The worst way to avoid public discussion is....

I normally avoid referencing organizations and people by name when I disagree with their position statements or viewpoints. It’s considered bad form, and as I sit on the board of directors for such an organization that is not without it’s own vaping industry controversy, it’s generally a grand invitation to start a very public squabble that would accomplish little beyond providing a “Jerry Springer Show” like entertainment extravaganza for an afternoon.

I am not going to do that today.

On May 7th of 2020, the Canadian Vaping Association published the following tweet, referencing a CVA press release published via GlobeNewswire (1) on the same day:

Figure 1: https://twitter.com/thecvaofficial/status/1258446790225006593

The CVA followed up with a couple of self replies singling out Vype and JUUL products, their high nicotine strength and concealability, and made the following statement (2):

“The UK has not seen a rise in youth vaping as a result of established nicotine limits.”

That is a bold statement to make without citation. It is true that the UK has not seen an elevation of youth uptake to the same degree as North America, however there are a lot of confounding differences in both legislation and public messaging with regard to vaping between the UK and North America that would have an impact on youth appeal. It goes far beyond ‘nicotine concentration’.

It wasn’t long before Clive Bates, Amelia Howard, Gregory Conley, and other vaping advocates from around the globe started weighing in on the merits of the press release and proposed restrictions. Various replies from CVA board members followed ranging from uncited claims, to ‘Sophie's Choice’ style lists of ‘would you rather’, to a particularly snide ad hominem attack on an advocate.

I am going to speak briefly of that gong show and then I am going to poke holes in the CVA’s youth uptake reduction strategy until it looks like the swiss cheese I have always thought it to be.

When questioned: Obfuscate, Ad Hominem, and Double Down

As stated, reaction to criticism of the CVA call was not full of cited data points, quotes, or even well thought out theories. It very quickly devolved to sub-professional levels by folks I would have generally believed ‘should know better’.

Figure 2: https://twitter.com/dashvapes/status/1258988692468838400

I have seen no government paperwork in Canada that said I had to select my preferred method of restriction. That is a supposition of the author of the tweet.

The individuals and organizations railing against flavoured vapour products did not put it forward as a ‘pick your poison’ option either, although I suspect they will gladly accept it and support the CVA for their insightful and valued contribution. 

Of course, immediately afterwards, I believe those folks will resume banging the flavour drum and making scripted advertisements about ice-cream trucks selling nicotine infused products to toddlers.

Figure 3: https://twitter.com/dashvapes/status/1258988692468838400

There is no evidence that had nicotine concentration in vapour products been limited to 20 mg/mL prior to this legislation in Nova Scotia or Quebec would have turned out any differently. Nor is there any reason to believe that a concession on nicotine will prevent such measures in the future.

If a mugger demands your wallet, and you offer your watch as a concession, they will take both your watch and your wallet.

Figure 4: https://twitter.com/ShaunBCasey/status/1258996622094204928

One might think that as a category that continually reminds our opponents of the science and data supporting harm reduction, and one that has historically been the target of claims of being shills, astroturfing, and ad hominem attacks, that we above all others, would understand how weak and petty such tactics are.

Nope. 

As my last comment on this twitter topic I would point to the following:

Figure 5: https://twitter.com/dashvapes/status/1259360295509798912

There is no more of an established means of officially making a public statement than a paid public press release. Similarly, posting said release in as public a discussion form as Twitter with the expectation that it will not be discussed is not a logical position.

There is no evidence that capping nicotine alone will impact use of the product by young people. Correlation does not equal causation.

There is no supportive data that this is the “Only” path forward for the industry, or the “Best” path, or even an “Effective” path. That is an assumption that is at the heart of the CVA’s strategy.

For those wondering, the above tweets are from persons on the board of directors for the CVA or their associated companies.

So that’s enough about the twitter bits, there are over 100 associated tweets out there you can thread your way through to see how it publicly played out. 

