E-cigarette submissions 181-210

Consultation submission 181 - Individual

Your details

This submission was completed by:(name)

[redacted]

Address:(street/box number)

[redacted]

(town/city)

[redacted]

Email:

[redacted]

Organisation (if applicable):

Position (if applicable):

(Tick one box only in this section)

Are you submitting this:

as an individual or individuals (not on behalf of an organisation)?

|_|on behalf of a group, organisation(s) or business?

(You may tick more than one box in this section)

Please indicate which sector(s) your submission represents:

Commercial interests, including ecigarette manufacturer, importer, distributor and/or retailer

|_|Tobacco control non-government organisation

|_|Academic/research

Cessation support service provider

|_|Health professional

|_|Mori provider

|_|Pacific provider

|_|Other sector(s) (please specify):

(You may tick more than one box in this section)

Please indicate your ecigarette use status:

|_|I am using nicotine ecigarettes.

|_|I am using nicotine-free ecigarettes.

|_|I currently smoke as well as use ecigarettes.

I am not an ecigarette user.

|_|I have tried ecigarettes.

Privacy

We intend to publish all submissions on the Ministrys website. If you are submitting as an individual, we will automatically remove your personal details and any identifiable information.

If you do not want your submission published on the Ministrys website, please tick this box:

|_|Do not publish this submission.

Your submission will be subject to requests made under the Official Information Act. If you want your personal details removed from your submission, please tick this box:

|_|Remove my personal details from responses to Official Information Act requests.

If your submission contains commercially sensitive information, please tick this box:

|_|This submission contains commercially sensitive information.

Declaration of tobacco industry links or vested interest

As a party to the global tobacco control treaty, the World Health Organization Framework Convention on Tobacco Control, New Zealand has an obligation to protect the development of public health policy from the vested interests of the tobacco industry. To help meet this obligation, the Ministry of Health asks all respondents to disclose whether they have any direct or indirect links to, or receive funding from, the tobacco industry. The Ministry will still carefully consider responses from the tobacco industry, and from respondents with links to the tobacco industry, alongside all other submissions. Please provide details of any tobacco company links or vested interests below.

[redacted]

Please return this form by email to:

ecigarettes@moh.govt.nz by 5 pm, Monday 12 September 2016.

If you are sending your submission in PDF format, please also send us the Word document.

Consultation questions

Although this form provides blank spaces for your answers to questions, there is no limit to the length of your responses; you should take as much space as you need to answer or comment. Feel free to enlarge the boxes or attach additional pages.

Q1Do you agree that the sale and supply of nicotine ecigarettes and nicotine liquids should be allowed on the local market, with appropriate controls?

Yes No |_|

Reasons/additional comments:

E-cigarettes should be allowed to be sold in NZ. They should be regulated and taxed for DEPENDENCE (regular usage) or regulated, not taxed and subsidised for WITHDRAWAL.

There are three broad stages in nicotine use. INITIATION, DEPENDENCE (regular usage) and WITHDRAWAL. This cycle ofter repeats after a period of abstinance.

Major health risks accumulate due to regular use of combustible tobacco products to satisfy nicotine dependence.

E-cigarettes appear to reduce these health risks by providing a less harmful supply of nicotine to satisfy dependence. Therefore there appears to be direct health benefits for smokers who INITIATE and use E-cigarettes for regularly (long term) and exclusively. This behaviour change should be encouraged and is aligned with the goal of a SmokeFree NZ albeit not a nicotine free NZ.

Evidence suggests current generation e-cigarettes are less addictive than cigarettes. At least as measured by speed of nicotine delivery to the bloodstream. The trend is for speed of delivery to increase with each generation of e-cigarettes. Therefore in time e-cigarettes will reach parity and ultimately exceed the speed of nicotine delivery for tobacco cigarettes. Thus increasing propensity for addiction.

Simply put E-cigarettes could replace tobacco cigarettes as the most efficient nicotine delivery devices and exposing users to lowered health risks.

