FCA COP-6 brief on e-cigarettes, is it good enough?

The Sixth session of the Conference of the Parties to the WHO FCTC, also known as COP-6 is going to be held next week (from the 13th to the 18th of October) in Moscow. I guess most of you noticed that WHO published their report and position on e-cigarettes (or ENDS as they like to call it) a little while ago, a report that to me looks like it's designed by Big Tobacco and backed up by Big Pharma to make sure e-cigarettes pose a health problem. You can read my comments on the report here.

On October the 7th the Framework Convention Alliance (FCA) published it's brief on e-cigarettes prior to the COP-6, and yesterday Clive Bates did an excellent review of their paperwork: http://www.clivebates.com/?p=2448. As Clive says, the FCA position on e-cigarettes is in sharp contrast to WHO. I'm happy to see that the FCA recognizes that there could be negative unintended consequences from over-regulation just as there could be from under-regulation, something the WHO doesn't seem to understand at all. To me this very sentence shows that they are actually seeing e-cigarettes as part of a possible solution, not the problem, as opposed to the WHO who only sees e-cigarettes as a problem (or at least so it seems from their report). 

The FCA also recommends agreeing on direction setting principles prior to any policy making, and suggest 7 such principles: 

1. The global burden of death and disease from tobacco is primarily caused by smoking.  
2. While quitting tobacco use is paramount, quitting nicotine use altogether is the best option.
3. For those unable to quit tobacco, switching to alternative sources of nicotine that are less harmful can reduce, often very substantially, the harm smoking causes to the individual. 
4. The benefits of such an approach would be maximised if uptake were limited to existing smokers who are unable to quit. 
5. The risks of such an approach would be minimised by taking measures to limit uptake by never-smokers, in particular amongst young people, to protect non-users, and to discourage long-term dual use.
6. There could be negative unintended consequences from over-regulation just as there could be from under-regulation. 
7. The involvement of tobacco companies in the production and marketing of e-cigarettes is a matter of particular concern as there is an irreconcilable conflict of interest between those profiting from the sale of tobacco and public health.

Clive comments on each of these principles, and I agree with most of his comments, so I'm just going to recommend reading his post. I especially like Clive's comments on number 4, where he disagrees with the FCA, and say that "this sounds reasonable but it is not true". The point here is that non-smokers taking up vaping could actually be doing so instead of taking up smoking. Clive points to Scandinavia and says that part of the reason for low smoking initiation rates here is that Snus initiation has displaced smoking. This is exactly the same theory that I've written about earlier, the firewall theory. E-cigarettes work as a firewall towards cigarette smoking, both for ex-smokers hindering a relapse, and for non-smokers, often youth that would otherwise have experimented with cigarettes smoking.

Now I said I agree with most of Clives comments. When it comes to the last principle Clive says that Big Tobacco's involvement "should be problematic only if their involvement results in more smoking." Although I don't actually disagree with that statement I think Clive gives Big Tobacco more credit than they deserve: "It is very far from clear that the companies have incentives to protect smoking". In my opinion, seeing how they have navigated and lobbied so far it's not that far from clear. Their latest warning labels on their e-cigs are a good example. However, as Clive says, it is problematic to deny a harm reduction product as a matter of principle just because it's made by Big Tobacco. But I do understand FCA's concern.

The FCA's brief on e-cigarettes are miles better than the WHO's, but I also ask myself the same question that Clive does: Is it good enough? I'm sitting here with a feeling that FCA is holding back a bit to avoid colliding to hard with the WHO, and I'm a bit afraid that we'll end up with something in the middle, which in my opinion isn't good enough. To quote Clive once again:

Think what could be achieved if this alliance embraced the concept of tobacco harm reduction, and ran hard with it – becoming the experts and authorities on managing the risks and unintended consequences in their own countries and, if appropriate, in the FCTC.