The Canadian Vaping Association’s Proposed Strategy in Response to Youth Uptake Concerns

Now while this is all recent in the realm of Twitter. The CVA’s proposed nicotine restriction at 20mg/mL has been openly published since at least September of 2019; in a press release titled “Media statement by the Canadian Vaping Association” (3). Nor was the 20 mg/mL cap the CVA’s only requested measure to impact youth usage and uptake. There are 5 points in that release, although one of them is made somewhat redundant by another. The first two points were put forth in the first paragraph of the release, and the latter three are in point form as a hold over from previous communications. All five have been repeated either individually, or as a conglomerate in many of the CVA’s press releases since.

I will list them here in the order they are presented and as worded in the press release:

• “The CVA is calling on all Federal, Provincial and Territorial Governments to ban the sale of nicotine e-liquid vape products and all visible marketing outside of adult access environments immediately. They must be removed from all convenience stores, gas stations or any retail location that is not age-restricted.”

• “We also call on the Federal Government to restrict nicotine levels to 20 milligrams per millilitre or two per cent.”

• “Display and promotion in retail environments should be restricted to age of majority retail stores”

• “National and brand specific advertising should be banned”

• “Mandating that e-commerce and online sales must be delivered via an age verification platform, such as the one currently available through Canada Post”

Given that point three is redundant due to the call for prohibition of that retail model, point 4 is kind of a moot point in Canada, and the fact that I basically agree with point 5, I am going to go through the first two points and in turn, try to answer the following questions:

How will this position impact youth initiation and use of the product?

How will this position impact the adult user of the product and/or the adult smoker?

How will this position impact the independent specialty vape shop industry?

How will this position impact the large corporate (read: Convenience Store / Tobacco Company) vaping industry?

And finally:

How well does this position mesh with the closing statement of the press release? “The lifesaving vape products have been deemed at least 95 per cent safer than combustible tobacco by the Royal College of Physicians. They must be embraced and available to Canadian smokers as a solution to address Canada's leading cause of preventable death – combustible tobacco.” (again, this is a direct quote, grammar is maintained from the original). 

“The CVA is calling on all Federal, Provincial and Territorial Governments to ban the sale of nicotine e-liquid vape products and all visible marketing outside of adult access environments immediately. They must be removed from all convenience stores, gas stations or any retail location that is not age-restricted.”

How will this position impact youth initiation and use of the product?

Studies and Public Opinion Research generally show that the majority of youth access to vapour products (nicotine and other adult products in general) through social sourcing, “Got it from a friend/relative” (either openly or through surreptitious means), “Paid someone to get it for me”, etc. Essentially just about anything shy of “I went into a store, picked, and paid for it myself”. It is important to note that in most studies, “youth” is classified as 15-19 years of age which is going to encompass Canadians on both sides of the legal age of access divisor. There is one piece of federal public opinion research that in limited cases does indicate respondents who were “Below Provincial Legal Age”, and one provincial study, but those reports are currently the exception as opposed to the rule in Canadian data collection.

Any action that would remove the product from a youth’s social reach would reduce youth access, but the effectiveness of that approach would be highly dependent upon the product being completely removed from their realm of social access points. Where social access involves leveraging individuals who are accessing the product via legal means (Bootlegging, Booting, Theft from adult users) then to be effective you would have to restrict adult access to the product as well. Social access is an area of concern in most “adult oriented” industries.

Essentially, prohibiting sales in “convenience stores, gas stations, or any retail location that is not age-restricted” would be most effective in isolated communities where vapour products are not available anywhere else including via mail order or on-line purchase, and less effective as other legitimate access points are more available. In a metropolitan community I suspect social access would be far less impacted as the likely outcome would be that root source of products that find their way into the socially accessible reach of youth would simply shift from the newly prohibited access point to one that is equally accessible and not prohibited.

Humans are a problem-solving species. This is not just a facet of adult humans; youth have always been able to demonstrate adept skillsets when it comes to attaining things they want. Particularly when the things they want are the things adults tell them they cannot have.

Supporting Quotes and Figures:

The following quote is from page 213 of a Centre for Addiction and Mental Health (CAMH) report titled Drug use among Ontario students, 1977-2019: Detailed findings from the Ontario Student Drug Use and Health Survey (OSDUHS) (4).

“Among underage students who reported using e-cigarettes in the past 12 months (n=1,983), the most common source reported was a friend. The least common sources were purchasing at a convenience store/grocery store, a gas station, or a pharmacy (all estimates suppressed).”

