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A chorus of idiots

Hold my light

Personally I’m a fan of Philip Morris International’s “Hold My Light” campaign. I’ve been advocating for tobacco harm reduction for years, and it’s good to see PMI throw their weight behind the same cause. Campaigns like this have the potential to make a huge difference, and I think they should be encouraged.

If you missed it, Hold My Light is a multimedia campaign aimed at encouraging smokers to give up and switch to reduced-harm products. The centrepiece was a four-page advert in the Daily Mirror, backed by a website, video and other promotional material, and the theme was the simple message that if you smoke, it’s better to quit. You wouldn’t think that would be at all controversial, would you? Well, you’d be wrong.

Despite Hold My Light saying exactly the same thing as they’ve been saying for decades, anti-tobacco activists have greeted the campaign with an absolute shitstorm of criticism and abuse. Starting the day of its launch, PMI have been bombarded with wild accusations and hysterical conspiracy theories from a collection of people who really should know better, but very obviously don’t.

Cancer Reasearch UK

Cancer craziness

First up, we have George Butterworth from Cancer Research UK. I’ve been involved with vaping advocacy since 2013, and I know that among vapers there are some pretty mixed feelings about CRUK. The charity does generally support vaping as a safer alternative to smoking, but on the other hand it also tends to back more restrictions on what we’re actually allowed to vape. CRUK was a big fan of the EU’s notorious Tobacco Products Directive, for example, despite being repeatedly warned the law would take a lot of very good products off the market. George Butterworth “welcomed” the TPD, claiming it would reassure vapers that e-cigs were safer than smoking. That’s an odd thing to say about a law that enforced health warnings on every e-cigarette and bottle of liquid.

Now he’s at it again. Butterworth, who’s been telling smokers to quit for years, is frothing with rage at PMI because they’re running a campaign telling smokers to quit. He accused the company of “staggering hypocrisy”, apparently because PMI still advertises its cigarettes in countries where people like Butterworth haven’t banned them from doing it.

What Butterworth doesn’t get is that PMI, being a publicly traded company, has a legal obligation to look after its investors’ money. That means selling products, of course, but you can’t expect someone who’s never had to make a profit to understand that. Instead he says “The best way Philip Morris could help people to stop smoking is to stop making cigarettes.”

Well, this just tells us that George Butterworth is a complete idiot. Hasn’t he learned anything from Prohibition, or the decades-long and totally failed war against drugs? If Philip Morris stop making cigarettes tomorrow, smokers will just buy them from somewhere else. If all tobacco companies stop making cigarettes tomorrow, say hello to a global explosion of organised crime that will make Al Capone and the Medellin cartel look about as serious as shoplifting a Kit Kat.

PMI can’t just stop making cigarettes, and anyone who understands anything about economics knows that. As long as a there’s a demand for cigarettes – and that isn’t going to change anytime soon – someone is going to be making and selling them. It can be regulated tobacco companies like PMI who pay tax and obey the law, or it can be organised crime. “Nobody” is just not an option.

Action on smoking and health

Pains in the ASH

And then there’s Action on Smoking and Health. I don’t like ASH at all; this is no secret. I’ve had a public run-in with their CEO, Deborah Arnott, and chest-poked a couple of her minions over their bullying, coercive approach to vaping, harm reduction and everything else they choose to stick their noses into. So guess what? Their reaction to the Hold My Light campaign annoys me too.

First out of the box to whine about the campaign was of course Debs Arnott herself, a sour-faced specimen with the general demeanour of a small-town traffic warden. Arnott claimed, bizarrely, that the campaign is an attempt to make an end run around the UK’s ban on tobacco advertising. I don’t have a marketing degree, but to me it seems like advertising a product by telling people to stop using it isn’t really the way ahead.

