18 Oct 2016:

As a consumer group, Malaysian Organisation of Vape Entities (MOVE) has been and will continue to defend the rights of consumers to vape.

Our position on the right to vape is corroborated by various independent studies by medical professionals and scientific bodies that have accepted that e-cigarettes may serve as a viable substitute for smoking cigarettes, thereby significantly reducing or eliminating exposure to harmful elements in cigarette smoke.

However, vested interests and negative misinformation has unfortunately attracted a lot of fallacy and fact-less allegations.

In this regard, we refer to a letter endorsed by more than 50 top specialists from around the world, sent to the World Health Organisation (WHO) which states that:

i. ”Tobacco harm reduction is strongly consistent with good public health policy and practice and it would be unethical and harmful to inhibit the option to switch to tobacco harm reduction products”;

ii. “WHO and national governments should take a dispassionate view of scientific arguments and not accept or promote flawed media or activists’ misrepresentation of data”; and

iii. Allowing adult smokers to have access to less harmful consumer products could save hundreds of millions of lives: “The potential for tobacco harm reduction products to reduce the burden of smoking related disease is very large, and these products could be among the most significant health innovations of the 21st century – perhaps saving hundreds of millions of lives. The urge to control and suppress them should be resisted and instead regulation that is fit for purpose and designed to realise the potential should be championed.”

It is also extremely important and relevant to make reference to a recent WHO report on e-cigarettes published in August 2016 (FCTC/COP/7/11) in which WHO states: “If the great majority of tobacco smokers who are unable or unwilling to quit would switch without delay to using an alternative source of nicotine with lower health risks, and eventually stop using it, this would represent a significant contemporary public health achievement.”

MOVE would like put across the recent facts on e-cigarettes by citing the findings of independent scientific studies and evidence such as: • “E-cigarettes: a new foundation for evidence-based policy and practice” by Public Health England, a UK Government health agency • “Use of electronic cigarettes (vaporisers) among adults in Great Britain” by ASH-UK, a UK-based anti-tobacco non-governmental organisation • “Study of adult vapers and e-cigarette usage in Malaysia” by Dr Konstantinos Farsalinos, a world-renowned cardiologist and e-cigarette expert

We appeal to the Government to refer to these scientific studies and evidence to make sensible and informed decisions.

In order to bring clarity to the debate, we are highlighting 10 facts on e-cigarette and e-liquid with nicotine:

FACT 1 – Right to have [95%] less harmful product

Public Health England has reported that e-cigarettes carry a fraction of the risk of cigarettes and estimate them to be 95% safer than conventional cigarettes.

This report also mentions that e-cigarettes release negligible levels of nicotine into ambient air with no identified health risks to bystanders.

Subsequently, the UK Royal College of Physicians also had similar findings in their report published in April 2016.

Currently, there are a large number of independent studies conducted by medical professionals reaffirming that e-cigarettes have a fraction of the risk when compared to smoking cigarettes to the user.

E-cigarettes also protect others from harmful effects of second hand cigarette smoke. Smokers and vapers who are the rakyat therefore have a right to be able to benefit from this less harmful alternative.

FACT 2 – E-cigarette and e-liquid are not pharmaceutical products

By all means, we strongly believe that the manufacture and sale of e-cigarettes needs to be sensibly regulated.

In August last year, we garnered the support of almost 50,000 consumers to regulate e-cigarettes through our online petition.

MOVE also welcomes the wise and prudent decision made by our Government to regulate e-cigarettes as a response to consumer demand.

We hope that our Government will continue to uphold this decision and position in the upcoming WHO’s seventh session of the Conference of Parties (COP7) in November.

While we support the need to regulate e-cigarettes, we also believe that the aggressive push to regulate liquids containing nicotine as pharmaceutical products is ill-conceived and excessive.

E-cigarettes are not a pharmaceutical product.

It is almost as ridiculous as claiming that shampoo is a consumer product but where it contains papaya or tea-tree extracts it will be treated as a food product, and as absurd as saying that any form of artificial sweeteners used by diabetic patients should be treated as a pharmaceutical product.

Regulating e-cigarettes as pharmaceutical products would have the same effect as a ban on the category – since it would require that:

  • they be manufactured in pharmaceutical manufacturing facilities,
  • be supported by pharmaceutical clinical trials proving safety and efficacy,
  • be sold in pharmacies, be packaged labelled and
  • communicated as medicines, and perhaps even be sold only by prescription.