Figure 6: Page 213 from the report “Drug use among Ontario students, 1977-2019: Detailed findings from the Ontario Student Drug Use and Health Survey (OSDUHS)”. The bottom left graph in the image identifies "Source of Previous Electronic Cigarette Among Users Under Age 19". It can be noted that 75.3% of respondents identified a means of access that could readily be defined as social sourcing.

From Vapers Panel Survey to Measure Attitudes and Behaviours Regarding Vaping Products June 2019 (5) a report written by Environics Research as Commissioned by Health Canada (This is a recurring public opinion survey).

“Vapers of legal age to buy tobacco products in their province are more likely than those who are not of legal age to get devices and liquid from sources where proof of age is likely to be required (such as convenience and other retail stores and online). In turn, vapers below their province’s legal age are more likely to get devices and liquids from friends or others (non-family), or to ask someone to buy it for them.”

Figure 7: Page 18 from the report “Vapers Panel Survey to Measure Attitudes and Behaviours Regarding Vaping Products June 2019”. It should be noted that in this survey respondents could select more than one answer, and that the number of "Below Provincial Legal Age" respondents is significantly lower than those in the CAMH report in figure 6.

How will this position impact the adult user of the product and/or the adult smoker?

At 9.985 million km2, Canada is an exceptionally large country. With a Q1 2020 population estimate 37.895 million residents (6), population density outside of urban areas is quite low.

Figure 8: Archived Population density Map from Statistics Canada. https://www150.statcan.gc.ca/n1/pub/91-214-x/2015000/section04-eng.htm

The most recent Statistics Canada data shows that “In 2018, 15.8% of Canadians aged 12 or older (roughly 4.9 million people) smoked cigarettes either daily or occasionally.” (7), and according to the University of Waterloo in 2017 roughly 292,000 Canadians aged 15 and older reported daily use of e-cigarettes (8) based on the 2017 Canadian Alcohol Tobacco and Drugs Survey (CTADS). There is little data publicly available on the federal government website from the new Canadian Tobacco and Nicotine Survey (CTNS) executed in December of 2019 beyond a lone article from “The Daily” Statistics Canada newsletter (9). 

Since may of 2018, with the passing of the Tobacco and Vaping Products Act (10), and the entry of the large corporate entities (C-store / Tobacco Companies) into the Canadian market, the “Provincial Legal Age” portion of those 4.9 million Canadian smokers, has had legal access to some form of vapour technology product in almost every location where they can buy combustion based tobacco products. If your town is big enough that you can buy cigarettes there, the odds are you can find vapour products in some limited capacity there as well.

In comparison to these 10’s of thousands of retail spaces where vapour products are currently available in some form or fashion, the Canadian Vaping Association, in a March 2020 press release (11), estimates that there are “1,200 vape shops across our nation”. Most of these shops are in metropolitan regions and to a lesser extent in larger townships of 10,000 or greater. To successfully operate a specialty shop carrying one specific type of commodity only, that business needs access to a large enough consumer base to be financially viable.

Restricting vapour technology access for transitioning smokers and former smokers who have completely adopted vapour technology will have an impact upon those users. 

Enthusiasts and hobbyists, or transitioned smokers who are comfortable figuring out technology-based products on their own and do not have access to one of those “1,200” vape shops may shift to the on-line market. 

 Those who are not comfortable with more advanced systems, are only experienced with the “ease of use” focused convenience store systems (which are often under represented in the offerings of the specialty vape shop), or that suddenly find themselves inconvenienced in attaining the product will be at risk of relapse. Cigarettes and other forms of combustible tobacco will once again be the easiest, and most readily available form of nicotine consumption.

Rural smokers who have not experimented with vapour technology, are unlikely to, given the impact to availability in their sphere of commerce, and given that combustion based tobacco products, products with which they have a long standing familiarity and comfort level, will remain readily accessible.

Evidence of one potential outcome is easily found within business publications and stock market analysis where tobacco stock futures rise in response to proposed and enacted restrictive measures placed against vapour technology, whether those measures are proposed or enacted as access restrictions, flavour restrictions, taxation, or nicotine content restrictions.

