Comments to WHO on Tobacco Harm-Reduction Products | Citizens Against Government Waste

Comments to WHO on Tobacco Harm-Reduction Products

Agency Comments

May 16, 2018

World Health Organization
Independent High-Level Commission
On Non-Communicable Diseases

Re: Comments on May 1, 2018, First Draft Report

Citizens Against Government Waste (CAGW) appreciates the opportunity to comment on the World Health Organization’s (WHO) Independent High-Level Commission’s on Non-Communicable Diseases (NCDs) May 1, 2018, First Draft Report.

CAGW is a 501(c)(3) private, nonpartisan, nonprofit organization representing more than 1 million members and supporters in the United States. CAGW’s mission is to eliminate waste, fraud, abuse, and mismanagement in government. Founded in 1984 by the late businessman J. Peter Grace and late Pulitzer Prize-winning columnist Jack Anderson, CAGW is the legacy of President Ronald Reagan’s Private Sector Survey on Cost Control, also known as the Grace Commission.

The WHO is concerned with the lack of progress on combating and reducing NCDs, which lead to premature death. As a result, the WHO established the NCD Commission, which is charged with “identifying bold recommendations to enable countries to curb the world’s biggest causes of death and so extend life expectancy for millions of people.” The commission has been asked for recommendations “on how to intensify political action to prevent premature death from cardiovascular disease (stroke and heart attacks), cancers, diabetes and respiratory disease, reduce tobacco use, harmful use of alcohol, unhealthy diets, and physical inactivity, and promote mental health and well-being.”

CAGW is pleased that the commission recognizes the well-established role of the private sector to influence health outcomes. The commission is considering that a “fresh working relationship must be established with the food, non-alcoholic beverage, restaurant, technology, and media industries, with the aim that all countries benefit from public-private partnerships that promote health and behavior change.”

CAGW has noticed that the tobacco industry is not included in the list of private-sector entities with which the commission wishes to engage. Nowhere are electronic cigarettes (e-cigarettes), vaping, or the use of other tobacco harm-reduction products mentioned as effective tools to switch smokers to less risky nicotine delivery devices. Perhaps this is simply an oversight in the draft report, since many tobacco companies have introduced harm-reduction products. It is well known that smoking cigarettes is one of the main risk factors for several chronic diseases, including cancer, respiratory diseases, and cardiovascular diseases. Millions of smokers have been switching to e-cigarettes and other harm-reduction products for some time as a way to avoid cancer, as well as respiratory and cardiovascular diseases caused by combustible cigarettes. These techniques are well-established worldwide.

A Chinese pharmacist and smoker, Hon Lik, has been credited with producing in 2003 the first commercially viable electronic cigarette (e-cigarette), or vaping device, after his father, who also smoked, died of lung cancer. In 2006, e-cigarettes became available in Europe and Americans were introduced to these devices in 2007. These alternatives to smoking have become popular because they help people avoid the harmful consequences of inhaling a litany of poisonous chemicals, like tar and carbon monoxide, that cause heart and lung diseases, as well as cancer. Since 2003, vaping and similar harm-reduction tobacco products have become a cultural phenomenon. World-wide sales grew from $20 million to $10 billion between 2008 to 2017.

Governments are beginning to recognize the benefits of having smokers move away from smoking cigarettes and utilizing non-combustion tobacco products instead. England is leading the way on e-cigarettes and similar tobacco harm-reduction products. In April 2016, the Royal College of Physicians released a report that concluded e-cigarettes appear to be an effective aid to quitting smoking; that any health hazard arising from vapor inhalation is unlikely to exceed 5 percent of the harm from smoking tobacco; that evidence available today indicates that e-cigarettes are being used almost exclusively as a safe alternative to smoking; and that in the interest of public health, it is important to promote the use of e-cigarettes.

While many countries ban e-cigarettes and others impose severe penalties, including fines and imprisonment, these polices are slowly changing as studies demonstrate e-cigarettes present far less risk than smoking. In 2017, New Zealand completely reversed its position on these devices and will allow them to be sold and imported legally.

