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THE COUNTERFACTUAL: What is WHO doing about ENDS?

Republished from Clivebates.com with the consent of the author

This section really reveals that WHO does very little other than publish prohibitionist propaganda. It is however worthwhile noting that its regrettable dependence on voluntary contributions leaves it exposed to major conflicts of interest. 

WHO does not pay attention to the evidence. If it did there would be much more discussion of trade-offs and possible benefits and a proportionate and more realistic approach to the risks. In fact, the report highlighted, the WHO Report on the Global Tobacco Epidemic, was “made possible” by the private foundation of the billionaire, Michael Bloomberg, who coincidentally figures prominently in the report despite the claim that it is independent. The report acknowledgements include several anti-vaping activists, some funded by Bloomberg, brought in to do the work.

The influence of anti-vaping outsiders on WHO’s finances. Bloomberg’s foundation, Bloomberg Philanthropies, campaigns for vaping prohibitions to the extent possible wherever it works via the work of its grantees. Take the major Bloomberg funding recipient, the Union, for example: and its prohibition policy, Why bans are best. Bloomberg’s approach to evidence and data on tobacco is discussed here: Michael Bloomberg loves data. Except when he doesn’t

WHO is conflicted by the funding it receives from pro-prohibition Bloomberg Philanthropies ($23m). Then there is also the much larger WHO donor, the Bill and Melinda Gates Foundation ($592m), which supports a range of organisations hostile to tobacco harm reduction. In addition, there are also pharmaceutical companies like GSK ($12.3m) that provide multi-million dollar donations to WHO but take a hostile stance toward e-cigarettes. 

Note that this money does not have to be spent on anti-vaping campaigns for the policy position of the donor and the donation to create a conflict. The point is that anti-vaping organisations play a significant role in WHO’s finances.

Written by Clive Bates

Thailand takes the dangerous path of denying harm reducing alternatives

Thailand’s Public Health Minister and Deputy Prime Minister Anutin Charnvirakul said last week that the importation and production ban on vaping products will continue, depriving Thai smokers of provable alternatives to quit.

“Thailand’s failure to acknowledge the powerful benefits of harm reduction — specifically in vaping products and other nicotine alternatives — shows that they are letting down the 15.4 million Thai smokers,” said Tarmizi bin Anuwar, an associate at the Consumer Choice Center.

“There is a reason that countries such as Japan, and more recently the Phillippines have embraced these novel technologies, empowering their own people and giving them legal alternatives to save lives. The government must take an evidence-based policy approach in developing policy to ensure that the government does not do wrong actions,” he added.

“Every health ministry in the world is looking for solutions to reduce the use of combustible tobacco by their populations. While they continue searching, nicotine alternatives such as vaping have proven to be a gateway away from smoking and are now a key tool for harm reduction globally,” said Yaël Ossowski, deputy director at the Consumer Choice Center.

“If the Thai government continues its prohibition on nicotine alternatives, they are depriving their citizens of other means of putting down the cigarette. This impacts every segment of society — young and old — and will have real health consequences.

“To demonstrate to the international community that Thailand is serious about this issue, they should empower their consumers and entrepreneurs to deliver the solutions that have already driven record-low smoking rates in other countries, by embracing and legalizing vaping products and nicotine alternatives,” said Ossowski.

“Otherwise, smokers will be forced to turn to illicit markets to find these products that are widely available outside the country, which will be harmful for society overall.”

The Counterfactual: What role do ENDS play in smoking cessation?

Republished from Clivebates.com with the consent of the author

The evidence actually supports significant effects on smoking cessation. The evidence is only unclear if you insist on looking away from it or imposing a far higher standard of certainty than on any other tobacco control measure. All evidence is unclear to some degree, but evidence from multiple sources triangulates to strongly suggest that vaping assists with smoking cessation and that e-cigarettes function as economic substitutes for cigarettes. This is exactly what we should expect.

Professor Kenneth Warner of the University of Michigan summarises the state of the evidence as follows:

Smoking cessation and harm reduction are compatible, not opposing strategies. There is nothing wrong with some of these smoking cessation measures, but there is much less evidence than WHO implies that they work at scale in real-world settings or reach the smokers who are at the greatest risk (those who don’t want to quit). But they are not alternatives to harm reduction approaches and they work in a different way. E-cigarettes are not primarily a smoking cessation treatment (though they can be that as well) but work as a much safer consumer alternative to cigarettes for people who want to use nicotine.