A market thus created would be lucrative with dependent vapers a captive market for exploitation by commercial interests. These interests would have no incentive to encourage withdrawal by individuals as this would depress future sales. Tobacco companies are well placed to command the majority of this market as the dynamics closely resemble the existing tobacco consumer market place.

Therefore whether e-cigarettes are allowed or not, the issue of how to help nicotine dependent individuals withdraw successfully remains. In fact it may prove more difficult to persuade vapers to withdraw as the health risks, costs and social stigma reduce over time. In addition medicinal and behavioral support for withdrawal is likely to recede in the face of the commerical reality of competing with the lucrative sales of e-cigarettes.

To ensure New Zealanders have proven, safe and effective means to withdraw from nicotine DEPENDENCE it is essential that regulation differentiates between non combustable nicotine products that are designed and promoted for WITHDRAWAL and those designed for DEPENDENCE.

I propose that nicotine products for WITHDRAWAL be licensed as medical devices or medicines.

Such a license would be granted for general sale after presentation of appropriate supporting data to Medsafe. Products thus licensed would automatically qualify for PHARMAC funding. These products would also be exempt from any excise duty or other taxes to differentiate from and make them less costly than DEPENDENCE e-cigarettes.

Conversly E-Cigarettes designed to perpetuate DEPENDENCE would only require registration with proof of quality, contents, appropriate electrical standards etc. These products should be taxed to cover the risk to the public purse of likely health risks of long term usage ( ie lower than cigarettes, but linked to the propensity for addiction) and ensure the retail price is significantly higher than products registered for WITHDRAWAL.

I believe by acknowledging and differentiating the end use of E-Cigarettes as described above will provide commercial incentives to market viable WITHDRAWAL systems to individuals while encouraging the population harm reduction potential of e-cigarettes as replacements for tobacco cigarettes. Little or no taxpayers money would be required over and above existing expenditures for such initiatives.

NZ SmokeFree would be more attainable with an ultimate aim of reducing Nicotine consumption as an achieveable secondary goal.

Q2Are there other (existing or potential) nicotine-delivery products that should be included in these controls at the same time? If so, what are they?

Yes No |_|

Reasons/additional comments:

Products such as NicoNovum synthetic snus and NicoVentures MHRA approved Nicotine vapor device are examples of other nicotine delivery devices or systems that currently exist and should be accounted for. Novel technologies as they present should be determined as belonging to one class or the other.

Q3Do you think it is important for legislation to prohibit the sale and supply of ecigarettes to young people under 18 years of age in the same way as it prohibits the sale and supply of smoked tobacco products to young people?

Yes No |_|

Reasons/additional comments:

Prohibiting sales to those under 18 is a sensible approach. Although evidence shows such bans have little effect on initiation of smoking by teens never the less it does no harm. However as E-cigarettes are ultimately to be marketed by Tobacco companies aligning age restrictions is appropriate.

Q4Do you think it is important for legislation to control advertising of ecigarettes in the same way as it controls advertising of smoked tobacco products?

Yes No |_|

Reasons/additional comments:

Again, differentiating between end use i.e. WITHDRAWAL or DEPENDENCE is important. E-Cigarettes marketed to perpetuate DEPENDENCE should have the same controls as tobacco. Those licensed for WITHDRAWAL should fall under Medicines regulations.

Q5Do you think it is important for the SFEA to prohibit vaping in designated smokefree areas in the same way as it prohibits smoking in such areas?

YesNo |_|

Reasons/additional comments:

E-Cigarettes marketed to perpetuate DEPENDENCE should have the same controls as tobacco.

Q6Do you agree that other controls in the SFEA for smoked tobacco products should apply to ecigarettes? For example:

Control

Yes

No

Reasons/ additional comments

Requirement for graphic health warnings

|_|

E-Cigarettes marketed to perpetuate DEPENDENCE should warn of health consequences including addiction.

Prohibition on displaying products in sales outle