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December 13, 2019
Dear Minister Hajdu,
First, let me congratulate you on your new cabinet appointment. I am familiar with your previous work and was very pleased to hear of your appointment to Health Minister. I wish you all the best in your important role.
I am writing to you today with regards to your mandate on vaping. While I am in complete agreement with the role of public education, I am concerned with the wording to, “start with regulations to reduce the promotion and appeal of vaping products to young people.” We currently have regulations prohibiting the sale of nicotine e-cigarette products to youth, as well as prohibiting marketing to young people. We have, in fact, a long list of regulations in place already with more (including some that would severely impact the sale of vaping technology under the current wording, such as the sale of open systems) under consideration.
I understand the concern about youth uptake of e-cigarettes. I own and operate a vape shop myself, together with my husband, a business we began after having quit smoking ourselves through vaping. Prior to government involvement, the industry self-regulated, prohibiting the sale of products to minors and working directly with ex-smokers to help them make the switch with the appropriate devices and e-liquids. Now that government has regulated the industry, we can no longer market the products as a cessation tool or replacement therapy but that is still primarily what it is being sold and used for.
I was very glad to see the government’s statement in 2018 that, “The Tobacco and Vaping Products Act… makes it legal for adults to buy vaping products that contain nicotine, as a less harmful option than smoking. This is part of our broad new vision for dealing with tobacco use.” (Use of italics, mine.) It seemed our Liberal government understood and indeed shared our vision and hope for this most disruptive technology. Which makes sense for a government that likes to remind us that it relies so heavily on science and evidence-based decision-making.
Since then, the evidence has not changed- adult smokers continue to use vaping to transition from smoking at rates not seen with other nicotine replacement therapies. This is a very promising sign, given the 45,000 Canadians that die every year from a tobacco-related disease and nearly 5,000,000 smokers in Canada. I hope, with news that youth are experimenting with the product (largely obtained through social sources, by Health Canada’s own reporting), will not distract us from this important fact.
I also hope that you as our Minister, and our government as a whole, will recognize that education is the most important and effective tool we have in working with teenagers. Abstinence only and fear-based campaigns have been ineffective with youth, and age restrictions (though I support them) have had limited effect. We need only look to the statistic that 44% of youth in Canada engage in underage drinking for evidence of that, or that 17% report using cannabis.
As you are well aware, there are a myriad of reasons why young people engage in risk-taking behaviours. Our Chief Public Health Officer of Canada, Dr. Thersa Tam, acknowledges those complexities in her 2018 report. Most often, experimentation is nothing more than that, including with substances that have the potential to be addictive. But young people should be provided with all of the information at our disposal and encouraged to make healthy and informed decisions. We understand this about sex education, though it took us many years to accept that teaching children about the serious topics of STDs and teen pregnancy and consent was a better route than teaching abstinence only and hoping for the best. We are still behind on teaching them about drug and substance use and abuse and providing them with social and mental health supports.
I was encouraged to see that the Drug Policy Alliance in the United States launched Safety First: Real Drug Education for Teens, a curriculum that provides teachers and their students with the information and tools to have real conversations about drugs and their inherent risks. It includes, among other topics, a comprehensive lesson on vaping and e-cigarettes. I share DPA’s belief that providing young people with both education and social resources remains the best and most effective tool at our disposal. I hope that one day, Canada follows suit as our young people are no less at risk and from far greater dangers than e-cigarettes. As someone who works in the (nicotine) vaping industry, I am frequently asked what I recommend to reduce youth uptake and my number one recommendation is always education and accurate information.
That is one of the reasons it has been so dismaying in the previous months to see both media and public health officials conflating the issue of lung injuries sustained from vaping black market THC products (more specifically related to vitamin E acetate used an additive in these products) and vaping nicotine e-cigarettes. This is completely irresponsible reporting and has had the effect of a) allowing a segment of the population to continue to be at risk by not providing them accurate information and b) turning smokers away from a less harmful alternative and turning the public against it, based on misinformation. Some nicotine vapers have even reported returning to smoking, feeling it to be a less imminent risk.
As Ian Irvine recently wrote for the C.D. Howe Institute, “The unfortunate consequences of these events is that health authorities are advising the community at large to steer clear of vaping, at a time when it has the potential to reduce harm. This comes on top of provincial laws that treat e-cigarettes as if they are as dangerous as conventional cigarettes.”
More disappointing has been the federal government’s reticence to correct the record and issue the appropriate health warnings. While vaping THC products was only legalized in Canada in November of this year, it is naive to operate under the belief that Canadians weren’t already accessing THC cartridges. In fact, as all of those products were sold under the black/grey market prior to November, it would be reasonable to assume that consumers would be at grave risk without the appropriate health warnings. Instead, it was left to individual citizens to spread the word among friends and family. As the nicotine vape industry was paying such close attention to this issue from the start, many of us took up the cause to spread news of the serious risk of contaminated THC cartridges. Contrary to what may be popular belief, we have an utmost interest in protecting the public health, and have since our inception.
Risk analysis is complicated and I understand the public’s (and government’s) concern with the youth uptake of nicotine products. But it must be weighed against the harm caused by smoking. The precautionary principle applied too heavily handed here may result in the deaths of smokers that were entirely preventable. This is why so many vaping advocates see this as such an emotionally charged issue, because it is- the stakes are very high. It is made even more personal by the fact that many in the industry are former smokers themselves. The cost of getting this file wrong is profound, which makes the reactionary and overreaching provincial restrictions of recent weeks all the more disturbing.
I do hope with your appointment as Health Minister that we can expect a reasoned conversation and science and evidence-based decision making on the nicotine vaping file. I have watched the conversation around vaping devolve over the years. It has gone from an exciting ground-breaking technology with the potential to have a serious impact on smoking rates (which it still does, with even more advancements now) to a moral discussion with puritanical leanings and a prohibitionist bent. It is currently a conversation with little social value. Prohibition has caused more problems than it has solved, as has overregulation.
As a result of the last several months of news reporting, the nicotine vaping industry will have a steep hill to climb to reestablish trust with the public and most importantly with smokers. But that is largely owing to misinformation circulated by the media and their constant use of young people vaping in the promotion of their stories. My hope is that while it will be an uphill battle, this Liberal government will support us in our efforts to continue to provide an off-ramp for smokers looking to make the transition from combustible tobacco.
I would very much appreciate hearing back from you, or from your office, on this issue. I look forward to a more extended conversation on this topic and will be of any assistance that I can. Again, congratulations on your post and best wishes for a successful term.
I have attached two links, one to Ian Irvine article referenced above and one to an article in Filter magazine entitled Can Harm Reduction Finally take root in America’s schools that is relevant to our discussion.
The Vilification of Vaping CD Howe Institute
Can Harm Reduction Finally take root in American schools? Filter Magazine
March 30, 2020
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