADA YOUTH VAPING FIGURES
https://www.canada.ca/content/dam/hc-sc/documents/programs/consultationlegislative-
review-tobacco-vaping-products-act/34-21-3028-TVPA-Legislative-Review-
EN05.pdf
First of all, aside from using old data and even admitting:
“There have also been concerns that an increase in youth vaping may lead to increases in
youth smoking rates in Canada. However, recent data, presented below, suggests that, thus far,
this has not been the case”
and
“The prevalence of daily smoking among youth aged 15 to 19 years was so low (small sample
size) that it was considered to be ‘unreportable’ in 2020”,
and a cautionary warning about their data:
“Caution is warranted when comparing results from the Canadian Tobacco, Alcohol and Drugs
Survey and the Canadian Tobacco and Nicotine Survey, given the differences in the sampling
frames, data collection modes and timeframes, and sample sizes of the surveys.”
The “Surveys” also neglect to explain and separate vape usage from strictly nicotine e-liquid
vape products apart from alternative Cannabis, THC, CBD, and other unrelated products;
thus leading to a misleading-by-design inflation of the Youth Vaping Usage figures.
Additionally, the surveys also include youth who took a single puff [even if they didn’t like it,
and never tried it again] as counting towards being recorded as a youth vaper.
The data, and high usage figures Health Canada also uses (based on sample data from such
surveys) is from “ever tried” talliation [including single puff use, as well for responses using
any type of vape product even if unrelated to nicotine based vape products].
When you closely examine the figures, the “Daily Use” figures are extremely low. Additionally,
they neglect to separate youth smokers from youth non-smokers. Multiple data analysis
studies, both in Canada and the United States, have found that the true percentage of nonsmoking
daily vaping youth figures drops far below 1%.
While likely well intentioned, these Government general surveys neglect to separate the
product usage types or categories clearly. They also allow for a wide range of interpretation of
the questions. Even when I took similar agency surveys when in my youth, whenever I ask
“What do they mean by this?” or “Is this the type of thing they include or exclude in the
question?” — the response was always “Just put down whatever you think the question means
or is asking”
(i.e. the wording was so generalized or vague that it was common to not understand what
specific information was being requested – as was often common when discussing the
various question with other students that completed the surveys too and so simply replied “I
have no idea what they wanted, so I just answered ‘yes’ or ‘no’ to finish it”)
FURTHER QUESTIONABLE “SURVEY” DATA CONCLUSIONS
It is rather inconsistent when Health Canada and other Gov’t funded agencies and
organizations toute alarmingly high usage rates, yet also admit there is a huge decline in
actual usage. This can be seen when figures [very similar and varied to American casual
surveys and/or polls] will cry out “Epidemic” levels around 70% to 80% or more youth usage
[which includes one time one puff usage, as well as usage from ANY category or yape on
vape content], but when you drill down to actual Daily Usage, the figures usually plummet to
about 3% and even lower.
This then brings up the questions (1) what is the “epidemic” figure based upon, and (2) why is
there such inconsistency between claimed high alarming usage figures when stricter
regulations are desired to be passed, compared to the actual habitual use figures (which the
agencies tend to use in order to somehow show their efforts are being successful.
HEALTH CANADA REVIEW OF 5 VAPING RELATED OBJECTIVES
(a.) protect young persons and non-users of tobacco products from inducements to
use vaping products;
Health Canada has addressed this objective by restricting the promotion of the products away
from youth oriented publications and media. As well, e-liquid and product labels have required
proper and partially adequate changes to the labelling, imagery, branding, and Flavour
naming [NOTE: Although they still require the 30% label coverage to include the
inappropriately large POISON warnings on the front of the label – and have not approved any
“Intended For Adult Use Only – Keep Out Of Reach Of Children” en lieu or even permissible
to include.
Age Restrictions and Retailer Age ID Verification are required, so youth may not legally
purchase vape products.
PROBLEM: Simply adding more laws or restrictions in attempt to make the products less
accessible (including by legal adults) DOES NOT address the issue when there is (1) no
enforcement of the current laws and restrictions, (2) places no onus or consequences on the
youth breaking the law, (3) does not target the actual culprits providing the products to youth
illegally [and in fact, the additional restrictions, bans, and prohibitions have always proven to
increase the illegal black market sourcing], and (4) only penalizes the legitimate retail that
does abide by the Age Restriction & Verification laws.
SOLUTION and/or IMPROVEMENT CONSIDERATIONS:
• Fines and/or penalties need to be increased and enforced for those that break the laws
– both for the youth offenders, and for the supplier or source that directly provided the
vape products to the youth without Due Diligence to make best effort to ensure the
buyer was of legal age.