Arnott was followed by Hazel Cheeseman, ASH’s director of policy. I’ve met her too. More pleasant than Arnott but just as misguided, Cheeseman is an earnest-looking creature better suited to teaching small children than making policy. Describing the campaign as “simply PR puff,” Cheeseman suggested that if PMI were serious about achieving a smoke-free world they would stop opposing anti-smoking legislation that “will really help smokers quit”. What she means is nonsense like plain packs and display bans, which real-world evidence says don’t achieve anything, and of course ever-increasing punitive taxes.

Get real

Let’s get this straight: I have spoken to senior people at PMI (and other tobacco companies). I have been to the Cube at Neuchatel and seen the time and money PMI are investing in reduced-risk products. I have used those products myself, and I enjoy using them.

None of Cheeseman’s regulations would ever have stopped me smoking. Higher taxes? I’d just have bought cheaper food to free up some money. Graphic health warnings? I’d have worked to collect the full set, then frame them and hang them on my wall. Plain packs? I used a cigarette case anyway. These laws are all useless, because they’re written and lobbied for by nanny statist clowns who don’t understand how real people think.

The truth is that all the outrage being thrown at Hold My Light by the likes of Butterworth, Arnott and Cheeseman is just self-righteous indignation. How dare PMI break out of their bad guy stereotype! How dare they work towards the same goal as CRUK and ASH? And how very double dare they do it by selling products that real people actually enjoy using? At this point it doesn’t matter what PMI choose to do; it’s going to be wrong, simply because they’re the ones doing it. If they ignore harm reduction and just keep selling Marlboro they’re heartless and don’t care about their customers. If they try to persuade people to switch to safer products they’re hypocrites. Any time they do anything that satisfies one of their opponents’ demands, those demands will simply mutate into something new and probably ridiculous.

Well, I’m sick of people like Arnott and Butterworth sticking their oars in all the time. Who elected these people? What did they ever contribute to our lives beyond endless bitching and whining? By what right do they tell private citizens what they should or shouldn’t do? It’s time for them to shut up and live our own lives the way we choose.

One of the better choices we can make is to quit smoking. As much as I enjoyed smoking it really isn’t very good for you, so it makes sense to stop – just like PMI are saying. And if you want to do that by switching to one of PMI’s safer products, like iQOS or Mesh, don’t pay any attention to carping nobodies like Cheeseman; just go ahead and do it.

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Everything you need to know about the FCTC COP8 junket

COP8

Understanding the FCTC Conference of the Parties.

The WHO Framework Convention on Tobacco Control’s (FCTC’s) 8th “Conference of the Parties” (COP8) gets underway on October 1. It is a bizarre meeting whose format results from FCTC technically being an international treaty. Thus, it theoretically requires serious formal meetings of national officials who have the authority to negotiate and make commitments on behalf of their governments. In reality, the idea of treating FCTC’s deluge of position statements and vague policy recommendations as the law of the land, as would be the case with a proper treaty, is laughable. Functionally FCTC is really just an overfunded special-interest lobbying organization, and a rather dysfunctional one. The COPs are exactly what you might expect based on that: gabfests in which delegations of unserious people (few of whom could actually commit their governments to anything) hold a cheerleading session and enshrine their flights-of-fancy in “official international treaty” documents.

 

The COPs are notorious for their paranoid exclusionary policies, including banning of reporters and other observers from many of their sessions. Consumers have no seat at the table, let alone industry, which FCTC declares itself to be diametric opposed to (and as a result, ironically grants industry control over their actions). Perhaps most notoriously, the international law-enforcement agency, Interpol, which plays a major role in fighting cigarette smuggling, was denied observer status because they engage in the obvious tactic of cooperating with companies that also work to stop smuggling. As much as these exclusions arouse ire, they would actually make perfect sense if FCTC were a proper treaty. Trade treaties are negotiated by states (via empowered serious officials who speak for their government, of course, not a gaggle of loons), without any direct participation by the stakeholders, and some steps in those negotiations are not possible without confidentiality. Military treaty negotiations are even more secretive, and ISIS and the Taliban are obviously not allowed to observe the meetings.

