The Norwegian Institute of Public Health censored their own top researchers

Last week I wrote that the TPD and plain packaging passed in the Norwegian parliament. The Norwegian Institute of Public Health, NIPH, played an important role in this, not only through their response to the public consultation prior to the vote, but also through their reports on e-cigarettes (which I've written about before) and their statements during a committee hearing in October this year. Now, some of NIPH's own researchers reveals that important information was held back during this committee hearing, and hence the members of parliament, that voted in favour of the new tobacco act, had inadequate information. Norwegian newspaper Dagbladet has gained access to emails showing this and they've talked to Erik Nord and Karl Erik Lund about it. This was published in an article last week (sadly behind a paywall).

Erik Nord

Karl Erik Lund

"NIPH handled this case in a way that Karl Erik Lund's and my own views on e-cigarettes were never submitted to the Committee. (...) This was in my opinion contrary to the general desire for the best possible  information on the case, and disloyal to the parliamentary committee on health and care services", writes FHI researcher Erik Nord in an email exchange Dagbladet has accessed.

Both Nord and Lund have argued that what we know about relative harm and usage patterns strongly suggests that a strict policy on e-cigarettes can lead to loss of a lot of lives. They wanted to get this view across to the committee, but instead their calculations and summary on the research done on e-cigarettes were omitted when NIPH held their presentation to the parliamentary committee.

Nord directs harsh criticism towards the leaders of NIPH that he in this case says are driven by a wish to satisfy the politicians instead of a wish to objectively impart knowledge. Nord and Lund both have their background from the The Norwegian Institute for Alcohol and Drug Research, SIRUS, that earlier this year was merged with NIPH. SIRUS researchers then expressed concerns that they risked loosing their freedom, credibility and freedom of speech as NIPH has a less independent role compared to SIRUS. It looks to me that they had a very good reason to worry. The two institutes have often disagreed publicly for several years in different questions, for example the use of snus. Karl Erik Lund have been a strong supporter of harm reduction through both snus and e-cigarettes and have expressed this publicly a lot of times while he was Research Director at SIRUS, and I'm happy to see he and his colleagues from old SIRUS still puts ethics and science above satisfying egocentric politicians.

This is not the first time Lund and Nord have ended up in this situation after the SIRUS/NIPH merge. They also wrote a report contradicting Minister of Health, Bent Høie's views on plain packaging. Despite that an article in newspaper VG revealed that this report was ignored and left out of the background material when the proposed changes to the tobacco act was written, nothing was done. The Australian lies fit Høie's agenda better, so they kept those instead.

"After the VG article about snus packaging some time ago I sent out an email about a crisis of confidence in the NIPH. In a meeting immediately afterwards Camilla (NIPH director Camilla Stoltenberg, ed note) asked what was needed to restore confidence. I have since pointed out that action, not words, is needed. The handling of this case was the opposite of what is needed", Nord write in his email.

Talking to Dagbladet Nord estimates that between two and three thousand Norwegian smoker will die prematurely as a direct consequence of a strict e-cigarette policy. "This is the reality that the politicians will have to expect", says Nord.

"When the health care committee requests to be presented with the different views, it is natural to do so. Instead the area director chose to give a kind of unified presentation where our calculation was completely gone", he explains to Dagbladet.

In an email that Dagbladet has read, Nord writes that NIPH in some cases obviously has "issues dealing with its dual role as a research / information provider on one hand and advisor on the other, and that it's leaders unfortunately sometimes ends up being political actors".

Area director Knut-Inge Klepp have been publicly sceptical to e-cigarettes all along. This also goes for NIPH director Camilla Stoltenberg, and that suits Bent Høies agenda quite nicely. Lund and Nord research and views on the other hand, doesn't fit this agenda at all. So one can only wonder... why did they decide to merge SIRUS and NIPH?

Klepp, of course, does not agree with Lund and Nord and says: "I disagree that we in any way attempted to withhold information. We have been completely open that there is scientific disagreement within the institute" What a load of crap. What he's actually saying is that they admit that their researchers (the people that actually know something about this) does not agree with the leadership, but they chose not to present their views anyway. Why? Because they've found other science that fits the politicians agenda better?

He then goes on with the usual "there is not much research done on the consequences of e-cigarettes and a fresh survey from the USA supports a stricter policy than Nord and Lund wants", and goes on:

The math is interesting. There is uncertainty about the numbers just as there is uncertainty about much of the knowledge about e-cigarettes. Here we get new results every week, and I think that it is wise not to be too firm, but monitor research on health effects both in Norway and internationally closely in the future. 

I'm not sure what to say to that? "Blah, blah, blah" might be fitting? There is a lot of research available, just not much supporting the views and agenda of Klepp and whatever politician he thinks he needs to satisfy to keep his job. Klepp goes on:

(...) It is not a problem that it appears there is scientific disagreement within such a large institute, but rather a strength. The challenge is of course that we can use the controversy to develop good research that can bring us results in this field.

More empty words from Klepp there. The research is already there, from researchers at his own institute among others. Still he was the one that chose to omit it when presenting what was supposed to be all the views and research to the committee, depriving them of the ability to make well informed decision.

Then again, would it really have mattered if Lund and Nord had been able to get their views across, telling the committee the real consequences of their actions? Apparently not. Tove Karoline Knutsen (Norwegian Labor party, AP) says that the committee members are well aware of the views of Lund and Nord but still:

Of curse we listen carefully both to NIPH and others, but for Labour it is also important to proceed somewhat incremental in cases where there is so little research as in this case, and in any case ensure that we don't do something that is irreversible. If at some point we get far more knowledge our view can be revised, but I think it is important now that we treat e-cigarettes as regular tobacco with the same restrictions, if they are primarily intended to be a tool for smoking cessation.

I get the feeling you've listened a lot to NIPH, and paid extra attention to Klepp's way of ignoring science. What really is irreversible is the damage done by the new tobacco act. Pigs will learn to fly before Norway removes or changes a law that complies with the EU TPD.

Last week I tried to figure out what motives the Minister of Health and his department have for doing this, even though they have to know by now that they will slow down the accelerating decrease in tobacco smoking. Here's a scary thought: What if that is exactly what they want? Why? From a purely egocentric point of view, just thinking of their own political life it makes sense though. Because no matter how poorly their plain packaging works, smoking rates will continue to decline. The Australian government have demonstrated how, by some simple statistical tinkering, they can make it look like this has worked. That looks great in a political campaign. Same thing with e-cigarettes, even if they manage to slow down progress, which will result in less lives saved, e-cigarette use will slowly become more visible and mainstream, and they can say that "hey, we legalized e-cigs... and have a look at our statistics now. Smoking is declining." (Which it would have done anyway, of course). What's even better from their point of view is that if the decrease in smoking is slow enough, they can continue to make up useless provisions to score political points for years to come as well.

The Norwegian Institute of Public Health has become the government's tool to deceive the public, making us believe that they're doing a great job for public health. As we've seen they are willing to go pretty far to do this, even censor their own top researchers if their research show the "wrong" results. We can only hope that Lund, Nord and the other researchers from SIRUS will create such hell that the house of cards eventually falls apart. These are the most experienced and best tobacco researchers we have here in Norway and they are the ones that should be responsible for NIPH's statements, views and presentations regarding this.

TPD and plain packaging passed in Norwegian Parliament

On Friday, December 9th, the Norwegian government published a press release stating that the proposed changes in the tobacco act will pass in Parliament. The proposed changes are, as I've written before on several occasions, the EU TPD and plain packaging for both cigarettes and snus. I recommend reading my previous articles on what this proposal actually means, and what lies our politicians use to justify this, either consciously or due to severe lack of knowledge and willingness to learn. I also submitted an answer to the public consultation on this case. The exact time the new tobacco act will be effective is not yet set, but it will happen some time during spring 2017.