In July 2017, England’s Department of Health (DOH) announced is tobacco-control plan, “Towards a Smokefree Generation,” to cut smoking rates. England recognizes that while the nation has made great strides in reducing smoking rates there is much more to do. Smoking continues to remain high among those who already suffer from poorer health and are the lowest wage earners, with even higher rates in people with mental illness. Part of the DOH’s strategy to achieve a smokefree generation is to “help people to quit smoking by permitting innovative technologies that minimise the risk of harm” and to “maximise the availability of safer alternatives to smoking.”

The DOH noted that, “Two thirds of smokers say they want to stop smoking, however long-term success rates are low. Despite the availability of effective medicines and treatments to support quit attempts, the majority of smokers choose to quit unassisted, by going ‘cold turkey’. This has proved to be the least effective method. Smokers who use a combination of medication and expert behavioural support are up to four times as likely to stop smoking successfully as those who attempt to quit unaided or with over the counter nicotine replacement therapy.”

Furthermore, the DOH recognized that “the evidence is increasingly clear that e-cigarettes are significantly less harmful to health than smoking tobacco. The government will seek to support consumers in stopping smoking and adopting the use of less harmful nicotine products. Public Health England [PHE] has produced guidance for employers and organisations looking to introduce policies around e-cigarettes and vaping in public and recommend such policies to be evidence-based. PHE recommends that e-cigarette use is not covered by smokefree legislation and should not routinely be included in the requirements of an organisation’s smokefree policy.” (emphasis added)

The United States Food and Drug Administration (FDA), under its authority within the Family Smoking Prevention and Tobacco Control Act, is also taking a new look at non-combustible tobacco products such as e-cigarettes. The agency is currently reviewing Pre-Market Tobacco Applications (PMTA) and Modified Risk Tobacco Product Applications (MRTPA) for Philip Morris’s IQOS, an innovative heat-not-burn tobacco product. Studies show that the product significantly reduces the production of harmful and potentially harmful chemicals

On July 28, 2017, the FDA announced a new regulatory framework to shift the trajectory of tobacco-related disease and death downward and strike “an appropriate balance between regulation and encouraging development of innovative tobacco products that may be less dangerous than cigarettes.”  As a result, the agency delayed the submission of PMTAs for e-cigarettes, until August 8, 2022, recognizing that if current law and regulations are not changed, most of the vaping industry would be unable to comply with the law. Since most vaping businesses could not submit onerous and costly PMTAs and MRTPAs, they would be forced out of business, leaving consumers that have used e-cigarettes to stop smoking in a precarious position.   Efforts are now underway in the U.S. Congress to make this temporary delay permanent so the e-cigarettes can remain on the U.S. market.

In Japan, British American Tobacco’s heat-not-burn technology, GLO, and Philip Morris’s IQOS are extremely popular. These products account for 29 percent of the nation’s tobacco market, versus 16 percent in 2016. Later this year, Japan Tobacco plans to release its own heat-not-burn device.

The WHO and the Independent High-Level Commission must surely understand that there will always be people that undertake risky behavior, including smoking cigarettes. The WHO must also realize that outlawing cigarettes to halt smoking is not a reasonable or viable alternative. The United States tried to stop alcohol consumption in the 1920s to early 1930s, with disastrous results. Prohibition led to black markets and rampant organized criminal behavior.

E-cigarettes and heat-not-burn technologies are growing in popularity and it would be imprudent for the WHO to ignore this trend. CAGW urges the Independent Commission to seriously consider how e-cigarettes and heat-not-burn tobacco products can be used to help people wean themselves off smoking and adopt a less risky alternative. Promoting these policies in the final report will help achieve the WHO’s goal of reducing premature deaths due to non-communicable diseases and save valuable health dollars that can be used to stop communicable diseases.


Tom Schatz
President, CAGW

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