velocitygirl
Postman
- Joined
- Dec 19, 2015
- Messages
- 187
My reply. Need tea..
Thank you for your reply. As you say, and as was stated in the House of Lords last week in the Minister's reply to questions from the Lords, the law was adopted quite some time ago. Much has changed since these regulations were passed and/or discussed. I am very familiar with the measures you outline below and absolutely agree that targeting of sales towards minors and low-quality dangerous eliquid isn't acceptable, either to regulators or vapers themselves. I don't think you have the complete picture on how these regulations will impact on those who are smokers and in the future will hopefully move to vaping or to those who vape already.
Legislation, especially that which covers such a fast moving industry as vaping, should be adaptable to provide the best outcome for the health of the nation. In this case this legislation will deter those from moving to vaping and will actually make the sale of the majority of the current tanks and liquids illegal. The majority of the 3-4 million vapers in the UK hadn't heard of vaping devices in 2015 and therefore their voices will not have been heard.
Most tanks are over 2ml capacity and most liquids of standard are bought in bottles of 15ml or more. You can purchase bleach in bottles of more than 10ml and this liquid is far, far more dangerous to the public than a bottle of 3mg eliquid.
This has been reported over and over again from many eminent sources and this 'mistake' was reported to the EU:
"overwhelming data indicating that more than 0.5 g (500mg) of oral nicotine is required to kill an adult"
http://www.ecita.org.uk/ecita-news/...ghly-toxic-it’s-less-dangerous-washing-liquid
The Department of Health England and the Royal College of Physicians have both recently published papers on how vaping is beneficial to smokers and how much less harmful this is.
Impact assessment by the DoHE: http://www.legislation.gov.uk/ukia/2016/109/pdfs/ukia_20160109_en.pdf
Royal College of Physicians report: https://www.rcplondon.ac.uk/projects/outputs/nicotine-without-smoke-tobacco-harm-reduction
The New Nicotine Alliance have also published a comprehensive response to the DoHE outlining the many ‘unintended’ consequences of this legislation:
https://docs.google.com/document/d/...qyr_AzQenWCcYBKzF-bzk/pub?embedded=true#ftnt1
The main points that concern vapers worldwide are (although I encourage you to read all the above as they are a comprehensive analysis of the far-reaching implications of this legislation):
Loss of product diversity: the rise of vaping over the last few years has been greatly helped by the consumer-driven developments to enable vapers to gain a better experience and to provide the different types of equipment for all levels of vaping experience. This also keeps people interested in the industry and from smoking!
Restrictions on liquid strength: some smokers find it incredibly difficult to stop smoking even when vaping 20mg/ml which will be the new limit. Nicotine is relatively safe even up to 56mg so why restrict sales when there is a minority of those who wish to still purchase this?
Limits on container and tank size: This part of the legislation is the most irrational and onerous of all. To limit tanks sizes to 2ml capacity and bottles of liquid to 10ml will have the most impact, rendering a high percentage of all equipment and sales illegal, not to mention the plastic waste this will create. Most vapers can easily use 20ml of liquid a day, especially if you have, like me, managed to lower your nicotine intake down to the lowest available. The increase in of empty 10ml plastic bottles will have a significant environmental impact. To limit tanks to 2ml seems utterly ridiculous and the only explanation for this is that the only ‘compliant’ 2ml capacity devices are made by big tobacco companies in the form of the old-fashioned ‘cigalikes’. Most of the tanks manufactured today are over 2ml.
Restrictions on advertising, promotion and sponsorship: most vapers completely understand that advertising and promotion where children may encounter them is not acceptable, the knock-on effect of banning promotion and sponsorship will close down most of the online support forums we have available to us. These forums help smokers who are trying to find their way to vaping, allows crowd-sourced monitoring of any equipment issues especially reporting safety problems much quicker than any trading standards department could and warns other users of unsafe juices or additives, eg the use of diacetyl in liquids was spotted and rejected by users long before it hit the ‘headlines’. Consumers forced companies to publish their safety/testing sheets.
Policy compliance burdens and other costs - leading to black markets: as Clive Bates and many other have already pointed out (http://www.clivebates.com/?p=4017), this will lead to a black market developing and safety will be the last thing to be taken into consideration. Vapers want safe, clean juice and if the small-medium UK manufacturers can no longer afford the process of regulation that has been put into place, not only with safety suffer but there will be an estimated loss of 50,000 jobs in the UK.
Bans on online sales: Sadly some UK companies have already started closing down operations due to the inability to be able to sell to other countries in the EU. Luckily the UK Government has not banned online sales (Austria) but many other countries in the EU have and even if they haven’t each company has to register individually with each country which obviously has a huge resource overhead.
Raise taxes on vaping liquid/equipment: if this is purely to recoup taxes lost from tobacco sales then this is no way to encourage smokers to stop. Most of the ingredients in liquid are food-based so anything above this norm would be inappropriate and stop smokers moving over to vaping especially if there’s no financial incentive.
What will you be doing to address the possible loss of many many jobs in the Welsh vaping industry and how will this legislation be modified in view of recent findings by DoHE and the RCP. Will there be an impact assessment done when the TPD kicks in proper in November of 2016?