How will this position impact the independent specialty vape shop industry?

This position would eliminate all current competition for the independent specialty vape shop.

How will this position impact the large corporate (read: Convenience Store / Tobacco Company) vaping industry?

These entities would be the “competition” referenced in the previous answer.

How well does this position mesh with the closing statement of the press release? “The lifesaving vape products have been deemed at least 95 per cent safer than combustible tobacco by the Royal College of Physicians. They must be embraced and available to Canadian smokers as a solution to address Canada's leading cause of preventable death – combustible tobacco.” 

This position will remove the less harmful product from tens of thousands of locations, restricting access to “1,200” locations, largely concentrated in metropolitan and urban communities. The more harmful product will maintain ubiquitous market presence.

For the Canadian smokers who we want to “embrace” this reduced harm option and live within urban locales, access will be massively restricted. For those Canadian smokers who reside outside of those urban areas, it will be all but eliminated.

“We also call on the Federal Government to restrict nicotine levels to 20 milligrams per millilitre or two per cent.” (Original phrasing maintained)

“50 mg/mL is way too much”. “Nobody needs more than 20 mg/mL”. “I quit with 12 mg/mL, that’s the perfect amount”. “I quit with the patch, and if I can do it you can do it to”.

“I quit with sheer willpower in 1985 and if you can’t, it’s because you are weak”

If there was a single silver bullet that worked for everybody, I would not be writing this novella, because there wouldn’t be any smokers anymore.

This 20 mg/mL cap that the CVA is so confident is the sole reason youth uptake is less prevalent in the United Kingdom was not initially proposed by the U.K. and had little to do with preventing youth uptake.

The 20 mg/mL nicotine cap was a mandate of the European Union’s Tobacco Products Directive (TPD), implemented in 2016 after years of debate and discussion.

The 20 mg/mL nicotine cap was intended to be implemented along with 10 mL bottle capacity restrictions, child resistant enclosures on bottles, 2 mL capacity limits on vaping device reservoirs, and “leak proof” refilling mechanisms for those 2 mL reservoirs: To lower the potential for accidental poisoning via ingestion of nicotine bearing vaping liquids. 20 mg/mL was selected as a target because the commission believed that at that value an e-cigarette would deliver similar nicotine to a combustion based cigarette.

The European Union consists of a lot more member states than just the United Kingdom, and all those states are subject to the TPD. If a 20 mg/mL nicotine cap is the primary contributor to a containment of youth uptake in the U.K. then throughout the European Union we should see similar effects.

Both adult, and youth smoking rates and vaping rates vary across the various EU countries. The most recent Eurobarometer on tobacco and vaping products use was performed in 2017 on year after implementation of the TPD, the next Eurobarometer if, I understand the intervals correctly should be performed this year and will give us a clearer picture of what the member states look like in comparison to the world and each other.

How will this position impact youth initiation and use of the product?

Limiting nicotine concentration to 20 mg/mL or roughly 2%, is unlikely to have a viable impact on initiation as data sets to date demonstrate that reasons for initiation are more “curiosity” based, or “availability” based, than they are an innate desire to abuse nicotine for a physiological effect. That said, potential for abuse could be part of that curiosity and will be discussed shortly, however first let us look at some data about “why youth start to vape”.

From the CDC Morbidity and Mortality Weekly Report (MMWR): Tobacco Product Use and Associated Factors Among Middle and High School Students — United States, 2019 (12)

Figure 8: https://www.cdc.gov/mmwr/volumes/68/ss/ss6812a1.htm#T6_down

This somewhat echoes the findings of Health Canada sponsored public opinion research (13) from 2018:

Figure 9: Page 22 of the Phoenix SPI paper commissioned by Health Canada in 2019. Peer Crowd Analysis and Segmentation for Vaping and Tobacco

None of this is to say that youth are not abusing higher concentrations of nicotine for physiological effect. However before we tear off thinking that a 20 mg/mL cap on concentration will end that, we need to put some thought into both the physiological effect (buzz) and the aspect of abusing a product to receive effects not intended by the product manufacturer.