I've been watching the speeches made by representatives from all parties when this case was processed in Parliament on Friday. A lot of the representatives have developed a remarkable resistance to facts, seeming almost immune to the realities of the case. I guess most of my readers don't understand Norwegian, so I'll sum up the arguments used in short: The gateway theory and nicotine in e-cigarettes will harm both the user and innocent bystanders (mainly children of course). Yeah... that's right. Norwegian government still believes that e-cigarettes will increase recruitment of smokers among young people, even if it has been shown over and over again that this is not the case at all. They are very concerned with the increase in snus use and e-cigarettes, and fails completely to see that this coincides with an accelerating decrease in young smokers. Karl Erik Lund's excellent article on the role of e-cigarettes in the tobacco endgame have bypassed them completely. Not that I expected them to read it anyway, but it seems very unlikely to me that no-one in the government or members of the parliament have seen these statistics and been wondering if there might be a connection. To me it is pretty obvious that they don't want to see the connection.

It doesn't help that our department of health refuses to retract or correct their report that falsely stated that nicotine in vapor can be harmful to bystanders. Hell, they even refuse to comment on Dr. Farsalinos last critique, and it's pretty obvious why. Farsalinos shows above all doubt that they are wrong, they stand no chance of making any reasonable argument to why they should not correct this in the report. This would also force them to rewrite the conclusion of the report stating that there is really no harm from so-called second hand vaping. So they just shut up and hope this thing goes on unnoticed by most people, including policy makers. Cause without any harm from passive vaping, their house of cards is starting to fall apart. Same thing goes for the harm from, and addictive properties of nicotine alone. Take that myth away and you'll rip away the whole foundation for their regulation. The sad part is that their strategy of complete silence and just ignoring evidence seems to have succeeded.

An argument that is presented several times in the debate about plain packaging is that this has been so successful in Australia. First of all, this is simply not true. It hasn't been a success in Australia, it's just the Australian government that have twisted some statistics in an effort to hide their failure from the world. I pointed this out in my consultation answer (first point, and also pointed out by Dick Puddlecote among others) so there is actually no excuse for this other than "not bothering to even read the consultation answers". Secondly, let's say plain packaging actually did work, just imagine that the Australian government did not lie about this. How can you argue that even though snus is a lot less harmful than smoking, we should introduce plain packaging for this product as well, making it less attractive compared to smoking. Makes absolutely no sense at all if you ask me. So not only do they base their policy on a lie, but they've created a policy that makes even less sense if the lie wasn't a lie but rather reality. Now that's just priceless.

Minister of Health, Bent Høie, showing his
useless plain packages.

Again... the Norwegian government shows clearly that they are really not that concerned with public health. What their motives really are seems a bit unclear to me. In one way, money is the obvious answer. Handling this in the right way, to promote public health, will cost money in the short run, mainly due to lower income from sin taxes. It's a long term investment in public health that will pay off economically as well, as I've explained before. The problem is that we won't see the effects while this government is in power. It will take some time before we start seeing how much less we need to spend on health care for smokers and the benefits of a healthier population in general. A more healthy population is a more productive one. In a way this government would pay the price while the next once will see the profit. But money is not the only answer here. In my opinion we have a minister of health, Bent Høie, that uses most of his time and energy trying to make it look like he is doing a good job, or at least like he is doing something. He has gotten a lot of press on the plain packaging case and clings on to the Australian lie so he won't have to admit that he's wrong. He is too weak to stand up to the EU and use our right to reserve ourselves from stupid regulations, so he sticks to the lies in this case as well, showing up everywhere with a worried look on his face... "Think about the children! We need to protect the children!". Last time I saw him on TV he was after sugar, and now plans to implement rules that forces food manufacturers to reduce the amount of sugar in their products gradually and grocery stores to move their candy out of sight so we won't be tempted to buy it. In other words... force or trick the public to reduce their sugar intake rather than using the money on education and measures that encourage people to make these choices themselves. Of course he gets to go on national TV to tell everyone that he'll make sure we don't need to worry about our sugar intake any more... he'll just be a hero and fix it for us. Just sit back and relax and let me handle this...

I'm not going to compare raising a dog to altering the behaviour of a population... oh wait, I just did. Kind of a weird comparison maybe, but anyone who have (successfully I might add) raised a dog will know giving the dog a treat every time it does something right works a hell of a lot better than yelling at it for doing it wrong. Now here in Norway it seems like they decided to try out the same thing to get people to switch to electric cars. Give them treats that is. They removed almost all taxes, let them use the bus lanes and even gave them free parking with free charging included. Guess what... it worked. It worked almost too well. When I drove to work today I noticed that the bus lane was just as congested as the other lanes. Now, instead of giving out treats to people for switching to electric cars, the government could have taxed all other cars heavier. It most certainly would also have worked... but not nearly as well or fast. It seems to me that the politicians are surprised how well it worked and now they're scratching their heads wondering how they can justify taking some of the treats away again to put on the breaks to be able to handle the new situation. Where am I going with all this talk about electric cars you ask? Well, the strategy that the government have chosen to fight the tobacco epidemic is quite the opposite to their electric car strategy. I guess this goes for the whole world, not just the Norwegian government. For decades they have tried to scare, force and bully people to stop smoking. And it has worked.... but very, very slowly. E-cigarettes (and I guess also snus) have proven to be much more effective than any other effort to get people to stop smoking, or even better, not to start in the first place. Why do you think this is the case? It's because they are treats in themselves. They give the smoker something more than the cigarettes gave them. So you see... raising a population isn't really that different from raising a dog. The EU and the wimps in the Norwegian government sadly fails to see this, even if they've got good documentation at hand that shows how well it works, and have now decided to keep beating the poor puppy until it gives in and obeys. Sad ... just sad ... cause you know what, they will never reach their goal of a tobacco free population this way. Maybe we should try buying Høie a dog... no wait... that would be animal cruelty.

A Billion Lives ready for global lauch on October 26th

Aaron Biebert's documentary about vaping, A Billion Lives, has now been shown several times around the world, and not long ago the rumors that it is being considered for "Best Documentary Feature" at The Oscars were confirmed. Their success has not come easily, a lot of hard work has been done and a lot of strong forces have been working against Aaron and his team. Some days ago I got a newsletter from them (if you haven't signed up yet, please do it now) telling us about their struggles and how vapers all around the world have made this possible despite the efforts that have been made to stop the words about this documentary from spreading:

Big organizations were trying to bury us. Facebook was unfairly censoring our posts, making them unseen to the public we were trying to reach. Big Hollywood companies were mysteriously "not interested" after expressing strong support. Our small team starting facing burnout and fatigue.
It wasn't looking good. We fell about a month behind our planned release schedule. But you stuck with us.

You lifted us up. Many of you volunteered to help.

You made a lot of noise and caught the attention of two distribution companies called Tugg & Demand.Film.

In this newsletter, the team asked vapers around the world to help organize the global launch on October 26th, and the vapers responded. The movie will be shown quite a few places already, but still there are a lot of screenings that will only happen if they manage to get enough reservations. And this is where you can help out. Have a look at the global launch page on their site to see how and where you can get to see this documentary. The more screenings that actually happens, the more publicity the movie will get, and this is an important movie to make the world aware of. Buy a bunch of tickets and bring your friends! And if you happen to know someone who can get the word out in some kind of publications... even better.