WHO overstates its own role in addressing smoking. Nor are they the same as the measures promoted by WHO at last year’s World No Tobacco Day – Commit to Quit – when WHO launched a year-long campaign to help 100 million people quit tobacco. A year on we have heard little of this and no progress report. A year later, these claims look like empty hubris. 

Written by Clive Bates

Money-saving tips for consumers during high inflation

In the view of Fabio Fernandes, Head of Communications at the Consumer Choice Center, a consumer advocacy group and nonprofit organization, consumers looking to gain a solid financial footing in this uncertain economic environment should try to reduce their spending habits on non-essential items.

“Inflation hurts low-income consumers the most since families at the lower end of the income distribution spend a substantial share of their income on core needs. Nearly 75% of expenditures for low-income families go to food, transportation, rent, utilities, and cellphone service.”

Gas Prices:

“Unfortunately, gas prices are still high in many parts of the United States, and there are very few things car-dependent consumers can do to minimize its impact on the household budget. Our suggestion is to plan your drive for when you’re running errands by tracing a route that would reduce needless extra miles.” 

“Another obvious suggestion is driving less. The work-from-home trend is stronger than ever, and if your job allows, ask your employer to stay at home a couple of days a week.”

Inside the Home:

“When it comes to inflation on household items, the greatest villains are utilities. Consumers can save energy by reducing the number of times they do laundry or run the dishwasher, or even by changing a couple of degrees the thermostat.”

“Consumers who have been using the same providers for electricity, gas, and especially broadband tend to get too comfortable. If you live in an area with multiple providers for any of those services, don’t hesitate to call them and listen to their offers. New customers enjoy special prices and perks that old clients don’t, so looking at the competition might be a money saver.”

Subscriptions:

“Digital subscriptions can be a rabbit hole and a financial drain. Get rid of those charges you get every month for apps you don’t use and don’t necessarily need. Reducing the number of streaming subscriptions or consolidating into family plans can help you save the big bucks in a year. ”

“It’s the ideal time to negotiate your subscriptions or membership fees. Many companies are offering reduced prices or even a couple of months free when you try to cancel your subscription. However, don’t bluff. List the subscriptions and memberships you can live without and when offered a deal, consider the weight of the new price on your household budget.”

Shopping:

“Sound financial advice for consumers looking to save money when shopping is to go with a plan and stick to your shopping list. Consumers should be comparing prices, planning their meals, and clipping coupons to maximize their savings. These not only make budgeting easier but more importantly, most impulse purchases can be avoided this way.”

“There’s always the advice to buy in bulk. You can share the cost of large packages with friends and family and thus get excellent deals. Add to that coupons, store membership, and fidelity cards, and consumers could get additional discounts while accumulating points, or my favorite, getting cashback for every dollar spent.”

When asked about Buy Now Pay Later, Fernandes said: “Shoppers need to be aware that a missed installment payment could mean late fees and other penalties. It could also be reported to the credit bureaus and end up on a consumer’s credit report.”

“With soaring inflation, buying and paying now is much better if you have disposable income. Paying later sometimes means putting an additional burden on your household budget when inflation rises further, and wages can’t keep up.” Fernandes continued.

“The reality is that there is very little room in anyone’s budget for wants right now,” concluded Fernandes.

CCC joins coalition opposing Credit Card Competition Act

Dear Member of Congress: 

We, the undersigned organizations, oppose the inaccurately named Credit Card Competition Act of 2022 (S. 4674). The bill is a backdoor  price control, and extension and expansion of the Durbin amendment as  enacted in the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203).  

As written, the bill directs the Federal Reserve to draft rules requiring credit cards issued in the United States to offer at least two unaffiliated  payment network options for point-of-sale and online transactions.  

According to the bill, the two networks may not both be Visa and  Mastercard, because they “hold the 2 largest market shares with respect  to the number of credit cards issued in the United States.” However,  should market share switch hands to new firms, the routing mandates  will no longer apply. The bill also mandates that the proprietary security of the credit cards function so that all networks are available for retailers  to pick and choose—consumers get no say whatsoever. In fact, the bill  never mentions consumers, nor how they will benefit.  

