Despite a shared culture and heritage, the U.K. and the U.S. find themselves at polar opposites of the spectrum in their attitudes toward vaping.
By Maria Verven
While there are more vapers in the U.S. than there are in the U.K., vaping is more prevalent in the U.K. when calculated as a percentage of the overall population.
The reason? In the U.K., vaping is far less stigmatized socially, and it has been heartily endorsed by key public health organizations for “preventing almost all the harm from smoking.”
Let’s find out the other reasons why these two countries are worlds apart.
THE U.K.: ACKNOWLEDGING WHERE E-CIGARETTES ARE ON THE RISK CONTINUUM
While the U.K. has imposed very strict regulations on e-cigarettes and e-liquids, key organizations including Public Health England (PHE) and the Royal College of Physicians (RCP) agree that vaping is far less harmful than smoking traditional tobacco products.
The EU Tobacco Products Directive (TPD) provides the framework and regulations for all e-cigarettes and e-liquids containing nicotine. The TPD’s regulations outline minimum standards of safety and quality for anyone who manufactures, imports, or rebrands e-cigarettes and e-liquids.
Among the guidelines are limits on the capacity of vapor tanks and e-liquid bottle sizes as well as restrictions on certain ingredients and coloring agents. There is a six-month approval period for new e-liquids and hardware. The TPD also regulates the allowable level of nicotine, so portable vapor devices such as the Juul that contained higher nicotine levels were not allowed (Juul Labs recently developed reduced-nicotine pods that meet the guidelines).
Consumers and healthcare professionals can report adverse events and safety concerns to the U.K.’s Medicine and Healthcare products Regulatory Agency (MHRA) through a “Yellow Card” reporting system.
But compared with the U.S., the U.K. sees much less disruption, thanks in part to the huge increase in e-cigarette use and a regulatory environment that appears to be informed on how e-cigarettes factor into the risk continuum. In fact, e-cigarette campaigners have even been assured by the Department of Health and Social Care and the designated approval agency that they will turn a blind eye toward any advertising promoting vaping as a safer alternative.
MEANWHILE IN THE U.S.: BANS AND INCREASING RESTRICTIONS
The Tobacco Control Act gave the U.S. Food and Drug Administration (FDA) authority over all tobacco products, and in May 2016, the FDA extended this authority over all electronic nicotine-delivery systems (ENDS), including e-cigarettes and vape pens.
Manufacturers and importers selling vapor products and e-liquids made on or before Aug. 8, 2016, were required to submit a list of all ingredients to the FDA by November 2017; small-scale tobacco product manufacturers were given another six months.
Submission of premarket tobacco product applications (PMTAs) for all noncombustible products, including e-cigarettes, is due on or before Aug. 8, 2022, when manufacturers must demonstrate that marketing the new tobacco products “would be appropriate to protect public health.” The FDA claims it will consider the risks and benefits to both users and nonusers when reviewing each product’s components, ingredients, additives and health risks in addition to how the product is manufactured, packaged and labeled.
Ironically, the FDA’s deeming regulations don’t impose the same types of specific manufacturing guidelines as the TPD. They don’t outright prohibit any particular ingredients, set maximum nicotine levels or even require the use of child-resistant packaging. Since many e-liquid manufacturers also sell across the pond, they have been engineering their products and packaging to comply with the TPD’s guidelines. In fact, many bolstered their quality-assurance measures by implementing good manufacturing practices (GMPs) and building ISO 7 state-of-the-art cleanrooms in an effort to build public confidence and to stay one step ahead of potential FDA requirements.
Despite this, many U.S. legislators continue to express concerns about e-cigarettes and who’s using them—particularly teens—siding with the popular stance that these products are “bad.” Coupled with a huge increase in the popularity of vapor devices such as the Juul, regulators and legislators have tried to outdo each other by proposing even more forceful actions to “stem this dangerous trend, including revisiting our policy that extended the compliance dates for e-cigarette manufacturers, including flavored e-cigarettes, to submit applications for premarket authorization,” according to FDA Commissioner Scott Gottlieb.
So it came as no surprise when in November 2018 the FDA announced new restrictions on the sales of flavored e-cigarettes, except those flavored with menthol and mint. They have yet to specify a timeline for implementing the new proposal, which also requires stores to have secure areas that are restricted to adults over the age of 18. Ironically, this keeps e-cigarettes off the shelves of most convenience stores and gas stations, where traditional cigarettes continue to be sold. They also proposed new age-verification standards for online retailers selling e-cigarettes.