 

Paper Policemen

Paper policemen.

The problem is that FCTC is a treaty in name only, and the COPs do not resemble negotiations about a treaty. They feel like what they really are: political rallies. When a political rally excludes the press and stakeholder observers, we immediately suspect that they are up to something nefarious, which is certainly true in this case. Moreover, WHO’s rhetoric about why FCTC exists is that the “treaty” is designed to improve population health. That goal would be best served by including the actual stakeholders (consumers and industry), rather than having a group of non-stakeholders engage in uninformed discussions about top-down approaches. But health has become a mere pretense for the FCTC, and this was already true before the “treaty implementation”.

 

Instead of having a nuanced and complicated humanitarian goal, like improving health, the participants live in a fantasy world in which they are protagonists in a simplistic modern-style fairy-tale (think: Star Wars). They are at war against evil, facing an a enemy (a fictitious monolithic construct they call The Industry) with no discernible motivation other than to do evil. This means there is no room for mutually beneficial arrangements and no possible strategy other than total war (see above link for more of my analysis on that point). As a result, they act as if COP chattering sessions are a secret military conference, not realizing that it is they who are playing the role of The Empire, the Taliban, or ISIS (which, incidentally, was praised by some people who will be at COP8 for its anti-tobacco policies).

 

Has it ever been about health?

If FCTC were really about health, they would embrace low-risk alternatives to smoking. As anyone familiar with tobacco control knows, they do not. FCTC documents devote at least as much attention to attacking low-risk products as they do cigarettes. Much of the rhetoric targeting low risk products these days is about flavors and other features that supposedly attract young never-smokers. One might have some optimism about what COP8 will say about heat-not-burn based on this. HnB products are plain-old-cigarette flavored, are not sleek and sexy, and their use is not much easier to conceal from parents and teachers than regular cigarettes. They seem like the dream product for someone who genuinely wants to help smokers lower their risks without attracting many new young users.

 

The problem is that the focus on flavors and such is mostly just hollow rhetoric. A large portion of participants at COP8 are anti-tobacco extremists, a term I coined as follows: If someone had the choice between magically eliminating the harm from tobacco products, such that people could still enjoy all the benefits without health risk, or magically eliminating all tobacco products from existence, they would choose the latter. A substantial fraction of tobacco controllers would prefer to deny people the pleasure of tobacco use, regardless of whether there is health risk. Combine this with the fairytale opposition to “The Industry” (HnB being entirely a product of that great evil empire, “Big Tobacco”), and there is little hope for good news.

 

A few good men (or women.)

Of course, there will be non-extremists at COP8. There will be participants who really care about health, and even a few who actually care about people’s happiness. There will be those who understand how the world really works and recognize that their policies need to be realistic and will be useful only if there is stakeholder buy-in. But here is where the dysfunctional governance structure of FCTC comes into play. A real treaty negotiation would offer some possibility that the humanitarians and realists would prevail. Indeed, if delegations were comprised of real diplomats and other serious officials, there would at least be a bias in favor of realism. But instead the COPs function more like a student organization with a “there are no bad ideas” policy. It is a recipe for kakocracy, with the most extreme crazy people defining the agenda and policy positions. It might be that a majority of the “voting delegates” (again, since none of this is genuine public policy, neither membership nor voting really matters much) might think an extremist proposal is unrealistic or even loony, but they will not bother to vote against it, let alone speak out. What would be the point? In addition, they are (realistically) worried about being excommunicated from the club and losing access to the endless gravy train if they oppose extremist positions. Those with enough integrity to resist that pressure have already been excommunicated.

 

Anti-everything.