It is abundantly clear that special interest groups are using the  federal government to alter the credit card market to benefit  themselves and not consumers. This is textbook rent seeking behavior, anathema to free market principles, and should be  staunchly opposed by Republican lawmakers.  

Furthermore, we oppose S. 4674 for the following reasons: 

The bill does not promote competition, instead it dramatically expands the role of the federal government to  overregulate the market for credit cards. Today, requiring multiple dual-message networks to function over one card is  technologically infeasible. The cost of overhauling our current  credit system to comply with the mandates in the bill could cost  up to $5 billion.  

The mandates in the bill are so costly that more than $60  billion in rewards that consumers receive every year would  largely disappear. According to the International Center for Law & Economics, “86% of credit cardholders have active  rewards cards, including 77% of cardholders with a household income of less than $50,000.”

The bill authorizes the federal government to intervene in  contracts between private parties. The federal government  should not be interfering in private contractual agreements. This  encroachment will force small banks and credit unions to  severely limit or cease providing co-branded cards that millions  of consumers use every day. This is similar to how Biden’s  Securities and Exchange Commission is attempting to dictate provisions of contracts between private fund advisers and  investors.  

There is no evidence that this bill will pass savings down to  consumers. A report from the Government Accountability  Office stated that if the regulations in the Durbin amendment  “had not been implemented, 65 percent of noninterest checking  accounts offered by covered banks would have been free.” Since  the enactment of the Durbin amendment, about 22% of retailers have raised prices on consumers while only 1% lowered prices.  Additional regulation on credit interchange will affect fees and  interest in the credit market, thus increasing costs for consumers. 

Because the bill forces credit cards to allow access to all  networks, proprietary technology will be exposed to  competing networks, destroying incentives to create new and  innovative fraud protection and cybersecurity. As one paper points out, the routing mandates “largely undermine the  economics of networks and issuers.” 

The bill is a perfect example of Congress ceding its Article I  authority to the Federal Reserve. All the provisions of this bill  require the Federal Reserve to draft rules to carry out its  mandates.  

Based on the points made above, we believe this bill is diametrically  opposed to free market principles. We encourage all lawmakers to  oppose this bill. 

Sincerely,  

Yaël Ossowski
Deputy Director
Consumer Choice Center

WHAT ARE THE POLICY OPTIONS FOR REGULATING ENDS?

Republished from Clivebates.com with the consent of the author

WHO leads with outright prohibition as its preferred policy, though it has never bothered to justify this with reference to intended and unintended consequences or the rights of smokers to access lower risk products. Almost everything else it proposes functions as a de facto protection of the cigarette trade.

WHO starts with an anchoring bias: that the normal policy response should be the prohibition of ENDS. There is no scientific or ethical basis for this policy. Why would it make sense to ban the much safer nicotine product, deliberately deny law-abiding smokers better options, protect the cigarette trade from competition, stimulate unregulated black markets in vaping products, and draw young people into the illicit supply chain, and therefore into criminal networks? 

WHO has never assessed the costs and risks of ENDS prohibition, but relentlessly promotes it all the same. I have written about WHO’s strong support of vaping prohibition here: Prohibitionists at work: how the WHO damages public health through hostility to tobacco harm reduction

The arguments against prohibition are well put in this document by the consumers’ organisation INNCO: 10 reasons why blanket bans of e-cigarettes and HTPs in low- and middle-income countries (LMICs) are not fit for purpose.

International Network of Nicotine Consumer Organisations (INNCO), 
10 reasons why blanket bans of e-cigarettes and HTPs in low- and middle-income countries (LMICs) are not fit for purpose, March 20

WHO fails to grasp trade-offs and unintended consequences in policymaking. There is nothing in this regulatory package that shows that WHO has grasped the basics of policymaking in this area. The critical policy insight is that excessive regulation of vaping products functions as a barrier to entry and protection of the more dangerous cigarette products. The Royal College of Physicians (London) expressed this well in its 2016 report, Nicotine with smoke: tobacco harm reduction:

Tobacco Working Group. Royal College of Physicians (London) 
Nicotine without smoke: tobacco harm reduction 28 April 2016

There are other trade-offs: the protection of young people from relatively minor risks (e.g. experimental vaping) could have the effect of imposing major risks on adults (continued smoking or relapse from vaping to smoking). A further complication is that for some adolescents, vaping will function as a diversion from smoking. For these young people, the teenagers most at risk, vaping creates a significant health benefit.