I'm also really happy to see that the movie will be shown here in Norway on November the 14th, in Oslo. I know that they have people working hard to get the press there as well, and I really hope I'll be able to go see it.

Once again: If we can work together and get this movie out to as many people as possible it will be hard to ignore for the people that are going to decide what happens to vaping in the future without risking their own heads rolling. So please do whatever you can to make this happen in a place near you!

Norwegian e-cigarette consultation - My answer

In a couple of days, on monday 26th, we reach the deadline for submitting an answer to the Norwegian governments consultation on the proposed changes to the tobacco act, including a new section on e-cigarettes. I have written a couple of posts about the proposition earlier and what is wrong with it:

• Norway status update: The Norwegian government don't understand the vaping market 
• New Norwegian Tobacco Act proposal based on lies and misinformation
• Norway status update: Plain packaging and e-cigs regulated as tobacco

Below is an English translation of the answer I have submitted. I apologize for some weird English in the translation... I've only had time to let google translate most of it and just corrected the most incomprehensible parts :) 

I strongly encourage Norwegian vapers to submit their own answers. It does not need to be a long thorough walk-through of everything that is wrong, your own vaping story will help a lot. The more answers the government gets on this, the better are our chances of them re-thinking the whole thing. This has already happened in Denmark so it is not hopeless to try. 

For my Norwegian speaking readers: My original answer in Norwegian.

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Consultation on proposed changes to the tobacco regulations and new regulations on electronic cigarettes - Consultation response.

Lately the Minister of Health, Bent Høie, and his government have been under pressure because of their treatment of research reports on the effect of standardized snus- and cigarette packaging. Responding to this the Government defend their conduct saying that they want to use only quality assured background material as a foundation for the proposition (https://www.regjeringen.no/no/aktuelt/vg-tilslorer/id2511679/). I fully support this choice so I find it reprehensible that the proposition is largely based on material that certainly is not quality assured, and apparently hardly has been read by the ministry. I also disapprove that the ministry puts forward some adverse and negative effects as potential problems when good evidence exists that debunks these theories.

1. Regarding neutral cigarette and smokeless tobacco packages
First things first. In his defense of holding back the NIPH study on the effect of standardized snus and cigarette packages Bent Høie says this: "The simple explanation is that in February 2016 an extensive Australian report on standardized tobacco packaging came out. This was so clear in its conclusions that the ministry believed it was not necessary with a Norwegian report as well this shortly after ". Australian authorities have presented the numbers in a way that makes standardized cigarette packages look like a success, probably because they do not want to admit that it actually has not been. They claim is that smoking has decreased from 15.1% to 12.8% after standardized packages were introduced, which is only a cheap trick. Statistics show that this decline has taken place from 2010 to 2013, standardized packages were introduced in 2012. The decline from 2010 to 2013 is virtually the same as it has been in previous years (approximately 0.75% per year), which rather suggests that neutral packages have had no effect. In fact, smoking among youth between 12 and 17 has gone up slightly in the period (http://www.aihw.gov.au/alcohol-and-other-drugs/ndshs/2013/data-and-references/, download data excel sheet), but it would of course be very wrong to argue that this is due to standardized packages, although this would have been natural if one continues to follow the same erroneous logic that led to the success conclusion. To find factors that actually works we should rather have look at why the proportion of smokers in England have gone from 19.3% to 16.9% between 2012 and 2015 after they’ve almost had a standstill the 5 preceding years with a decline of only 0.5% in total.

This shows that the ministry haven’t analyzed their background material properly and left out even the simplest form of quality assurance (namely reading material carefully), thus ending up with a totally ineffective regulation that will only lead to increased use of resources. One can even state a hypothesis about the effect of standardized snus packages that very much seems plausible, namely that the introduction of standardized packages for both snus and cigarettes will cause these products to be perceived as equally harmful by the population. We know with certainty that snus is not nearly as harmful as smoking tobacco, there are several studies that show this. One can also see the statistics from Sweden that there is a clear link between the fact that Sweden is the country in Europe with by far the lowest cigarette consumption and highest snuff consumption while having the lowest occurrence of lung cancer. They are also the lowest in the statistics of oral cancers.

It is in my opinion obvious that a significant review and quality assurance of the background material the ministry use as a basis for the introduction of this regulation is needed before this can be done.

2. Regarding regulation of e-cigarettes
Minister of health, Bent Høie, and other ministers have repeatedly stated that the government wants to remove the unnecessary ban on e-cigarettes on the basis that this has a great harm reduction potential compared to smoking tobacco. This is consistent with, among others, the English health authorities report (https://www.gov.uk/government/news/e-cigarettes-around-95-less-harmful-than-tobacco-estimates-landmark-review) that concludes that e-cigarettes are at least 95% less harmful than cigarettes. Royal College of Physicians strongly recommend that e-cigarettes are promoted as widely as possible as a substitute for smoking (https://www.rcplondon.ac.uk/news/promote-e-cigarettes-widely-substitute-smoking-says-new-rcp-report), and Norwegian government politicians statements in the media suggests that the government also wants to give smokers the opportunity to switch to e-cigarettes. Nevertheless, it is proposed here a regulation scheme which will counteract this to great extent. The proposed regulation will make e-cigarettes less accessible, less secure and knowledge of e-cigarettes and its relative harmfulness in the population will be much lower. In sum this will lead to that fewer people will be able to quit smoking but also that more people will start smoking. A number of experienced tobacco researchers have stated that e-cigarettes are the biggest health revolution since penicillin, and it is a consumer-driven revolution with the potential to end the tobacco epidemic once and for all if it is allowed to continue. Here I would encourage you to read Karl Erik Lund's comment about the e-cigarettes 'role in "the tobacco endgame", that describes this very well: http://www.degruyter.com/downloadpdf/j/nsad.2016.33.issue-3/nsad-2016-0018/nsad-2016-0018.xml.

2.1. Known misconceptions and myths
The purpose of the regulation of e-cigarettes should be to make safer products, protect the public from potential harm while preventing smoking initiation, especially among young people. Many of the proposed provisions are based on misconceptions, myths and poor quality assured background material. At the same time a lot of good background material is omitted.

Minister of Health Høie has repeatedly stated a concern that young people would start with e-cigarettes and then move to smoking. To this there is NO evidence and this "gateway" theory is disproved in virtually all serious investigations, such as the aforementioned study by Public Health England (https://www.gov.uk/government/news/e-cigarettes-around-95-less-harmful-than-tobaccoestimate-landmark-review), which concludes that "there is no evidence so far That e-cigarettes are acting as a route into smoking for children or non-smokers". NIPH's report from 2015 (https://www.fhi.no/globalassets/migrering/dokumenter/pdf/helserisiko-ved-bruk-av-e-sigaretter-pdf.pdf) also concludes this: "This seems to imply that e-cigarette smoking in Norway may have served as a means to quit regular smoking, and until now has not served as a gateway to start regular smoking." For us as former smokers, now vapers, this is also quite obvious. Going from a product that is relatively harmless, tastes good and gives good effect to a less efficient, more expensive and extremely much more harmful product makes no sense, neither when it comes to e-cigarettes / cigarettes or other product choices they make in life .