As global tobacco policy expert and former director of UK-based anti-tobacco NGO ASH-UK Clive Bates, noted “A limited authorised range of dull but perfectly safe medicalised products that no-one wants to use is worthless and counterproductive.”

FACT 3 – No one is taking nicotine only

While nicotine is a controlled substance regulated by the Ministry of Health, e-cigarette users are not buying or using liquid nicotine on its own. This is the biggest confusion and misconception.

Generally nicotine constitutes only a small percentage of e-liquid amongst other ingredients.

In practice, in a properly regulated environment, e-liquids can be appropriately regulated akin to a consumer product, by defining the limits of nicotine content, mandating proper manufacturing and labeling standards and requiring child-resistant packaging.

Public Health England reported that e-cigarettes when used as intended, pose no risk of nicotine poisoning to users. Nicotine poisoning only occurs when substantial quantities of liquid nicotine is ingested.

Interestingly, studies and surveys show that the leading cause of poisoning in children is from household and personal care products. For example, a number of household products such as bleach and cleaning liquids can cause poisoning if swallowed.

If the direction is for products to be regulated under the Poison Act based on accidental poisoning from ingestion, then following this logic, all products or substances that have the potential to be drunk or eaten in error will need to be regulated under the Poison Act.

As discussed below, leading regulators have established feasible, workable maximum limits on the quantity and/or concentration of nicotine in liquid solutions sold for e-cigarettes. We would support such an approach in Malaysia.

FACT 4 – Nicotine does not cause smoking related disease

While nicotine is an addictive substance, currently, there is broad agreement among medical experts and the public health community that it is NOT the cause of smoking-related disease.

Instead, it is the highly harmful constituents of cigarette smoke that are generated by burning a cigarette.

As Professor Robert West, professor of health psychology and director of tobacco studies at University College London’s department of epidemiology and public health explained: “E-cigarettes are about as safe as you can get…Nicotine is not what kills you when you smoke tobacco.

“E-cigarettes are probably about as safe as drinking coffee. All they contain is water vapour, nicotine and propylene glycol [which is used to help vaporise the liquid nicotine].”

FACT 5 – E-cigarette is a better and less harmful alternative to smoking cigarettes

Since people continue to smoke cigarettes because they wish to use nicotine, nicotine abstinence made a lot of sense in the past, when the only method to dispense nicotine was through smoking.

However, today, with e-cigarettes, we have a better and less harmful alternative to dispense nicotine while potentially eliminating the threat of diseases associated with the harmful chemicals generated by lighting a cigarette.

In conclusion, with the presence of e-cigarettes, is asking for complete nicotine abstinence justified? NO!

FACT 6 – Malaysia has become another victim of Big Pharma and NRT’s failure

It is a fact that Big Pharma has been exposed in UK for lobbying to stunt the growth of e-cigarettes due to vested interests.

This is very obvious because they stand to lose substantial market share for their ineffective and failed nicotine replacement therapy (NRT) business when smokers are choosing e-cigarettes as their preferred cessation tool.

This fact is reported by ASH-UK in a survey which shows that smokers in UK find e-cigarettes much more effective to reduce or stop smoking when compared to other NRT products.

This is a classic case of Big Pharma attempting to protect their failed smoking cessation product line AND depriving smokers of a potentially less harmful and more effective alternative.

The corrupt lobbying attempts of Big Pharma trying to shut down the e-cigarette industry and jeopardising a billion lives, are exposed in the recent documentary A Billion Lives by filmmaker Aaron Biebert.

In conclusion, the failure of NRT in Malaysia, available at pharmacies is sufficient evidence to show that classifying e-cigarettes as a pharmaceutical product will be counterproductive and hypocritical.

FACT 7 – Stigmatising consumers who are looking for less harmful products is wrong

Given the potential benefits of e-cigarettes for cigarette smokers, regulations should be enacted to make them more accessible to smokers rather than regulations that take the product off the market and make it difficult for smokers to buy.

Smokers intending to switch to less harmful e-cigarettes require nicotine in their e-liquids. It is a mockery to intentionally make it difficult for smokers to have access to e-liquid with nicotine, which is less harmful than regular cigarettes.