• An approved standardized Age Verification system should be required for any person
or establishment selling the products (including online retailers)
• A separate Retail Vape License license should be required (and not under a general
Tobacco Retailer license – it would be strictly for retailers and sellers selling vape
products). That way if a retailer is in repeated breaches of the law, that license may be
revoked, and they would no longer be legally allowed to carry or provide vape
products.
SOLUTION and/or IMPROVEMENT CONSIDERATIONS (continued):
• Open System vape products [e.g. devices tanks, and components which can be
customized, refilled, reused, should be restricted to Adult Only specialized vape shops
which offer nicotine based e-liquid vape products, which comprise at least 98% of their
merchandise.. NOTE: Cannabis and other vape product variations and categories
would not be included in the Vape License as they would be required under the
Cannabis Retailer classification.
• Closed System vape products [e.g. disposables, single use vape pods, etc.] which
might be sold by convenience, multi market stores [that aren’t at least 98% nic based
vape products only] or non-specialty shops would be required to maintain a Restricted
Vape Licence; meaning they could only sell the approved closed system products, and
would not legally be legally allowed to sell the Open System products or components
thereof.
• Fines and penalties (as well as enforcement) needs to be increased [Note: many
general retailers aren’t hindered by the current fines since the penalties are too
minimal compared to their uncaught sales for them to be much of a deterrent. Repeat
offenders should be given and larger exponentially heavier fine for repeat offences if
they cannot show that a valid attempt of Due Diligence was made.
NOTE: Any shop, including those making legitimate efforts to Age Verify the buyer, can miss a
couple due to fake or false identification. As well, they have no control over what the adult
buyer does with the products once sold – so the buyer who then supplies the products to
minors would be the offender. Due Diligence would include refusing to sell to an adult customer
of whom they have reasonable suspicion is making the purchase to provide to a minor(s) –
much like Liquor Stores where minors approach and get an adult to buy liquor for them.
Repeat offences within a specified period would be grounds for Revoking the person or
establishment’s Vape Retailer License.
• Parents or Guardians of minors purchasing, selling, or using vape products should also
be notified, and perhaps face a small fine as well. i.e. Put some onus on the parents to
once again Parent and discipline their kids.
HEALTH CANADA REVIEW OF 5 VAPING RELATED OBJECTIVES
(b.) protect the health of young persons and non-users of tobacco products from
exposure to and dependence on nicotine that could result from the use of vaping
products;
First off, it’s important to halt over emphasized claims about the addictiveness of nicotine on
its own. Yes, nicotine does have some short term addictive properties on its own, but there
have been professional scientific studies which found it was a relatively short termed
addiction when not modified.
One of the reasons it has been vilified is because of how long term addictive cigarettes and
smoking have become using nicotine. However what is often not mentioned is that it was
back in the 1950’s generation that tobacco companies realized their products weren’t as
addictive [retaining the young smoker] long term as desired – which was why they added so
many toxins, carcinogens, and other chemicals in order to boost or increase the addictiveness
of the nicotine in their cigarettes.
E-liquid products do not (and should not) use these chemical and carcinogen booster
ingredients in their e-liquids. The damaging health effects from smoking are caused by the
combustion and high levels of toxins from the cigarettes, not the nicotine itself.
NOTE: I would highly recommend watching the in-depth documentary “You Don’t Know
Nicotine” to get a more in-depth understanding or both the pros, and cons, in regards to
nicotine: https://knownicotine.com/
It’s also important to realize that the diluted liquid nicotine, used in vape products, is the same
as the nicotine found in approved pharmaceutical NRT smoking cessation products [and often
in lower levels] – they are not the same as the final cigarette boosted nicotine.
NOTE: In Canada, it is legal for a minor to buy nicotine gum, patches, lozenges, and
other nicotine NRT products without parental approval or age verification
Another difference between 2nd hand vapour and 2nd hand smoke from cigarettes is that the
exhaled vapour particles from vape products are designed to dissipate quickly, without the
toxic lingering or residue. Extensive professional scientific studies have been done on the
contents of exhaled vapour, and found that it was relatively comparable to regular normal air
in the environment, and the risk levels were found to be unconstitutionally low [far below the
measurable level of concern] and negligeable.
While we’ve all seen (and even heard from Health Canada) frightening reports of fine metal
particles and carcinogens in the air; it’s important to realize that any of the levels found are
vastly below any danger level. One was some of the early pseudo studies achieved the higher
rates or levels of toxins was by over heating the products [often drying out the liquid so that it
was the actual wicking material that was burning, not e-liquid vapour].
IMPORTANT: It is critical to understand that nicotine based vape products are water-soluable.