It also expressed concern about the effects of "secondhand vaping", and to protect non-vapers and non-smokers is the reason for a part of the regulation stating that e-cigarettes should be covered by the smoking ban. The 2015 NIPH report is largely used as justification for this. If you read this report in its entirety you will see that the aerosol from e-cigarettes is regarded as virtually harmless in terms of exposure to all substances other than nicotine. However, the report highlights that "passive exposure to aerosols from e-cigarettes causes about as high nicotine levels in the blood, as of a passive smoker of regular cigarettes. This means that one can expect similar harmful nicotine-related effects of passive smoking of e-cigarettes as for regular cigarettes. ". This is absolutely correct, but the report then claims that "this does not mean that passive exposure to aerosols from e-cigarettes provide carcinogenic effects, but that such passive smoking may affect the cardiovascular system, have stimulant effects and contribute to addiction.". This is completely wrong. Nicotine in passive smoking has never until now been an issue or a problem, and the reason for that is that the amount of nicotine taken up by passive smoking is not big enough to provide any biological effect at all. This is pointed out explicitly by Dr. Konstatinos Farsalinos, one of the world's leading independent researchers in the area here: http://www.ecigarette-research.org/research/index.php/whats-new/whatsnew-2015/204-niph. FHI has answered this criticism and must therefore be aware of this (http://www.ecigarette-research.org/research/index.php/whats-new/whatsnew-2015/207-niph2), but will still not retract their claims. If this serious error in the NIPH report had been corrected, one is left with no reason to include e-cigarettes in the smoking ban because of a need to protect the surroundings. It is worth noting that Public Health England's report from 2015 comes to a different conclusion regarding the amount of nicotine that is released into the air through the use of e-cigarettes (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457102/Ecigarettes_an_evidence_update_A_report_commissioned_by_Public_Health_England_FINAL.pdf. One is thus left with a very thin basis for the inclusion in the smoking ban, namely odors and visual similarity with smoking. Prohibiting the use of e-cigarettes because of odors should be up to the individual house owner, not the state. When it comes to visual similarity with smoking, this will only apply to the tobacco industry's so-called "cig-alikes" (e-cigarettes that look like cigarettes) and we can assume that e-cigarettes are now so familiar in the population that mistakes will occur very rarely. Again the government's own desire to use only quality assured material as basis for the regulation is disregarded by using a conclusion that obviously is proven to be incorrect.

Another concern, that is the reason for several of the rules, is direct exposure to e-liquid with nicotine on the skin or by ingestion. In other words users spilling liquid on themselves or others, or that someone (usually children) unwittingly drinks nicotine e-liquid. The toxicity of nicotine is strongly exaggerated and the doses that are generally accepted as lethal are based on rather questionable self-experimentation in the last century (http://link.springer.com/article/10.1007%2Fs00204-013-1127-0). In general, nicotine will not cause serious harm by spilling a little or that one is unlucky enough to swallow a few drops. Bernd Meyer, among others, has shown this here: http://www.bernd-mayer.com/electronic-cigarettes-and-nicotine-poisoning/. Note that this is based on three articles, quality assured and published in scientific journals (links are at the bottom of the article). Media has also regularly written stories about how nicotine poisoning cases have started to appear more often. Again, it's about quality assuring the background material. Looking at the real numbers behind this shows that there is often about phone calls due to worried users and ignorance being recorded without having particularly serious consequences, maybe just a little nausea and dizziness. In addition, we know that many other household products are sold completely unregulated and has much more damage potential if for example a kid get hold of it, than e-liquid. Comparing the number of serious poisonings from these substances to the number of poisonings due to e-liquid accidents, the latter number will be vanishingly small. Of course we want to avoid such exposure to nicotine e-liquid, but one must look at the relative harmfulness. I will return to this below. The consultation paper refers to an EU report which reported 277 cases of poisoning connection to the use of e-cigarettes. This in itself is a very low figure if one takes into account that this is over 3 years in 8 countries with millions of users. It is omitted in the consultation paper that only 6.8% of these (only 19 cases) have moderate or severe consequences (http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri = CELEX:52016DC0269&from=EN). Here too, it is worth referring to Public Health England's "Evidence update" from 2015 which shows that there are very few unintended severe poisonings: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457102/Ecigarettes_an_evidence_update_A_report_commissioned_by_Public_Health_England_FINAL.pdf

The addictive properties of nicotine itself is also a widely debated topic. To date there is little or no evidence of nicotine dependence that has occurred without the use of tobacco. This is because nicotine itself is assumed not to be able to create dependency, but interaction with other substances in tobacco is required to create dependency (see https://nicotinepolicy.net/karl-fagerstrom/520-dependence-on-tobacco-and-nicotine). A relatively strong support for this among scientists exists and millions of e-cigarette users report that they feel less dependent on e-cigarettes than the cigarettes. Professor Robert Molimard summarizes the scientific knowledge about the actual effects of nicotine on smokers here: http://www.formindep.org/The-myth-of-nicotine-addiction.html#report. This also provides support for concluding that a transition from e-cigarettes to cigarettes is highly unlikely.

2.2. Objections to the smoking ban and the ban on advertising Incorporating e-cigarettes in the general smoking ban can, as explained above, not be justified by a need to protect the environment for health reasons. It should, however, be up to the individual homeowners to regulate this. A restaurant owner is such pretty free, as far as I know, to make their own rules for example about how guests must be dressed. Likewise, they should be free to ban the use of e-cigarettes in their premises if they believe this is a nuisance to other guests.
English health authorities recommend businesses to not force users of e-cigarettes to go outside with smokers to vape as this can lead to relapse to smoking. This sounds very reasonable, and it is again a great encouragement to replace cigarettes with a less harmful alternative if you can use this indoors and in places you normally can not smoke. There are many stories about smokers who just tried e-cigarettes to curb nicotine cravings in situations where they are not allowed to smoke (eg. on airplanes or airports) and have ended up quitting cigarettes completely. These are often called "accidental quitters" and is a common phenomenon.
I observe that the ministry considering proposing exemptions from the advertising and display ban when it comes to e-cigarettes. This is good. If we want as many people as possible to quit smoking it should be possible to promote e-cigarettes. It should also be legal to inform customers that e-cigarettes means a much lower risk than regular cigarettes.

2.3. Objections to the registration requirements
The requirement for registration of all products including all varieties of both e-liquid and electronic cigarettes shows that the regulatory body have very low knowledge about the market to be regulated. The fees proposed are based on an assumed record of approximately 200 products that are based on projections from Denmark. The same applies to cost estimates. It is evident that the ministry has not made any investigations on their own or tried to understand the present market.

When it comes to e-liquid, the way I read the proposal, one will have to register each nicotine strength for each variant. E-liquids are often sold in 4-5 different strengths. This means that 40-50 different varieties of e-liquids will count as 200 products. This is no more than the range one finds from 2-3 producers. In many cases, manufacturers also have a selection of over 50 different flavors.

When it comes to e-cigarettes and equipment, over 20,000 products currently exists. A Norwegian dealer stated that they have approximately 1200 different products in stock. Of these probably more than half will be replaced within six months because they are outdated. Many manufacturers also produce a very limited number of items, so-called high-end products. None of these will be sold in Norway under such conditions. It goes without saying that you will not be able to make any money if you have to pay 47600 NOK to register a product that you usually sell around 10 units of. A processing time of six months we also see is a hopeless hurdle to get over, when a very large part of the products are outdated and replaced with new, improved versions by that time. One can also mention that if the government had allowed the state to take a large part of the estimated cost of around 10 million that these fees are intended to cover, this would have been an investment in public health who had paid for itself many times in a short period of time. The Directorate of Health has estimated that smoking costs society between 8 and 80 billion a year (https://helsedirektoratet.no/Lists/Publikasjoner/Attachments/90/Samfunnsokonomiske-kostnader-av-royking-en-vurdering-av-metodikk-og-kostnadenes-storrelsesorden-iS-1825.pdf) and it is obvious that if we can get more people to stop by using e-cigarettes this will lead to enormous savings. In this context, 10 million is a really small number.

