FEEDBACK FOR:

PROPOSED NEW REGULATIONS TO LIMIT NICOTINE IN VAPOUR PRODUCTS

Matthew Cook

Tobacco Products Regulatory Office
Tobacco Control Directorate, Controlled Substances and Cannabis Branch
Address Locator 0301A, 150 Tunney's Pasture Driveway
Ottawa, ON K1A 0K9

Email: hc.pregs.sc@canada.ca

Statement of Conflict: We are owners of The Ecig Flavourium Inc. Specialty Vape Stores in the province of Ontario. We profit financially from helping people stop smoking through the use of Vapour Products.

We also feel a huge responsibility to ensure that Adult smokers and former smokers continue to have fair access to this product. Additionally, we do not accept Health Canada’s or the WHO (WORLD HEALTH ORGANIZATIONS) classification of us as a Tobacco Company.

We have more in common with a pharmaceutical company, and private clinics that support addiction recovery and programs including harm reduction. So, I kindly ask that my submission be reviewed and categorized as a Private Addiction Recovery Service provider and remove any stigmas attached to tobacco. We are helping people recover from addiction NOT get them hooked. 

Hello, and thank you for the opportunity to present feedback for the PROPOSED NEW REGULATIONS TO LIMIT NICOTINE IN VAPOUR PRODUCTS

My name is Maria Papaioannoy – Duic. My husband (David Duic) and I are former smokers who have chosen vapour products as our way to stop smoking; owners of The Ecig Flavourium Inc. in Ontario; and I personally lead a movement called Vapor Advocates of Ontario (VAO) and also have supported the Rights 4 Vapers movement and have spoken and written publicly about my position on The Canadian Vaping Market. This submission, therefore, comes from my position as a consumer, a retailer, and an activist/advocate for vaping. 

This is not the first time we have participated in a feedback process with Health Canada, it will not be the last. We are grateful to be able to participate.

Since my first submission for feedback on Bill S5, I have watched Health Canada evolve from a Public Health organization that holds every Canadian equal, to an organization that has allowed systemic intolerance against those addicted to smoking to seep into the process of regulating the Vaping Industry.

On December 13^th, the Right Honourable Justin Trudeau published his mandate letter to the Minister of Health. In this letter the following on vaping was addressed.

In cooperation with other orders of government and key stakeholders, address the rapid rise in youth vaping. This should start with regulations to reduce the promotion and appeal of vaping products to young people and public education to create awareness of health risks. You are encouraged to explore additional measures.

Also, in this same communication the Prime Minister said.

We are committed to evidence-based decision-making that takes into consideration the impacts of policies on all Canadians and fully defends the Canadian Charter of Rights and Freedoms.

I am not a scientist. I am not an analyst. I am a person that interacts with smokers and former smokers on a daily basis. I am the person that hears and listens to Canadians who are trying AND quitting smoking by using vaping products. All adults who have not only struggled with the addiction, but also to the shame and the feelings that their own Public Health body tells them that they should suffer to quit.

In your RIAS you stated

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.

"Dual use" is not limited to e-cigarettes. There are many studies that show high rates of continued smoking in those using the nicotine patch. Additionally, most smokers who use NRT eventually fully relapse to smoking. Ecig users have much higher successful quitting rates, the mere fact some continue to smoke while using e-cigs [and the evidence indicates harms observed in dual users are exclusively caused by their smoking] further pushes the narrative that Health Canada and our government want smokers to only quit their way.

Three studies linked below that counter your assumption.

https://pubmed.ncbi.nlm.nih.gov/27011045/
https://pubmed.ncbi.nlm.nih.gov/30197510/
https://pubmed.ncbi.nlm.nih.gov/27845734/

Dual usage is better represented by a continuum from very low cigarette consumption (say somebody reducing down to 1 or 2 cigarette a day) to poor reducers (say somebody reducing from 20 to only 10 cigarette a day). The impact on respiratory/cardiovascular health is a function of the degree of these reductions (probably not linear).

How did I find this out? I simply reached out to one of the writers of the paper. Why? Because I care about Canadians.

As I observe the moral dilemma and proposed regulations, Tobacco control regulators, activists and academics are trying hard to degrade and diminish the vaping value proposition with nicotine caps, flavour bans, large and bold warnings and mendacious fear campaigns. This type of reactive vaping legislation completely circumvents the efforts of vapers and their advocates to live smoke-free lives. These ensuing new laws will work to reduce the incentive to go from smoking to dual use, and from dual use to exclusive vaping.  It is not just relapsing to smoking, it is stopping dead the transition from dual use to vaping. The journey to becoming smoke-free is a multi step process with vaping the main component throughout. But unfortunately, as blatantly shown in the RIAS, Health Canada has decided that vaping and those who smoke do not matter.

If Health Canada didn’t financially support and sit on steering committees of events that systemically exclude the vape industry from conversations, the unit would have been able to ask questions about these issues.

As someone who interacts daily with former smokers and is at the frontline of defense to keep vapour products out of the hands of minors I can share my experiences with you from a personal perspective.

I do not believe any nicotine cap will have the intended outcome. I do think the only impact will be to discourage adult smokers from making the switch and will push many former smokers back to smoking.  

Health Canada should start engaging openly with all those involved in the vaping industry. They should stand up against the WHO directives and engage openly with all the stakeholders and stop treating companies in this market as tobacco companies. We are not in the business of tobacco. This product vaping is lifesaving. This product can reduce the number of tobacco-related illnesses.

The simplest and most effective way to combat youth access is to enforce the laws already in place.

The regulations are there. However, they are not being enforced. Access to minors is restricted already, yet not a single enforcement of this has happened via Health Canada. How about instead of trying to figure out how many more restrictions we should layer to this market, let’s enforce what we have already on the books.  According to TVPA, it is illegal to sell a vapour product to anyone under the age of 18. I don’t understand how Health Canada can further address the youth uptake when you have chosen to ignore enforcement of access.  From my perspective and from customers perspective you want us to smoke again.

I am not willing to allow Health Canada to risk the lives of smokers without concrete evidence and thoughtful consultation with all Canadians. ESPECIALLY those who smoke. I care about smokers and vapers, because I am one of them, and I hear their stories every day.

Thank you,

Maria Papaioannoy 

Owner, The Ecig Flavourium