Nicotine naïve (never previous) users of tobacco products or vapour technology will receive a physiological effect like a euphoric buzz. This is not so much a function of the nicotine “in the device” this is what happens when nicotine “in the blood” hits receptors in the brain which then release dopamine. For the nicotine naïve, this can happen at levels far below the 59 mg/mL mark and indeed well below the 20 mg/mL mark. For the non nicotine naïve - those who have developed a tolerance, it will take a higher concentration of nicotine “in the blood” to receive the same effect or to maintain their comfort levels. This is independent of the nicotine concentration in the delivery system. You use the delivery system until your central nervous system says, “I have produced enough dopamine”. It does not matter what the delivery system is, you will use it until you are satisfied. A smoker under stress may smoke two cigarettes back to back. A mouth to lung vaper in a device at 10-15 Watts of power may go through 1/8th of a milliliter of 12 mg/mL liquid to achieve the same effect, and a person using a high volume delivery device at 30 or more Watts may go through a ½ milliliter of 3 mg/mL liquid. In this instance the device used, the concentration of liquid used, and the volume of liquid are to be frank, irrelevant:

A nicotine user will use whichever delivery system they have at hand until their blood concentration of nicotine is high enough that their central nervous system is satisfied. 

For a transitioning smoker that means they will vape until they remove their withdrawal symptoms, for a youth looking for a buzz, they will use that product until they get the buzz they are looking for. For the nicotine naïve, who do not have an overabundance of receptors this can happen at 3 mg/mL or 6 mg/mL or with one cigarette.

This leads us to “abuse”.

You cannot regulate “abuse” out of a product any more than you can regulate an illegal market. Similarly, you cannot legislate “abuse” out of a product, and off the top of my head I cannot think of an effective engineering technique that effectively eliminated “abuse” from a product. Not without rendering the product ineffective for its intended purpose. This is in effect what happened with NRT. To make the product low in harm and reduce its dependency potential, it was not satisfying enough to reach most smokers (See “Nicotine without smoke: Tobacco harm reduction” (14). RCP London 2016 Chapters 4 and 5).

Given that the effect is determined by the blood concentration, the same rules would apply to the abuser, as they would for the targeted users. Any drop in the liquid nicotine concentration can be amply compensated for by the abuser increasing the volume of liquid consumed.

The youth who tend to abuse vaping products for “the  buzz” figured this out quite some time ago, they are not by and large using gas station devices with 59 mg/mL liquid, running at 8 Watts and a comparatively high resistance coil. Most of them have already figured out that commercially available independent vapour industry liquid at 50 mg/ml in similarly small and concealable independent vapour industry hardware with 0.6 ohm coils operating at 22 Watts provides a lot more buzz and is significantly easier to operate than trying to penetrate a paper coffee cup with 5 JUUL devices. It will not take long for them to discover 20 mg/ml, at 55 Watts off a mesh coil “Hits like a truck… dude”. 

If we reduce the concentration of nicotine in vaping product liquids enough to eliminate “naïve buzz” we also eliminate “dependent smoker satisfaction” and “delivery system substitution”.

Which leads me to…

How will this position impact the adult user of the product and/or the adult smoker?

In 2014, while the EU TPD limits were being discussed a group of academics wrote a letter (15) to the EU Commission regarding various errors the commission had made in reviewing the science around vaping products as they created the foundational rulesets for the directive.

Item #1 on that list went straight to the nicotine cap.

Figure 10: Dr. Farsalinos' Scientific Blog. Screen shot of a portion of a letter sent by academics to the EU discussing errors in regulators interpretation of the science of vaping.

Now some folks will argue about the generation of devices used at the time (low power, low volume vapour delivery, and the harshness of higher levels of freebase nicotine etc.). However, we need to go back to the fundamental statement: It’s not the nicotine in the device – It’s the nicotine in the blood.

Despite its harshness, 48 mg/mL e-liquid was available in the UK prior to the implementation of the TPD, and demand was high enough that it was commercially available through most vendors. The types of devices that liquid was used with were generally operating with high resistance coils (1.8 to 2 ohm) and either direct output -3.7 volts, or variable voltage output devices. The Kangertech Evod, which was one of the devices used in Dr. Farsalinos’ research at that time, used a 1.8 ohm coil at an average of 3.7 volts. 7.6 watts.