This is similar to discouraging people from using hybrid cars that are less harmful to the environment than internal combustion engine cars.

It is an utterly flawed piece of public policy, depriving smokers from a less harmful product.

Many smokers do not see smoking as a disease but may see it as a choice and a habit they may want to quit or switch to a less harmful product.

These smokers will not approach doctors or pharmacies to access e-cigarettes, which may only be available with a medical prescription at accredited pharmacies if these products are regulated as pharmaceutical products.

Indeed, the low success rates of NRTs in Malaysia and globally, clearly show the fallacy of believing pharmaceutical products can eliminate smoking.

Excessive and ill-conceived regulation will marginalise these products and their consumers by making them unattractive to smokers who are looking for other less harmful products and they will continue to smoke more harmful regular cigarettes.

Such harsh regulations may also lead to adverse consequences such as encouraging vapers to obtain them from unregulated sources (self-nicotine the liquids), which is something which the government should try to avoid.

FACT 8 – E-Cigarettes a gateway ‘out of smoking’

A survey of over 7,000 Malaysians by Dr Konstantinos Farsalinos has confirmed that less than 1% of e-cigarette users were non-smokers before they started using e-cigarettes.

This is consistent with the findings of Public Health England in their report ‘… the authors find that among adults and youth, regular use of e-cigarettes is found almost exclusively among those who have already smoked’.

In the survey conducted by Dr Farsalinos in Malaysia, almost 70% of respondents confirmed they quit smoking because of e-cigarettes while a further 27% have reduced their smoking.

Further, 80% of the same respondents also stated they will revert to smoking much more harmful cigarettes if access to e-cigarettes was banned or restricted.

In summary, the survey reflects that if e-cigarettes were prohibited or regulated as pharmaceutical products, a most of the vapers would return to smoking cigarettes.

The fact is that both Dr Riccardo Polosa and Dr Michael Siegel, Professor at the Boston University School of Public Health, in separate studies, have concluded that “…rather than serving as a gateway toward cigarette smoking, e-cigarettes may actually be acting as a diversion away from cigarettes.”

Last but not least, there will be less incentive for smokers to continue smoking far more harmful cigarettes, when e-cigarettes can be further developed to become more reliable, equally satisfying and as readily available.

As such, e-cigarettes with or without nicotine, are not a gateway to smoking instead they are a gateway OUT OF SMOKING, and heavy regulation by restricting access to e-cigarettes will ultimately encourage continued use of much harmful cigarette smoking.

The Ministry of Health should be encouraging people to quit smoking, and not drive them back to smoking cigarettes by classifying e-cigarettes as pharmaceutical products.

FACT 9 – Sensibility, Credibility and Reliability

In a recent news report, Professor Datuk Dr Abdul Razak Muttalif, a former director of the Kuala Lumpur Hospital Institute of Respiratory Medicine and Chairman of the Health Ministry’s Technical Committee on e-cigarettes, without any concrete basis or reasons, questioned the reliability and credibility of Greek cardiologist Dr Konstantinos Farsalinos, who is a leading international cardiologist.

It is very unfortunate that it is always easy to come out with sweeping, baseless and fact-free statements without providing evidence to substantiate it.

The so-called “unreliable” survey conducted by Dr Farsalinos has more than 7,000 Malaysians interviewed. Additionally, similar results in UK and other countries give credibility to the Malaysian survey results.

Professional courtesy and ethics should be observed at all times even in matters that one is passionate about. It is very unfortunate and sad for one of our local experts to question the credibility of the doctor and its survey before doing some fact-check.

Instead, it would be great if a cordial and fact-based discussion can be organised where Dr Abdul Razak can share his survey results and/or studies (if any) with Dr Farsalinos.

FACT 10 – Wisdom and Courage

We applaud the wisdom of Ministry of Domestic Trade, Co-operatives and Consumerism (MDTCC) in recognising the need to regulate the use of e-cigarette and the courage of the Ministry in leading the effort to introduce a practical and sensible policy towards e-cigarette.

Ultimately, it is important for all to safeguard the best interest of the rakyat and not get influenced by misleading, tainted and corrupt lobbying activities of Big Pharma.

Regulators should start to explore possibility and embrace the potential benefit of e-cigarette in reducing or eliminating diseases and early deaths caused by smoking.

Malaysian Organisation of Vape Entities (MOVE)

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