Health Canada Nicotine Cap Submission March 2021-CLHealth Canada Nicotine Cap Submission March 2021-CLPRESS RELEASE.
LETTERS TO HEALTH CANADA.
PROPOSED NEW REGULATIONS TO LIMIT NICOTINE IN VAPOUR PRODUCTS
Tobacco Products Regulatory Office Tobacco Control Directorate Health Canada
Email: hc.pregs.sc@canada.ca
SUBMITTED BY RIGHTS4VAPERS MARCH 4, 2021
INTRODUCTION
In December 2020, Health Canada announced a proposal to lower the nicotine concentration to a maximum of 20 mg/mL and prohibit the packaging and sale of a vaping product if the nicotine concentration displayed on the package exceeds this new limit.
Rights4Vapers is pleased to provide Health Canada with our views on this proposal.
ABOUT US
Rights4Vapers is Canada’s leading vapour consumer advocacy group. Our organization works to ensure that the option to vape remains available to smokers who choose to make the switch. We represent the vape consumer, 98 percent of whom are former smokers, and boasts the largest survey data set of Canadian vapers with over 5,000 respondents. We are dedicated to the advancement of Canadian-based research on vaping.
We are an informal collection of committed advocates who believe that vapers and adult smokers deserve a less harmful alternative. We are guided by unpaid academic advisors.
We are a grassroots activist movement. We base our positions on the real-life experiences of adult vapers in Canada.
At the outset, we would like to stress that we do not think that minors should vape. Vaping products contain nicotine, an addictive substance. This being said, there is a question of access. Despite strict federal regulations that govern the sale of vapour products, and in particular the sale of these products to minors, minors are still vaping. The current federal regulations need to be better enforced.
We are not scientists. However, we follow the science of vaping where it leads. And the science tells us that vaping is less risky than smoking. We believe vapour products are the best and most effective alternative to smoking traditional combustible cigarettes.
In addition, Rights4Vapers reaches out to Canada’s vapers. We have the largest dataset of vaping behaviour in Canada. With over 5,000 respondents, we understand how adult vapers use their products and as a result understand how regulations will impact consumers.
Tens of thousands of Canadian smokers have turned to vaping as a way to reduce the health risks of smoking. Study after study has demonstrated that vaping is less harmful than smoking traditional combustible cigarettes. Public Health England published a paper in 2018 that states Rights4Vapers Submission 3 “vaping poses only a small fraction of the risks of smoking and switching completely from smoking to vaping conveys substantial health benefits.”1
We are concerned that the increasing number of proposed changes to vaping regulations across the country, particularly those banning flavours and imposing limits to nicotine strength, will deter smokers from choosing vaping as a safer alternative to smoking or push vapers back to
smoking.
THE VOICE OF VAPERS
We fundamentally believe that putting more restrictions of vaping products will be detrimental to the health of adult Canadian smokers and to the health of current vapers who may return to smoking if they cannot find a product that meets their needs.
We want to make sure that the voice of vapers is heard by officials at Health Canada. Most vapers would never think about sending an official submission in response to a regulatory change. We wanted to give them the chance.
With this in mind, we launched an online tool that gave vapers and supporters the opportunity to send a letter that urges Health Canada not to implement nicotine caps.
Over 2,300 Canadians took the opportunity. From coast-to-coast, from every province, vapers and supporters have told you that nicotine caps are not a good idea. They are not scientists, or politicians, or activists. They are ordinary Canadians who deserve a federal health ministry that will listen to their views. Their health and well-being deserve to be protected.
THE NICOTINE MYTH
Nicotine is not a carcinogen.
It is a stimulant and can cause dependence, but it is not the cause of smoking-related illnesses. Nicotine use is not risk-free, however. Minors, pregnant women and those suffering from unstable heart disease, severe hypertension and diabetes, among others, should not consume products that contain nicotine. In fact, the UK Royal College of Physicians considers medicinal nicotine to be a very safe drug.2
Nicotine itself does not have a significant impact on the health of people who smoke. However, when they stop smoking, they may feel irritable, restless, unable to concentrate, and most people experience cravings when they go without nicotine. Many people miss the nicotine when they stop smoking and experience a range of nicotine withdrawal symptoms which may make stopping smoking difficult.
Vaping can replace this nicotine but without many, or less of, the toxins found in cigarette smoke.
Having nicotine available in vaping products takes away these symptoms, and this can help break the cycle of addiction.
OUR POSITION
We believe that It is important to maintain an appropriate level of nicotine in vaping products to give new vapers the same experience as a traditional combustible cigarette. As we indicated above, vaping helps adult smokers mitigate the effects of nicotine withdrawal. In our survey of Canadian vapers, we ask about nicotine concentration. With over 5,000 vapers who have responded to our survey, we can confidently comment on the importance of nicotine concentration.
We have found that the majority of new vapers start with nicotine levels of above 7 mg. Some start with a very high nicotine level of 18 mg and more. However, as they continue to vape, the majority of users gradually decrease the level of nicotine to between 0 and 6 mg. It is vital to maintain an appropriate level of nicotine in vaping products to give new vapers the same experience as a traditional combustible cigarette.
CONCLUSION
Vaping is an important part of Canada’s tobacco harm reduction agenda. Health Canada has stated that “if you are a smoker, vaping is a less harmful option than smoking.”
Flavours and nicotine levels are not the problem when it comes to vaping. The true issues are accessibility, product standards and communications.
As we stated earlier, we believe that children should not vape. The problem is that kids are getting access to vaping products from friends and family. We need effective education and enforcement programs, not barriers that limit the choice of vaping products to adult smokers.
Vapers need to be confident that the product they are using complies with the highest product standards. The proliferation of black-market devices that can be tampered with is a growing concern. Just like with any other consumer good, e-cigarettes should adhere to safety and quality standards.
Finally, adult consumers need to know the facts about vaping. They need to know that vaping is less harmful than smoking. They need to know the science behind it. They need to know their options and how to use them.
We would welcome the opportunity to publicly present our positions. We trust that any changes to Canada’s federal vaping regulations take into consideration the many thousands of adult smokers who have chosen vaping as a way to quit smoking and reduce their risk of the particular health problems caused by smoking.
References:
1. https://www.gov.uk/government/news/phe-publishes-independent-expert-e-cigarettes-evidence-review
2. Harm reduction in nicotine addiction: helping people who can’t quit, Royal College of Physicians, A report by the Tobacco Advisory Group of the Royal College of Physicians, page 126, 2017.
DOWNLOAD THE R4V SUBMISSIONS PDF HERE:
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