Some years later a company called Pax Labs released a small device that used a high resistance coil, low power, 59 mg/mL nicotine salt (to address the harshness caused by free base nicotine). It was intuitive to use, required little in the way of upkeep and maintenance aside from charging it when the battery was depleted and replacing the pods when they were empty and was similar in size to, and ease of operation of a cigarette. That device grabbed 75% of the U.S. convenience store vapor products market.

Nicotine Salt solutions reduce the throat rasp (or hit) associated with the freebase nicotine solutions previously used in e-liquids, allowing for higher concentrations to be present without making them overly unpleasant to heavy smokers (many smokers find that 12 mg/mL freebase solutions can be unpleasantly harsh, and at 18 to 24 mg/ml they may find them too harsh to transition away from cigarettes, and this is in low volume devices. E-liquid in high volume vapour devices is often found in concentration ranges between 0 and 6 mg/mL, and very occasionally 12 mg/mL). Nicotine Salt solutions also have a faster uptake and when this is coupled with the higher nicotine concentration they are almost as an effective nicotine delivery system as a combustion-based cigarette.

Any legislative or regulatory change that negatively impacts the ability of a vapour technology device to deliver suitable amounts of nicotine to the blood system, and then the nervous system, particularly in comparison to the same capabilities of a combustion-based delivery system, will negatively impact smokers transitioning to vapour products and may cause recently transitioned vapers to relapse back to smoking.

Outside of its inherent mimicry of the physical habit of smoking, vapour technology’s largest strength is in its variability and the ability to tailor the system to the preferences of the individual user. The system can be a simple or as complex as the user desires. Those that want higher vapour volumes for either a dense lung sensation, flavour saturation or aesthetics can get what they need to stop smoking. Those that are purely nicotine focused can get devices that produce what they need. You want it to taste like a cigarette? Blueberries? Pina Colada? It can be done. These options: these “tools” in a vape shop owners toolbox, are what allow them to have a transitioning success rate that exceeds that of pharmaceutical NRT products.

However, tools are only useful when you use them.

You can only use tools if you have them.

Any competent tradesman will tell you, “You never give your tools away”.

And on that note…

How will this position impact the independent specialty vape shop industry?

In the sense that “anything that weakens my competition is good for me”, a nicotine cap would, at first glance, appear to be beneficial for the independent vape shop. However, if you look for much longer than a glance, then much like a 15-year veteran exotic dancer who doesn’t clear the stage before the houselights come up, the picture becomes less pretty.

“I’m doing fine”

“I have lots of customers”

“I’ve converted all sorts of smokers with (insert nicotine formulation, concentration and device here)”

“My sales data says…”

There are between 4.5 and 5 million smokers over the age of 15 in Canada viii. The University of Waterloo says that at last count there were 292,000 “vapers” (not ever users, or occasional users but regular users… consumers that would frequent vape shops more than once). If every one of those 292,000 vapers were a former smoker (and they are not) then the vaping industry gas effectively reached 5.84% to 6.5% of the smoking population in the country.

You might be doing fine, but you could be doing a hell of a lot better.

You might have lots of customers, but you could have more.

You might think you have converted lots of smokers. You have not. You have barely scratched the surface of the potential client base. 

Your sales data only speaks to the people who you service, and I’ll bet it doesn’t speak to all of them either unless you are taking the time to enter customer data for all of the brick and mortar walk ins as well as the customer populated data you collect through your on-line sales portal. Your sales data does not account for folks who do not shop with you. It does not account for the customer who only came once. It does not follow up with that customer to find out why they only came once.

It’s not about the tools (device and liquid) YOU used to transition. You sound like that guy who quit with sheer willpower in 1985 (He still thinks you are a wimp).

It’s not about the tools that MOST of your customers used to transition.

It’s not about the tools your most recent customer used to transition.

It is about the tools your NEXT customer needs to transition. The customer you have not met yet.