Written by Clive Bates

The Counterfactual: Are secondhand ENDS emissions dangerous?

Republished from Clivebates.com with the consent of the author

WHO avoids a comparison between secondhand smoke and secondhand aerosol. Again, WHO uses the words “potentially” and “potential” to avoid saying anything about how toxic or how risky. In my own Q&A on vaping and harm reduction, I highlight three key differences between secondhand smoke and secondhand vape exposure: 

  1. The quantity emitted. Most of the inhaled vapour is absorbed by the user and only a small fraction is exhaled (15% or less, depending on the constituent).  In contrast, about four times as much environmental tobacco smoke comes directly from the burning tip of the cigarette than is exhaled by the smoker. There is no equivalent of this “sidestream smoke” for vaping.
  2. The toxicity of the emissions. Tobacco smoke contains hundreds of toxic products of combustion that are either not present or present at very low levels in vapour aerosol. Vapour emissions do not have toxicants present at levels that pose a material risk to health. Exposure to nicotine, itself relatively benign, is unlikely to reach a level of pharmacological or clinical relevance.
  3. The time that the emissions remain in the atmosphere. Environmental tobacco smoke persists for far longer in the environment (about 20-40 minutes per exhalation). The vapour aerosol droplets evaporate in less than a minute and the gas phase disperses in less than 2 minutes.

The main issue with vaping in public is etiquette and consideration for others. At this stage, there is nothing to suggest that indoor vaping presents a material risk to bystanders. But that does not mean there should be a license to vape at will anywhere. It means the owner of a property should determine the policy for their premises. A government override of these property rights can only be justified if there are material risks to bystanders or workers.

Written by Clive Bates

THE COUNTERFACTUAL: Are ENDS addictive?

Republished from Clivebates.com with the consent of the author

The claim of addiction depends on what you mean by addiction and how the nicotine is delivered. WHO does not bother with such subtleties. There are two issues. 

First, what is meant by the word “addiction”? This term is often used very loosely and often with the intention of stigmatising “the addict”, However, it has a specific meaning that does not apply to all forms of nicotine use. 

E-cigarette use does not meet this definition for most users because nicotine itself isn’t that harmful and vaping just isn’t that harmful either. 

Second, it depends on the way it is delivered. The dependence-forming characteristics of nicotine vary according to how it is delivered to the body – how much and how fast it reaches the brain, and also whether there are other agents that add to the effect. It is quite likely that many smokers who have taken up vaping “transfer” their nicotine dependence to the new products while benefitting from the greatly reduced risk.

This issue was discussed in the paper in the American Journal of Public Health by fifteen past presidents of the Society for Research on Nicotine and Tobacco. 

Balfour, D. J. K., Benowitz, N. L., Colby, et al. (2021). Balancing Consideration of the Risks and Benefits of E-Cigarettes. American Journal of Public Health111(9), 1661–1672.

Written by Clive Bates

The Counterfactual: Are e-cigarettes more or less dangerous than conventional tobacco cigarettes?

Republished from Clivebates.com with the consent of the author

WHO goes through great contortions to avoid truthfully saying less dangerous. The most important feature of this section is that WHO does not answer this question with a truthful answer like “much less dangerous”. This is the correct unambiguous answer based on current scientific knowledge. In fact, WHO does not answer the question it poses at all – I suspect this is in order not to have to answer it truthfully. 

The question is used to imply e-cigarettes may be more dangerous. The question itself creates an anchoring bias: suggesting that it is even possible that e-cigarettes may be as dangerous or more dangerous – as if it is somehow a finely balanced call. It is not finely balanced. Not even close. The reasonable question would be “how much less dangerous are e-cigarettes than conventional tobacco cigarettes?”. The answer is a lot less. 