It is the cannabinoid and alternative variation products that are oil based (and can coat
the lungs). Some people do find they have a minor irritation to the PG [Propylene Glycol] in
nicotine vape products, but that doesn’t create long term health concerns as they simply use
e-liquids which use a lower PG level.
HEALTH CANADA REVIEW OF 5 VAPING RELATED OBJECTIVES
(c.) protect the health of young persons by restricting access to vaping products;
As covered in responding to topic (a.) earlier, Health Canada has addressed this objective by
restricting the promotion of the products away from youth oriented publications and media. As
well, e-liquid and product labels have required proper and partially adequate changes to the
labelling, imagery, branding, and Flavour naming.
Age Restrictions and Retailer Age ID Verification are also required, so youth may not legally
purchase vape products.
The same Problem and Solution Considerations is applicable
HEALTH CANADA REVIEW OF 5 VAPING RELATED OBJECTIVES
(d.) prevent the public from being deceived or misled with respect to the health hazards
of using vaping products;
It is important for the public and adult vapers to be aware of potential health hazards in order
to make an informed decisions…
HOWEVER: Health Hazards MUST be based on actual Scientific studies, which use proper
methodology [i.e. not misleading-by-design where it’s construct to result in a predetermined or
hypothetical finding]
Sadly, most studies and claims which grab the media highlights, aren’t based in true real life
scientific methodology. Many also conclude with concerning results which contradict their own
data. Worse yet, they make these “Conclusions” as if vaping was Causational, while their
actual data was merely Coincidental.
NOTE: “a strong association is not a proof of causation”
Indeed, many of the studies and claims reported, even by Health Canada, are based on
hypothetical and/or theoretical conclusions. Many are also not actual scientific studies, but
rather results from general surveys, opinion pieces, or even simple polls; with little or no
actual scientific basis behind them. Some even use data and reference other studies which
have been repeatedly debunked, exposed as flawed due to improper methodology, and some
even using data from other studies which have since been retracted.
SCIENTIFIC METHODOLOGY IS CRITICAL:
Studies – both pro and con in results – whether for or against vaping, must be examined for
how they were scientifically conducted. Mice and rats [forced streamed vapour into their
lungs, at levels which would be impossible for humans to endure, and use patterns which
have no resemblance to real life use, and with limited actual breathable air] are not humans –
nor do we vape that way. Like wise with Silver Fish, or even exposed cells in a petri dish
being doused in high concentrations being touted as conclusive that vaping was the cause of
damage [and ignoring the fact that humans regularly experience some cell irritations, and the
cells are constantly repairing or replacing themselves normally.
Many of headline reported studies [from both sides of the vaping debate] have been easy
casual studies, or misleading-by-design in order to get the desired predetermined results.
Unfortunately Health Canada primarily selects, promotes, and propagates most of the
claims from pseudo studies, polls, or surveys; and ignores those that show a proven
scientific benefit.
HEALTH CANADA REVIEW OF 5 VAPING RELATED OBJECTIVES
(e.) enhance public awareness of those hazards;
As with the commentary in question (d.), it’s important to realize that the general Public looks
towards Health Canada’s advice as reliable [and supposedly based on professional and
scientific fact]. In truth, Health Canada has done little to promote the potential of nicotine
based products as a sound and potentially valuable Harm Reduction tool away from smoking,
and also tends to downplay any scientific evidence supporting that Harm Reduction option.
True, Health Canada will often include a line saying [paraphrased] “vaping is safer than
smoking” – but that line is usually buried deep within all its negative conflations and claims.
IN FACT: Just the wording of Review Topic requests in (d.) and (e.) alone show that
Health Canada has no desire for any Harm Reduction or positive scientific inclusions,
and instead only want to focus on Hazards and Warnings (even if they’re scientifically
unfounded, hypothetical, or theoretical).
In the UK, the Health Industries conducted extensive unbiased research on vaping, and found
the health improvements in converting smokers to vaping was so valuable that the
organizations and majority of their Legislature now support vaping as a serious, viable, and
valuable Harm Reduction option. Their Youth Smoking rate has also plummeted to its lowest
rate ever.
Even France is far ahead of Canada, and even North America as a whole; and have
developed scientific equipment and methodologies which realistically mimic how the normal
vaper uses the products, but have also to accuracy and scales of the contents, residuals,
components, and effects from using vape products.
Canada (including Health Canada) meanwhile simply copies and pastes headline claims,
most often accepting unscientific pseudo studies as if they were fact based.
“Protect The Kids” is an easy deception to gain public support under the pretense of
only doing what helps them – but as their own reports have disclosed, they know their
regulations will drive a number of adults back to smoking, and rather than enforcing
their current laws and regulations, their agenda instead is to penalize the legitimate
adult retailers and vape consumers.