Flavours are critical to the appeal of vapour technology for smokers, but nicotine delivery is critical to the efficacy for reaching smokers. Trading one for the other is in most polite fashion: incredibly short sighted.

Can the independent vapour products industry survive a 20 mg/mL nicotine cap? Yes, it can. It might even thrive in some fashion, but it will not reach its full potential. 

How will this position impact the large corporate (read: Convenience Store / Tobacco Company) vaping industry?

If they don’t get wiped out by the request to prohibit the sales channel in its entirety, a 20 mg/mL cap on nicotine concentration will directly impact the efficacy of the majority of standard c-store vapour technology products. 

In order to maintain their small size and ease of use they require small batteries, high resistance coils and low volume vapour delivery. This means they need to have high concentrations of nicotine in solution to compete with a combustion-based product. Cutting that concentration to roughly a third will not benefit that product at all.

How well does this position mesh with the closing statement of the press release? “The lifesaving vape products have been deemed at least 95 per cent safer than combustible tobacco by the Royal College of Physicians. They must be embraced and available to Canadian smokers as a solution to address Canada's leading cause of preventable death – combustible tobacco.” 

Quite simply, it doesn’t.

None of it does.

References used in this post:

[1]             The Canadian Vaping Association. Press Release. May 2020. https://www.globenewswire.com/news-release/2020/05/07/2029745/0/en/High-Nicotine-Concentrations-Lead-to-Higher-Youth-Vaping-Rates-in-Canada.html

[2]             The Canadian Vaping Association. Twitter. May 2020.  https://twitter.com/thecvaofficial/status/1258446791537721350

[3]             The Canadian Vaping Association. Press Release. September 2019.  https://www.newswire.ca/news-releases/media-statement-by-the-canadian-vaping-association-854790020.html

[4]             Boak A., Elton-Marshall, T., Mann, R. E., & Hamilton, H. A. (2020) Drug use among Ontario students, 1977-2019: Detailed findings from the Ontario Student Drug Use and Health Survey (OSDUHS). Toronto, ON: Centre for Addiction and Mental Health.

[5]             Health Canada. Environics Research. Vapers Panel Survey to Measure Attitudes and Behaviours Regarding Vaping Products June 2019. https://epe.lac-bac.gc.ca/100/200/301/pwgsc-tpsgc/por-ef/health/2019/141-18-e/report.pdf

[6]             Statistics Canada https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=1710000901

[7]             Statistics Canada https://www150.statcan.gc.ca/n1/pub/82-625-x/2019001/article/00006-eng.htm

[8]             University of Waterloo https://uwaterloo.ca/tobacco-use-canada/e-cigarette-use-canada 

[9]             Statistics Canada https://www150.statcan.gc.ca/n1/daily-quotidien/200305/dq200305a-eng.htm

[10]             Government of Canada https://www.canada.ca/en/health-canada/services/health-concerns/tobacco/legislation/federal-laws/tobacco-act.html

[11]             The Canadian Vaping Association. Press Release. March 2020. https://www.globenewswire.com/news-release/2020/03/23/2005113/0/en/Canada-Must-Follow-the-Lead-of-Italy-France-Spain-and-Switzerland-and-Treat-Vape-Shops-as-an-Essential-Service.html

[12]             Wang TW, Gentzke AS, Creamer MR, et al. Tobacco Product Use and Associated Factors Among Middle and High School Students — United States, 2019. MMWR Surveill Summ 2019;68(No. SS-12):1–22. DOI: http://dx.doi.org/10.15585/mmwr.ss6812a1

[13]             Health Canada. Phoenix Strategic Perspectives Inc. Peer Crowd Analysis and Segmentation for Vaping and Tobacco. https://epe.lac-bac.gc.ca/100/200/301/pwgsc-tpsgc/por-ef/health/2018/074-17-e/report.pdf

[14]             Royal College of Physicians. Nicotine without smoke: Tobacco harm reduction. London: RCP, 2016.

[15]             Dr. Farsalinos’ Scientific Blog. “Scientific Errors in the Tobacco Products Directive. A letter sent by scientists to the European Union.” http://www.ecigarette-research.org/research/index.php/whats-new/whatsnew-2014/149-tpd-errors