It is obvious that the fees presented here will eradicate much of the market, as there are costs that make it impossible to operate in the market. The few who have the resources to cover these fees are large companies, mainly the tobacco industry with its so-called "cig-alikes". The tobacco industry is currently losing the market to independent producers but with such regulation their competition will largely disappear and tobacco giants will be left with the entire market virtually alone.

It is not the tobacco industry that drives innovation in the e-cigarette market. This is done by independent companies which are striving, not only for high performance, but also a high degree of product safety. This innovation and the desire to develop ever safer and more effective products will be seriously hampered by such a scheme with such consts. It also appears meaningless that all EU countries should have their own registration systems instead of a joint one.

A solution where manufacturers and importers must register and be responsible for that regulations are followed without recording every single product had been much more appropriate. The independent industry could then continue to exist and innovate.

2.4. Objections to product requirements
The maximum nicotine content of 20 mg / ml is inappropriate. Many smokers who want to switch to vaping will not experience this as satisfactory and this will lead to many more unsuccessful attempts to quit. In addition, different types of equipment produces different amounts of vapor and thus more or less nicotine is delivered. In more advanced models often used by more experienced vapers lower nicotine content is used since more vapor is produced. In models for beginners, which is the ones most often used when attempting smoking cessation, much less vapor is produced and the need for higher nicotine content is present. 36 mg / ml has traditionally been the highest content in the ready mixed liquid, but newer models that are specifically designed to get the over the first "hurdle" also contains even more than this to deliver enough nicotie with an even smaller amount of vapor. The limit of 20 mg / ml is justified by surveys that show that most people who vapes today use lower nicotine content than this. This is correct because all experience indicates that vapers gradually lowers their preferred nicotine content, partly because addiction becomes weaker and partly because of better equipment. Thus, this limit will most likely not lead to many of todays vapers relapsing to cigarettes, but it will be serious barrier for current smokers that want to switch.

The limit of 10 ml for refilling containers also appears to be inappropriate and will only lead to increased costs for consumers without providing greater product safety. The possibility that the small bottles are left lying around, accessible to children and pets, are at least as great as the larger bottles, if not greater. A requirement for child safety of the bottles is appropriate but the size limit like this will provide no noticeable security gain. Many household products are much more dangerous than e-liquid and come in larger containers and these should of course be kept out of reach of children, regardless of the size of the bottles. The same applies to the limitation of 2 ml for disposable cartridges. This will make e-cigarettes less user friendly, and decrease the chance of quitting, without causing any security gains.

The rules for refilling mechanism is unnecessary and will not provide any significant benefit to safety. As mentioned above, the potential for poisoning by getting nicotine liquid on the skin is quite exaggerated and even at concentrations far above 20 mg / ml will not cause any noticeable effect if a few drops are spilled on the skin if you wash this off quickly.

2.5. Objections to the requirements of user manual and labeling
The requirement for manual in Norwegian should apply to products produced in Norway, but it should also be opened for the English manuals. To oblige foreign producers to make Norwegian versions of the instructions could lead to so much more work and higher costs that one refrains from selling to Norway and we will thus have a narrower range of products, which in turn will lead to fewer people finding the model that makes them able to quit smoking.

The requirements on labeling also seems poorly conceived. Health warnings will indicate that this product is as harmful as smoking and will not encourage people to quit smoking. It also seems very out of place to have a reference to slutta.no on e-cigarette accessories.

3. Consequences of over regulation
As mentioned earlier e-cigarettes represent a health revolution that we seldom see the likes of. Today's market is developing rapidly and more and more efficient models are released rapidly. In addition, there exists a commitment and enthusiasm for the products that we've never seen before for a product that is intended for smoking cessation. A regulation like the one proposed here will, as I have described, slow the progression and force a large portion of today's players out of the market. This will lead to the loss of jobs and income to the state, fewer people will be able to quit smoking, more people will start smoking and we have a net negative effect on public health.

With high probability this regulation, and other countries' corresponding regulation of e-cigarettes, will lead to that in a few years only a few large rich players will be left in the legal market. This is mainly the tobacco giants. In addition there will be a huge black market where safety and health will not be the driving factors to the same extent that we see today. Many of the players in this market will probably be idealists who is currently operating in the legal market. This means even the black market will in all probability paradoxically contribute positively to public health, but in the black market we will also see forces pulling the other way.

4. Summary and Conclusion
The proposed regulation of e-cigarettes appears to be completely unfit for purpose, which must be to improve public health and save lives. It is pointless to regulate products that help people quit smoking, are demonstrably much less harmful than tobacco and which in addition contain no tobacco by including them in the tobacco act. E-cigarettes represent an enormous opportunity to save millions of lives worldwide but regulation such as the ones presented here will be a serious obstacle to this. E-cigarettes should either be governed by a separate own regulation scheme or under current regulation of foodstuffs and electronics products.

The government should also reconsider its introduction of standardized snus cans and cigarette packets as the figures and surveys that exist today shows that this will have little or no effect. Working with a sensible regulation of e-cigarettes would have been much better use of resources.

It emerges very clearly that the proposed regulation of e-cigarettes is an implementation of the EU's new tobacco directive on those points. Although Norway has a tradition of introducing EU directives in spite of that we are not members, it should be expected from our elected representatives that they make a thorough analysis of the impact of such directives. There are examples of misguided directives and perhaps the best and most relevant in this context is the EU's ban on snus. Again, we can look at the statistics and see that the the countries that have exemptions from this prohibition (Sweden) are destroying the other countries on the cancers statistics. Although many of our elected officials have been out in the media claiming that we are committed to implementing the EU's tobacco directive this is not true. We have our full right to reserve ourselves against this and we should do it in this case. I expect from our elected representatives that they manage to put the Norwegian people's lives and health in front of strawberries and champagne in Brussels and withstand pressure and threats. Take this opportunity to show that Norway is a pioneer where we are able to think for ourselves and not let us influence by they tobacco and pharmaceutical industry lobbyists at the expense of public health.

This regulation proposal show strong signs of lack of knowledge about the fields to be regulated. I will persistently ask Health and Care reconsider this regulation and obtain knowledge that can enable them to regulate in a way that allows us to benefit from the lifesaving potential of e-cigarettes. This knowledge exists, even here in Norway. Researchers from SIRUS that are now incorporated in NIPH has massive amounts of knowledge, but one must not forget the users who are organized into NDS.

5. My Story
Finally, I will briefly share my own story and experiences with the transition from cigarettes to steaming. I am now 36 years old and 4-5 years ago I saw someone using an e-cigarette in a movie trailer. I began to research online and tried some models, with and without nicotine. Finally I found a model that suited me well and e-liquid with enough nicotine that enabled me quit smoking the day I got it. Since then I have never looked back.

As a smoker my health was ailing to say the least. I coughed and spluttered almost all the time, I was overweight, much because I was not able to engage much in physical activities and my kids were probably pretty worried. After I switched to I noticed that my breath and stamina recovered quickly. I was able to start exercising and eventually I ended up being able to run long distances and not at least come along with the kids on skiing and hiking. Now I am in relatively good physical condition, have no problems with coughing or breathing and the frequent 3-week colds which virtually replaced each other when I smoked is completely gone. I have not been home sick from work for one single day since I switched to vaping.