THE U.K.: ENDORSEMENT BY THE HEALTH COMMUNITY
London’s Royal College of Physicians (RCP) not only endorsed the use of e-cigarettes as smoking cessation aids; it also concluded that e-cigarettes can “prevent almost all the harm from smoking.”
“Large-scale substitution of e-cigarettes for tobacco smoking has the potential to prevent almost all the harm from smoking in society,” the RCP states. “Promoting e-cigarettes and other nontobacco nicotine products as widely as possible as a substitute for smoking is therefore likely to generate significant health gains in the U.K.”
In fact, in the U.K., the health community is launching a new campaign to convince smokers that vaping is not only less harmful than smoking combustible cigarettes; it’s also a good way to quit. In one short video, an experiment was conducted to collect the sticky black tar that accumulates in the lungs of a heavy smoker in a jar, while showing that vaping the same amount of nicotine collects only a trace of residue.
And last year, PHE, the world’s oldest public health commission, even recommended that e-cigarettes be made available by prescription because of how successful they were in helping thousands of U.K. citizens quit smoking. PHE even recommended that the devices be made available for purchase in U.K. hospitals.
PHE says that although e-cigarette use did rise among young people in England, the numbers have flattened off since 2015. “There are no studies that show vaping increases tobacco use among young people in the U.K.,” said Martin Dockrell, head of the tobacco control program at PHE.
PHE says that e-cigarettes could help many more people quit smoking. Data from its smoking cessation program showed that 65 percent to 68 percent of people who used e-cigarettes as well as nicotine-replacement therapies succeeded in quitting.
“It would be tragic if thousands of smokers who could quit with the help of an e-cigarette are being put off due to false fears about safety,” said John Newton, PHE’s director of health improvement. “We need to reassure smokers that switching to an e-cigarette would be much less harmful than smoking.”
MEANWHILE IN THE U.S.: FEARMONGERING PERSISTS
Despite all of the e-cigarette studies that have been conducted, including the Drexel University study that concluded, “It’s about as harmless as you can get,” the U.S. public health community continues to fuel concern and controversy.
Myths persist around what’s in e-liquids, despite the rigorous testing and numerous studies that have been conducted not just on e-liquids but also the resulting vapor that is produced. Undocumented, unsubstantiated reports of diacetyl, formaldehyde and other aldehydes stoke fear and spread the gross misperception that e-cigarettes are as harmful as traditional combustible cigarettes.
Follow the money, and you’ll find that health organizations receive millions of dollars from pharmaceutical companies. So it’s no surprise that they demonized vaping and lobbied for bans, according to Bill Godshall, the founder and executive director of Smokefree Pennsylvania and a passionate advocate of vaping.
“If you want to keep money flowing in from Big Pharma, you’ll keep hawking their products. That’s not public health information,” Godshall said.
But by far the greatest hurdle to the industry is the FDA, according to Godshall, Gregory Conley of the American Vaping Association and other vaping advocates. Recent moves by the FDA to restrict or ban the sale of flavored nicotine pods will only serve to make it harder for adult smokers to switch to a far less harmful alternative, Conley said.
“For many smokers, it will be much easier to pick up a pack of Marlboros or Camels—or even an unrestricted cherry-flavored cigar at a local convenience store—than it will be to make the switch to a vaping product that truly helps him or her break their desire for cigarettes,” said Conley.
“Cigarette smokers have a human right to truthful health information and legal access to less hazardous alternatives,” Godshall said. “The FDA and public health agencies have an ethical duty to inform smokers that e-cigarettes are far less hazardous alternatives to cigarettes and to keep these alternatives on the market as long as highly addictive, lethal cigarettes remain legal.”
In summary, the burdens being imposed on the U.S. vapor community by federal, state and local legislators raise serious ethical questions. Taken altogether, the bans and restrictions on vaping, scare tactics and misinformation campaigns, as well as egregiously high taxes on vapor products can potentially doom millions of people—particularly those crippled by poverty and mental illness—to a lifetime of smoking.
All Americans have to do is look across the ocean to see how another country is providing the facts and endorsing a product that could save millions of lives.
