Our submission to the Health Canada Consultation

March 14, 2019

Our submission to the Health Canada Consultation

With the deadline looming (March 22nd, 2019) we've been encouraging people to submit their comments to Health Canada with regards to curbing youth vaping. We need strong, reasonable voices to enter the conversation to hopefully curb the attraction to youth while retaining the availability of vapor products to adults. Please, if you haven't already done so, submit your own responses here.

In the spirit of transparency, this was ours:

We are writing with respect to the public Consultation- Potential measures to reduce the impact of vaping products advertising on youth and non-users of tobacco products.

 

Both my partner and I currently vape having quit smoking habits that lasted 30 years each. We both tried all means of quitting smoking (patches, gum, cold turkey, etc) but never succeeded in quitting long term until vaporizers were readily available. We’ve now both been smoke-free for several years each and are living healthy lives, free of the myriad health issues caused directly by smoking. We also run an online vape shop.

 

Vaping is more than a business or habit for us. It is a technology which has had a serious impact on our health and the health of people we know and love, including a father(in-law) with throat cancer who was able to quit a decades long habit that had the potential to kill him through vaping. His own doctor recommended vaping, recognizing the value of a technology which simulates the hand to mouth habit, delivers vapour in lieu of smoke, and creates a disconnect with the flavour of cigarettes as a reward. Over time we have both been able to decrease the level of nicotine that we vape, from 18 mg to 6 and 3 mg. Our father(in-law) has quit vaping altogether and not returned to smoking.

 

We understand the concern with youth uptake of vaping. We send out all packages with age verification required by Canada Post. We warn on our website that if you cannot prove age of majority, the package will be returned to us at a cost to the customer. All of the shops we’ve frequented were adult only and carded for age long before any regulations were in place.

 

We understand that one of the suggestions to decrease the level of youth uptake has been to restrict flavours. We strongly believe this to be wrong-headed and would have an adverse effect on adult vapers. Disconnecting the reward of nicotine with the taste of cigarettes is a powerful component of vaping. It is not unusual for early vapers to try a cigarette again and most are repulsed by the flavour and intensity having received their nicotine in berry or dessert or other flavours over a period of time. This is a good thing. While some vapers do use tobacco flavoured e-liquids, the majority do not. Personally, I never would have taken up vaping in lieu of smoking if what was on offer was a poor imitation of a habit I was already fully immersed in. And I have no desire to experience the flavour of tobacco now, having years away from it.

 

It also doesn’t make sense that flavours are what are driving young people to vape. It’s far more expensive than candies, desserts, and in some cases even candy or dessert flavoured alcohol. And I’ve yet to hear a young person suggest that they just had to get the taste of mixed berries, regardless of the risk. Nor does the fact that most alcohol and drugs taste terrible deter them from trying those. Flavours are not what is driving youth uptake but they do make a serious impact on adult smokers’ ability to quit smoking for good.

 

As to what types of advertising should be used: we strongly believe that the best anti-youth advertising would be if the government of Canada was more actively involved in stressing the advantages of vaping over smoking. Early on, there was a push by the government that we (in the vaping industry) be limited in promoting vaping as a smoking cessation aid. This forced people to discuss vaping in other terms. It also made it sound as though vaping was more exciting and dangerous than any of us adult vapers ever found it to be. It seems this is a bigger attractant to youth than any advertising the industry could have conceived. But this was conceived of and continues to be perpetuated by government.

 

Studies by reputable bodies such as the Royal College of Physicians continue to be downplayed and we (in the industry) are not allowed to discuss the considerably lower risks of vaping over smoking, lest we be accused of marketing a non-approved smoking cessation product. But what better way to make it less appealing to youth than to take the sex-appeal of something the government and adults don’t want them seeing or talking about than to talk about the very real health benefits to smokers?

 

We are hesitant to jump on the bandwagon of restricting advertisements because above our interests as a business owner, we are non-smokers who very sincerely hope that others are able to quit smoking as we did. And yet we are constantly confronted by smokers who believe vaping to be “just as dangerous” as smoking because of the lack of public information. This is a consequence of restricting advertising and of all of the public health warnings and panic generated in large part by government. We understand that it may have been well-intentioned but it is having the adverse effect, keeping smokers smoking and making vaping more appealing to young people who see it as a “dangerous” and therefore exciting past-time.

 

If restrictions must be placed though, we would suggest only restricting advertising in non-dedicated retail outlets. Don’t have billboards in 7-11s or at gas stations and keep the products behind the counter so that a person has to show identification to gain access to vaporizing products. Vape shops are already restricted to age of majority and there are no children wandering the aisles. It is worth pointing out that there are no such restrictions on other nicotine products like the prominently displayed Cool Berry Quickmist nicotine spray found in many stores, including my local pharmacy, at children’s eye level.

 

And we would highly recommend against being too heavy handed in efforts to “inform the public through a warning on advertisements”. As mentioned above, this is not having the intended effect. If a warning must be included it should be limited to, “products intended for adult smokers.” Anything else risks appealing to children while deterring smokers who could very much benefit from the products.

 

In closing, we understand the concern about children who have never smoked taking up vaping. We are equally concerned about children taking drugs of any sort. We have yet to see a public health campaign that has been able to eliminate young people doing anything completely though. We know the people in the industry to be some of the most conscientious, especially around youth uptake. Please, do not allow moral panic to overtake good sense and patience. It will be something we all look back on as having had the worst impact on harm reduction in recent years.

 

Best Regards,

 

Shane and Brandee Eubank

Alberta, Canada





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