For me and many others vaping have not only been a means to stop smoking. It has become a hobby and a committed and enthusiastic community has sprung around the products. This is also one of the reasons why vaping works. With traditional smoking cessation products you remove the cigarettes that for many represents both coziness and relaxation without replacing it with anything. Vaping replaces the physical act of smoking and many users also feel they get a community and a hobby in addition that helps one keep cigarettes away long enough to prevent a relapse.

Ever since I started with vaping I have followed developments in the industry, politics and research and would say that I have pretty thorough overview of how the market and the community work and the research that has been done.

Public Health England estimated that the vaping is at least 95% less harmful as smoking. At least. That does not mean you necessarily get 5% of the harm. My own experience suggests that this figure could well have been higher than 95% and many other vapers I've talked share this view. I often see people crying out for evidence that vaping works and actually helps people quit. There are now millions of living proof! I am one of them.

The role of e-cigarettes in the tobacco endgame

A lot of the provisions we see in both the FDA deeming regulations and the EU TPD that are currently starting to hit the vaping industry and community these days are all about protecting non-smokers from this horrible thing that is vaping. Be that never smokers or former smokers,. And the most important ones to protect are our kids and teenagers. Think about the children!

In July Karl Erik Lund, Research Director of the Tobacco Unit of the Norwegian Institute of Public Health published a commentary in "Nordic Studies on Alcohol and Drugs" (The Journal of Nordic Centre for Welfare and Social Issues), from which I stole the title of this post. In his commentary he asks some very important questions, and gives us some thoughts on what he thinks is the most plausible answers.

Have e-cigarettes the ability to make the virtual elimination of cigarettes a realistic future target? I would say yes, through two possible mechanisms: by increasing smoking cessation and by reducing smoking initiation.

Karl Erik Lund has years of experience in the field of tobacco research, and backs up his answers referring to current research. A lot of this is not really surprising either... to me it feels like just good old common sense and logical reasoning. You see it's not only about finding answers, it's also about finding the right questions. This is where I believe (and I think Lund would agree based on reading his commentary) the regulators have failed miserably, or they have intentionally avoided asking these questions: What do we want to protect the children from, smoking or vaping? Will the provisions in the regulation schemes reduce smoking initiation? They say they want to protect non-smokers, but what do they want to protect them from?

The Swedish study that Lund refers to shows that use of e-cigarettes among adolescents is associated with many of the characteristics that also predispose for smoking onset (not living with both parents, disliking school, low socioeconomic status, alcohol use). In other words, it is very likely that a large portions of never-smoking e-cigarette users would have started smoking if e-cigarettes were not an available alternative. In the US we've seen numbers showing that imposing stricter age limits on e-cigarettes will in fact make more teens smoke cigarettes instead. Clive Bates also discussed the unintended consequences of these regulations not long ago here: Harmful and negligent to ignore unintended consequences of e-cigarette policies. So by making the safer alternative less available, are we really protecting the children? Don't even think about giving me some crap about the gateway theory, we all know that's not something that happens in the real world.

With all this in mind, another question comes up, and I guess it's a controversial one: What is the best age limit for buying e-cigarettes? Or even, should there be one? Just asking these questions will surely give you some ugly looks, not only from regulators and the anti-e-cig-movement (they'd probably be furious) but also from e-cigarette advocates, manufacturers and vendors. Here in Norway at least, it seems that everyone on both sides of the table agrees on an 18 year age limit. We do not want our children vaping.. period. And I've agreed on this in many a discussion as well. What bothers me, however is this: We know that imposing an age limit will increase smoking initiation and we know that the gateway theory is just a product of the ANTZ's imaginations. In addition to that, setting the age limit for buying e-cigarettes to the same as for buying cigarettes will lead a lot of current smokers to believe that there are similar risks associated with e-cigarettes which will discourage them from swapping. Instead of being a gateway to smoking, e-cigarettes seem to (again, common sense) work as a roadblock or firewall protecting youth from cigarette addiction. So I've come to the conclusion that putting the same age restrictions on e-cigarettes as we have on regular cigarettes is not a good idea. To be honest I'm struggling to come up with good arguments to why we should have such an age limit. To me it seems almost like putting age limit on condoms and assume that would stop kids below that limit from having sex. An age limit on e-cigarettes should at least reflect the relative risk, so setting the limit to the same as for energy drinks containing caffeine sounds more reasonable to me ... if we want e-cigarettes to play a big part in the tobacco endgame like Karl Erik Lund suggests in his commentary. That is what we want right?

Worth reading this weekend (August 12th 2016)

This week the FDA deeming regulations came into effect and you've probably read a lot about it already. The most immediate effects of this right now seems to be the following:

• Product innovation have been de facto banned in the US, as no new products are allowed on the market without investing a gazillion dollars in a Pre-Market Tobacco Application. That will probably be great for product safety right? And if you're not able to pay a gazillion dollars to get your products approved within two years you'll have to take them off the market.
• Vape shop owners are not allowed to help their customers use the equipment properly. Another great thing for product safety...
• Manufacturers and vendors are not allowed to tell people the truth about vaping: it can dramatically increase your chances to quit smoking and thereby save your life. 
• There are probably more, but I think it is so blindingly obvious that those three effects will not save lives but cost lives that it proves beyond all doubt that the FDAs motives for doing this has nothing to do with health... at all.

Anyway, here is some more reading for you this weekend, some of it about the FDA regulations and some about ...

• The Unintended Consequences Of Vaping Regulation - Guide to vaping highlights the stupidity of the FDA regulations. 

• FDA shoots itself in the foot, cigarette trade celebrates, public health loses - a summary in two quotes - Clive Bates does the same...

• If teens are going to smoke, better it be an e-cigarette - Colin Mendelsohn makes some excellent points about vaping teens in the Daily Telegraph:

It is quite possible that e-cigarettes are contributing to this rapid fall in adolescent smoking rates. Young people who experiment with e-cigarettes may otherwise have smoked if e-cigarettes were not available.

• Nearly 70 percent of European vapers have quit or reduced smoking - On Dr. Farsalinos latest study. Came out a while ago but still worth a read if you haven't read it yet.

Have a nice weekend!

Introducing the Vaping Giraffe Facebook page

Today I'm launching the new Vaping Giraffe facebook page. Why haven't I done this before you say? I have no idea to be honest, but it's here now :) I'll be linking to all my post on this page from now on and in time maybe there will be more as well.

I'll also shut down the opportunity to post anonymous comments directly on the blog from now on, since mostly there is only spam getting posted anyway. I'll leave the logged in options open for now, but I encourage people to use the Facebook page for comments and discussions. Oh... almost forgot: There will be Vaping Giraffe t-shirts available as well :)

Hope you guys like the new page and feel free to leave a message in there.

Worth reading this weekend (August 5th 2016)

Picture from Facebook (senronjohnson)

It's been a while now since my last post. I have been on vacation, visiting Denmark to see my kids play football (that's soccer for you Americans), but that's not the only reason I've been kind of silent. To be honest I've scratched my head a bit trying to figure out something interesting to write about without repeating myself over and over again. I mean, there are of course some interesting stuff going on in the world of vaping. The FDA is trying to destroy vaping and they're being sued by several parties for this. The development in the UK and New Zealand is quite interesting to follow as well, and not depressive as what is happening in the US. But here in Norway, and Scandinavia I guess, it's kind of quiet at the moment. Here in Norway we're currently waiting for answers to the request for comments on the new tobacco act proposal to start ticking in. The deadline is set to September 26th. Some answers have come in but the ones that will really matter is not there yet, like from NDS (Norwegian Union of Vapers), the Institute of Public Health and so on. I talked to the owner of a vapeshop I visited in Hjørring, Denmark, during my vacation and from what I could understand the situation in Denmark is pretty much the same. I'm not sure if they've passed the law yet (feel free to comment if you know) but it's a lot of the same as in Norway... TPD and horrible fees to register products to sum it up really quickly.