WHO offers a diversion from the question. Yes, but that formulation is simplistic: it avoids the “how dangerous?” questions and avoids the actual question asked in the Q & A – which is what is the relative risk of smoking and vaping? What if they differ in risk by a factor of about twenty times as many experts believe? Using neither may be a good option – but what about people who want to use nicotine or would find it difficult to stop? 

While ignoring the most fundamental difference (combustion), WHO introduces distracting but relatively trivial differences. WHO approaches this question on the basis that because we don’t know everything we must know nothing, adding the appearance of complexity to obscure more fundamental differences between e-cigarettes and cigarettes – namely that there are no products or combustion and smoke inhalation.

To avoid answering the actual question, WHO evokes a gateway effect. Here WHO just evokes imagined pathways by which the use of the much safer product leads to the use of the much more dangerous product – a kind of sleight of hand to imply that vaping and smoking pose equivalent risks. The problem is that these pathways are based on a gateway theory that does not hold water. 

WHO deploys a device to introduce doubt and to remove confidence that general advice about e-cigarettes being safer can be relied upon. It is a Merchants of Doubt tactic. There are of course differences between different vaping products – and differences arise from the pattern of use between users. This is also the case with combustion products. However, this should not be allowed to obscure the huge difference between the combustion and non-combustion nicotine products at the level of the whole category. The difference between smoke inhalation and smoke-free is the difference that really counts. 

The claim that smoking and vaping have equivalent risk is the Big Lie of tobacco control. It is inconceivable that this would be the case, yet it is an easy and lazy (or cynical) statement to make. When Professor Stanton Glantz made this case he used 700 words, my rebuttal took 13,000 – see: Vaping risk compared to smoking: challenging a false and dangerous claim by Professor Stanton Glantz

As I mentioned above, Public Health England suggests that “stating that vaping is at least 95% less harmful than smoking remains a good way to communicate the large difference in relative risk.” The Royal College of Physicians concurs

“Although it is not possible to precisely quantify the long-term health risks associated with e-cigarettes, the available data suggest that they are unlikely to exceed 5% of those associated with smoked tobacco products, and may well be substantially lower than this figure.”

These are much better ways of answering the question that WHO poses than the answers provided by WHO, which essentially say nothing useful at all, just distraction and obfuscation.

Written by Clive Bates

The Counterfactual: Do e-cigarettes (ENDS) cause lung injuries?

Republished from Clivebates.com with the consent of the author

Nicotine e-cigarettes did not cause the lung injuries described in this section. This entire section is completely misleading and has no place in a Q & A on nicotine e-cigarettes or ENDS (electronic nicotine delivery systems). It is clear beyond doubt that nicotine vaping was not implicated in the outbreak of EVALI discussed in this section.

In fact, there is no evidence for this whatsoever. This is a statement that ENDS (i.e. nicotine products) are implicated in the episode of lung injuries seen in the US in late 2019. The evidence is clearly contrary to this. Here is how I summarised the argument in my critique: The outbreak of lung injuries often known as “EVALI” was nothing to do with nicotine vaping.

Bates, C. (2021). The outbreak of lung injuries often known as “EVALI” was nothing to do with nicotine vaping. Qeios. https://doi.org/10.32388/ZGVHM7.3

This quote is fake and misleading. This is nonsense and not even a real quote from CDC. This is not the wording used by CDC and the word “ENDS” does not appear on the CDC page cited. The reason is obvious: ENDS means “Electronic Nicotine Delivery System” and there are no ENDS that have THC and Vitamin E Acetate (VEA) added because that is not physically possible (see Kozlovich et al, 2021) – these liquids do not mix. Far from being updated every week, this CDC page was last updated in February 2020. 

The wrong time and wrong attribution. That might be because the outbreak had dwindled to almost nothing by February 2020. This is consistent with supply chain contamination (with VEA) that ended once the problem was discovered and the supply chain emptied.

Source CDC

Yet more than two years later, in May 2022, it seems as though anti-vaping activists like the World Health Organisation found that promoting the EVALI story was just too tempting not to use in their misinformation operations. They commit the dual sin of drawing on an episode that is substantially over and misattributing it to nicotine e-cigarettes.

Written by Clive Bates

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