Thank you for your reply. As you say, and as was stated in the House of Lords last week in the Minister's reply to questions from the Lords, the law was adopted quite some time ago. Much has changed since these regulations were passed and/or discussed. I am very familiar with the measures you outline below and absolutely agree that targeting of sales towards minors and low-quality dangerous eliquid isn't acceptable, either to regulators or vapers themselves. I don't think you have the complete picture on how these regulations will impact on those who are smokers and in the future will hopefully move to vaping or to those who vape already.
Legislation, especially that which covers such a fast moving industry as vaping, should be adaptable to provide the best outcome for the health of the nation. In this case this legislation will deter those from moving to vaping and will actually make the sale of the majority of the current tanks and liquids illegal. The majority of the 3-4 million vapers in the UK hadn't heard of vaping devices in 2015 and therefore their voices will not have been heard.
Most tanks are over 2ml capacity and most liquids of standard are bought in bottles of 15ml or more. You can purchase bleach in bottles of more than 10ml and this liquid is far, far more dangerous to the public than a bottle of 3mg eliquid.
This has been reported over and over again from many eminent sources and this 'mistake' was reported to the EU:
"overwhelming data indicating that more than 0.5 g (500mg) of oral nicotine is required to kill an adult"
http://www.ecita.org.uk/ecita-news/...ghly-toxic-it’s-less-dangerous-washing-liquid
The Department of Health England and the Royal College of Physicians have both recently published papers on how vaping is beneficial to smokers and how much less harmful this is.
Impact assessment by the DoHE: http://www.legislation.gov.uk/ukia/2016/109/pdfs/ukia_20160109_en.pdf
Royal College of Physicians report: https://www.rcplondon.ac.uk/projects/outputs/nicotine-without-smoke-tobacco-harm-reduction
The New Nicotine Alliance have also published a comprehensive response to the DoHE outlining the many ‘unintended’ consequences of this legislation:
https://docs.google.com/document/d/...qyr_AzQenWCcYBKzF-bzk/pub?embedded=true#ftnt1
The main points that concern vapers worldwide are (although I encourage you to read all the above as they are a comprehensive analysis of the far-reaching implications of this legislation):
Loss of product diversity: the rise of vaping over the last few years has been greatly helped by the consumer-driven developments to enable vapers to gain a better experience and to provide the different types of equipment for all levels of vaping experience. This also keeps people interested in the industry and from smoking!
Restrictions on liquid strength: some smokers find it incredibly difficult to stop smoking even when vaping 20mg/ml which will be the new limit. Nicotine is relatively safe even up to 56mg so why restrict sales when there is a minority of those who wish to still purchase this?
Limits on container and tank size: This part of the legislation is the most irrational and onerous of all. To limit tanks sizes to 2ml capacity and bottles of liquid to 10ml will have the most impact, rendering a high percentage of all equipment and sales illegal, not to mention the plastic waste this will create. Most vapers can easily use 20ml of liquid a day, especially if you have, like me, managed to lower your nicotine intake down to the lowest available. The increase in of empty 10ml plastic bottles will have a significant environmental impact. To limit tanks to 2ml seems utterly ridiculous and the only explanation for this is that the only ‘compliant’ 2ml capacity devices are made by big tobacco companies in the form of the old-fashioned ‘cigalikes’. Most of the tanks manufactured today are over 2ml.
Restrictions on advertising, promotion and sponsorship: most vapers completely understand that advertising and promotion where children may encounter them is not acceptable, the knock-on effect of banning promotion and sponsorship will close down most of the online support forums we have available to us. These forums help smokers who are trying to find their way to vaping, allows crowd-sourced monitoring of any equipment issues especially reporting safety problems much quicker than any trading standards department could and warns other users of unsafe juices or additives, eg the use of diacetyl in liquids was spotted and rejected by users long before it hit the ‘headlines’. Consumers forced companies to publish their safety/testing sheets.
Policy compliance burdens and other costs - leading to black markets: as Clive Bates and many other have already pointed out (http://www.clivebates.com/?p=4017), this will lead to a black market developing and safety will be the last thing to be taken into consideration. Vapers want safe, clean juice and if the small-medium UK manufacturers can no longer afford the process of regulation that has been put into place, not only with safety suffer but there will be an estimated loss of 50,000 jobs in the UK.
Bans on online sales: Sadly some UK companies have already started closing down operations due to the inability to be able to sell to other countries in the EU. Luckily the UK Government has not banned online sales (Austria) but many other countries in the EU have and even if they haven’t each company has to register individually with each country which obviously has a huge resource overhead.
Raise taxes on vaping liquid/equipment: if this is purely to recoup taxes lost from tobacco sales then this is no way to encourage smokers to stop. Most of the ingredients in liquid are food-based so anything above this norm would be inappropriate and stop smokers moving over to vaping especially if there’s no financial incentive.
What will you be doing to address the possible loss of many many jobs in the Welsh vaping industry and how will this legislation be modified in view of recent findings by DoHE and the RCP. Will there be an impact assessment done when the TPD kicks in proper in November of 2016?