So since it's a bit quiet and not that much to report from Norway at the moment, here's some interesting reading for you this weekend:

• A strong case to overturn the EU snus ban - 10 reasons why legal action should succeed this time - Interesting on snus by Clive Bates. The way I see it, if the ban on Snus in the EU is lifted it is a victory for harm reduction strategies and that is good for vaping as well.
• Terry Barnes – Kiwis have got it right on vaping, leaving Chapman fuming - Good article on the situation in New Zealand. A confused and frustrated Chapman is good news in itself if you ask me.
• If you want to read up on the FDA situation in the US here's a couple of nice ones:
  - Senator Ron Johnson Challenging FDA Vaping Regulations (part five)
  - How The New E-Cig Rules Hurt Americans
  - FDA e-cig regulations deemed ‘incomprehensible” by Forbes Magazine

Have a nice weekend!

Norway status update: The Norwegian government don't understand the vaping market

About a month ago I wrote about the new Norwegian Tobacco Act proposal, which is basically the Norwegian implementation of the TPD. On July 1st the government published a request for comments and a some more details in the consultation document (in Norwegian only). The is not that much new information in the document, it's basically just repeating the flawed reasoning behind a lot of the proposed changes as I've discussed earlier. There are, however, some more information on the planned registration scheme, and they've suggested some numbers.

First of all, in order to sell tobacco products over the internet, or actually in any way that means sending the products to the customer, the vendor has to register with the health authorities. They also need to appoint a person, in Norway (from what I can understand), that is responsible for making sure the products meets the product requirements before they reach the customer, and they need to have a system that makes sure the customer is over 18 years old at the time they order. I addition to this, anyone delivering the products must have a system in place for checking the age of the customer, meaning it needs to be handed over to the customer in person. The registration fee is set to 2500 NOK ($295 using current exchange rate) at the time of registration and 1000 NOK ($118) every year to stay registered. From what I can see this goes both for cross-border and domestic sales. These fees doesn't seem that bad to me to be honest. When it comes to the requirements for anyone delivering it, my guess as of now is that this means we have to go pick up our packages at the post office (which we already do in quite a few cases where they're too big to fit in the mailbox), and we have to show some ID verifying our age when we do. At least for packages going through the Norwegian Postal service I don't see a problem with this, they've already got a system for checking age in place as they do this when delivering alcohol that can be ordered from the government owned alcohol retail monopoly (yeah, we have that here in Norway). I may be wrong though and these provisions may be intended to work in another way, but if I'm right I don't think this part will be a major problem for vendors or vapers.

The above mentioned rules will affect all tobacco products, not just e-cigarettes. Then there are some e-cigarette specific proposed rules that probably be a lot worse to live with. From what I've read most, if not all, EU countries implementing the TPD will require every vaping product to be pre-market approved and registered, and of course this goes for Norway as well. The product requirements are the ones we all know from the TPD by now, which I've gone through in my last post about this, so I'm not going to do that again in detail. It is worth mentioning, however, that a user manual in Norwegian with quite a few specific requirements (warnings, toxicity information, the width of the filling holes to make sure the user use the right kind of bottle etc.) is required, as is some health warnings and a reference to Slutta.no, which seems kind of weird to me as this is a national stop smoking service which have a history of not recommending e-cigarettes. Products need to be registered 6 months before they are put on the market. The application for each product needs to contain information about the contact person responsible in Norway, all ingredients, toxicological data on the ingredients and the emissions, how much nicotine is delivered, the components of the product, the production process, the manual and a statement where manufacturer takes full responsibility for the products quality and security under normal circumstances. It is the manufacturers and importers of the product that needs to register the product... and pay the fees. And the fees that they propose here are one of the big problems. To register a product you need to pay 47600 NOK, thats $5616. If you make a significant change or update to the product (what this means remains to be seen) the fee for registering the change is half of this, 23800 NOK ($2808), and on top of this there is an annual fee of 18850 NOK ($2224). The registration fee is set to cover the Norwegian Medicines agency's costs that are estimated to around 9,5 million NOK and an estimate of 200 new registrations in 2017. Anyone with just a tiny bit of knowledge about the vaping market today can see how wrong this is. First of all, where on earth did they get the 200 number? I talked to one of the vendors in Norway about this an he has around 1200 products in his store and estimates that there is around 20000 products on the market and maybe 10000 more each year. I don't think he overestimates... at all. Then I asked in my local shop how many Kayfun 5s he'd take in if he was to take that product in... "maybe 3 or 4", he answered. Then... how many of the products that you could buy 6 months ago is still on the market with no changes? My friend, the first vendor I talked about, told me he had removed 300 products so far this year... cause they're out of date. I guess you can all see where I'm going with this. This would basically mean no high end products cause you would just loose money trying to sell them in Norway and not much innovation going on cause making improvements to a product will cost you a lot. Big Tobacco and their far from innovative cig-alikes, however, will thrive under such regulations as their much more effective competitors are effectively shut out of the market. These ridiculous fees are based on totally wrong assumptions and shows that the government has no understanding of the market they are trying to regulate, which in my opinion should be one of the basic requirements for a regulator... understanding the market that is.

The Norwegian Government are blowing their own trumpet, claiming that they will now allow e-cigarettes to save the lives of many smokers. They claim that their regulations will just make sure that the products are safe... and of course that they fight heroically to make sure no children or teens start vaping. But again, through this document, and their proposals, they show that this is not about health, it's about money. They focus on how they are going to cover their losses. However, to me it seems like they fail totally at seeing the bigger economical picture as well. The Norwegian Directorate of Health have estimated that the annual costs of smoking in Norway is somewhere between 8 and 80 billion NOK. Now even if we subtract sin taxes of 7 billion a year there is still a lot of money to be saved here. The Directorate estimates savings of 2-3 billion NOK every year for each percentage point the smoking prevalence goes down. Then compare their cost of 9,5 million to these numbers... it's peanuts. If the government had decided to cover most of this, just leaving the fee at a reasonable amount, enough to make sure they are not encumbered with a gazillion unrealistic applications, it would have been the best investment they would have made ... ever. The problem I think, is that current government probably will not see the result of their investment while they are still in power. So they work hard to make it look like they're actually doing something for health, when in fact the best thing they could have done for public health right now, is close to nothing. Vaping wasn't big pharma's idea, it wasn't tobacco control that came up with it and it certainly wasn't the government. I think that is what they all have a problem accepting.

New Norwegian Tobacco Act proposal based on lies and misinformation

On Friday the Norwegian Government published their proposed changes to the Norwegian Tobacco Act. The proposal is available in Norwegian here and there are no big surprises here since Minister of Health, Bent Høie, presented the most important changes on a press conference the week before. I wrote about this last week here: Norway status update: Plain packaging and e-cigs regulated as tobacco

As the title of the proposal says, this is the Norwegian Government implementing the TPD and plain packaging: Amendments to the Tobacco Act (implementing Directive 2014/40 / EU and standardized tobacco packaging).

"The Government proposes that the current ban on the sale of e-cigarettes is repealed. We want to make e-cigarettes available to smokers who want a harm reduction alternative", said Minister of Health and Care Services Bent Høie.

So why do you propose amendments to the law that will have the opposite effect then, Høie? I've been reading through the proposal and as I said, no big surprises. This is the TPD with the limitations on nicotine content, bottle and tank size, advertising ban, pre-market registration and also a ban on vaping wherever smoking is banned. The published proposal contains a walkthrough of all the proposed provisions where they also list some of the answers they got from the hearing that was held. Although a quite a few of the critical answers, mainly from SIRUS (The Norwegian Institute for Alcohol and Drug Research) and NDS (Norwegian union of vapers), are included it is pretty obvious that the Ministry of Health choose to ignore these. The Ministry puts forward claims of risks that are not proven at all and shows little understanding of how vaping works.

The Ministry's justification of the tank and bottle size is based on a risk of poisoning that is totally blown out of proportions and of course they push the children in front of them as usual. They also refer to the "C-477/14 Pillbox"-case in the EU court of justice, which concluded that the size limits are justified because of the risk of poisoning, and list a bunch of numbers supposed to back this up. They even claim that leaking tanks may lead to a lot of poisoning, totally exaggerating the actual risks saying that "Nicotine is absorbed rapidly through the skin, and contact with skin can cause poisoning. There is thus a significant immediate risks associated with the use and handling of e-cigarettes". I'd be happy to empty one of my tanks, I think my biggest one is 7ml, on my skin to demonstrate that these risks are totally blown out of proportion. I've spilled a lot of e-liquid on myself without even noticing the effect. Of course you shouldn't do this on purpose, but the point is, you won't die if you accidentally spill some e-juice on yourself, even if it's 36 mg/ml, and you most definitely will not notice any terrible effects from a tank seeping liquid like the ministry seems to think. The justification for 10 ml bottles is also the poisoning risks, which makes no sense at all. There are a lot of household products that are immensely more dangerous than e-liquid and there are no bottle size cap on these now are there? You have to put a child-proof cap on them (I think), which is fine, but the rest of the responsibility for treating the product in a responsible, adult way is left to the user. There is no reason why e-liquid should be handled any different. Besides, there is no logic in thinking that smaller bottles will decrease the risk of children getting hold of it an accidentally getting poisoned. I'd say it will increase this risk as these bottles are much more likely to be left unattended, lost and so on.

When it comes to the nicotine content cap of 20ml/mg, they also use poisoning risks as justification for this. They refer to the EU commission saying that the most used e-cigarettes have a nicotine content lower than this. This shows that they have not bothered listening to what vapers are saying... at all. The point here is that a lot of smokers wanting to switch starts out with higher content and then gradually lowers it. This means that the nicotine content in the majority of e-cigarettes will be lower and lower as time passes since we'll have more and more long-time vapers that are using a lot lower nicotine content, pulling this number down. Høie claims he wants to make e-cigarettes a harm reduction alternative to for smokers, but this limit will work strongly against this. The 20 mg/ml nicotine cap is a limit that most people that already vape today will be quite fine with. I usually vape 6 mg/ml. In other words, this limit will probably not drive many vapers back to smoking, but it will severely limit the number of smokers that are able to switch.

I'm also sad to see the damage done by the Norwegian Institute of Public Health (NIPH) in this matter. Høie and his ministry puts a lot of faith in the report NIPH published a year ago on "Health risks associated with the use of electronic cigarettes". I wrote back then that this report will cause more harm than health. This report is actually a really strong documentation that there are very little harm in e-cigarettes, it basically concludes that harm from all substances in vapor are negligible... except nicotine. The report totally exaggerates the risks of nicotine, especially in second hand vapor, and now we see the damage done by this. This report and it's totally wrong conclusion on how the nicotine in second hand vapor affects people is now the justification that the Ministry of health uses for the ban on vaping wherever smoking is prohibited. The report concluded that the nicotine content in second hand vapor is about the same as in second hand smoke, which is true, and hence it will cause harm to bystanders... which of course is not true. It's a lie. Nicotine has never even been mentioned as a potential problem when second hand smoking. Dr. Farsalinos demanded that NIPH retracted these false statements, because "such a levels is not only harmless but has absolutely no biological effect, even according to the strictest regulatory definitions". When answering Farsalinos they just repeated that the levels of nicotine in second hand vapor was the same as in second hand smoking, totally missing the point, something that Farsalinos told them straight out here. It seems that NIPH just ignored this last request from Farsalinos and I think I remember them just dismissing this with some statement that this might be a questionable conclusion but that it was just a small part of it and so on and so on. Well now it turns out that the whole ban on vaping in Norway is resting on this misinformation by the NIPH. Ultimately, by refusing to retract a statement they know very well (or should know at least) is wrong, the NIPH is responsible for a lot of premature deaths. Being able to vape where you cannot smoke would have encouraged a lot of smokers to switch, or at least try e-cigarettes, which in turn might have turned them into accidental quitters.

I could go on about the lies and misinformation that the government use as justification for the proposed changes to the law for quite a while. A lot though is based on the alleged risks of nicotine. It seems to me, even if there is some concerned expressed about other substances and they want a lot of reporting to monitor this, that nicotine is the main concern. And all of this is based on an old lie, that nicotine by itself is very addictive. This is one of the reasons that the gateway theory also lives and gives the government reason to protect the children from e-cigarettes that they still seem to believe can tempt our teens into a life long cigarette addiction.  

It is the Ministry's opinion established knowledge that nicotine is among the most addictive substances contained...

There is no evidence, or indication, that nicotine without tobacco is very addictive. I've discussed this with my friends Sanner and Grimsrud earlier and they could not come up with anything either... other than "this is well known" and a reference to the old lie. As you can see above, the Norwegian Ministry of Health didn't even bother to refer to science at all, it's just common knowledge. For some reason the evidence that nicotine by itself is not very addictive never seem to get much publicity, but try to do a google search and you'll get a lot of good hits. Today most real scientists agree on this as well, but still the old lie seems to be believed by most people. Sad but true.

In addition to all this the government intend to registration and reporting systems to monitor and control the market. This means everyone wanting to put any e-cigarette product on the market in Norway, be it cross-border or not, will have to register the products 6 months in advance. Exactly how this will work and what will be needed to get their products approved is not quite clear, but what is clear is that the government intends to charge fees to get approved. Which of course will limit the availability, slow down innovation of safer products, drive costs through the roof and again, smokers are the ones that have to pay for this with their lives.

When it comes to the advertising and sponsoring ban, things are a bit more fuzzy. I'm not an expert on reading these kind of texts thought, but what seems clear is that sponsoring, that's free giveaways, will be prohibited. Vending machines are also included in that paragraph for some reason. It also seems like advertising will be banned but a representative from governing party FRP said last week that e-cigarettes will not be affected by the display ban so vendors will be allowed to display their product in stores. Then the whole paragraph about advertising and sponsoring ends with this:

Regarding the proposal for exceptions for e-cigarettes from the display ban and the ban on advertising, the ministry aims to follow up this issue in the regulations.

Again, I'm not an expert in reading this, but I think this means it will not end up in the law but rather as regulations in addition to the law which means it will be a lot easier to change later on. I think I'll just get back to that later on if I can figure out or get someone to explain what it will actually mean. (Any expert on Norwegian law, feel free to comment)

I discussed in my post last week how the Norwegian government justify their plain packaging by referring to the lies of the Australian government. Their implementation of the TPD is mainly justified by the myth of nicotine addiction and grossly exaggerated risks of poisoning. Sadly, it seems like these lies are extremely hard to get rid of. To be honest I don't think that it matters much to Høie and the Ministry of health whether the myth is busted or not, cause to them they are just excuses. What this actually is all about isn't really the Norwegian government working to improve public health as much as possible, this is about the Norwegian government making the EU happy... nothing more. But that doesn't mean we will stop fighting to expose the lies ... and eventually they will regret this when the heads start rolling.