Thus, it is a safe bet that the “official” statements coming out of COP8 will be anti-HnB, anti-vape, and anti-snus. They will also find a little time to be anti-smoking, though worrying about smoking is just so 2005. Less snarkily, there is really not much for them to say about smoking that they have not already said. If FCTC were really a treaty, or even a policy analysis think tank, there would be a lot new to say about anti-smoking policies, particularly analyzing the actual nuts-and-bolts details. But FCTC does not do that. They offer flyover-level statements about what policies member states should implement, but without operationalizable details or program evaluation to assess whether they work (spoiler: almost none of them have any apparent effect).

 

Thinking again of a student-type organization, many of us can recall an experience from our youth of creating an organization and having twenty people show up and enthusiastically debate goals, philosophy, and language for weeks. After that is finished and it is time to start on practical tasks, only three of them ever show to do any real work. That is not a perfect analogy for the COPs (everyone goes home and does something to keep their lavish salaries flowing), but it is a pretty good metaphor (what they do is usually the functional equivalent of not showing up until the next political rally).

 

That is actually good news. There is a good chance that COP8 will issue some extremist condemnation of HnB, but this will be almost entirely cheap talk that has little impact. In only those few countries where WHO basically controls the health ministries (e.g., India), HnB might get banned as a result of a COP8 statement. In a few others where the loons have unfettered control independent of WHO influence (e.g., Australia, Finland), the same might happen, but it will not be because of COP8. The U.S. is a wild-card due to the unfettered power and arbitrary behavior of the FDA, but is not going to be influenced by FCTC. For most of the world’s countries, however, realism and humanity will probably prevail over COP8 statements, despite the signatures on the FCTC “treaty”.

 


 

Carl V Phillips PhD is a regular contributor on Heat Not Burn UK.

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Bad news: FCTC will declare war on heat not burn

FCTC

Bad news: FCTC will declare war on heat-not-burn (they just haven’t gotten organized yet.)

by Carl V Phillips, PhD.

The World Health Organization’s Framework Convention on Tobacco Control (WHO’s FCTC) is the most influential tobacco control enterprise in the world. Consumers in rich Western countries may not often notice FCTC’s impact because their dominant domestic tobacco control, such as the FDA in the US, are large and powerful enough to set their own agenda. But even in the West, FCTC’s agenda creates marching orders that a lot of tobacco control organizations follow. Thus, all heat-not-burn consumers should feel some trepidation about FCTC slowly getting organized to attack them. Their next attempt to attack heat not burn will be at the upcoming eighth session of the Conference of the Parties (better known as COP8) taking place in Geneva, Switzerland from 1st to 6th October 2018.

That “slowly” is the good news here. FCTC is a morass cheap-talk meetings, position statements, and bureaucracy (in the pejorative sense of the term). In theory it is an international treaty, but in practice it is a reactionary collection of people who would rather complain and make excuses for their failures than actually do the hard work needed to accomplish their goals.

The bad news is also embedded in that characterization, in “reactionary” and “their goals.” As I previously explored in detail, tobacco control in general, and FCTC in particular, is primarily concerned not about affecting consumers, let alone helping them, but with hurting what they call “the industry.” This mythical monolithic actor includes everyone who sells tobacco products, and if convenient for them, is expanded to include any consumer advocate or anyone else that questions their diktats. FCTC officially claims their goal is improving health, but this simply is not true, as evidenced by their active opposition to promoting the substitution of low-risk products for cigarettes.

They do not even recommend that policy interventions focus on cigarettes and other high-risk products. Instead, they explicitly insist that the same effort be devoted to discouraging all product use, regardless of risk. For example, they explicitly state that tax rates be the same on all products. While this is technically nonsense (what tax rate on a tin of snus or bottle of e-liquid is “the same” as a given tax on a pack of cigarettes?), the spirit of it is a clear lack of concern about health. One of the reasons so many Japanese switched to heat-not-burn is its favorable tax treatment (which might end).

FCTC declares their goals are diametrically opposed to those of industry, and spend as much energy focusing on attacking industry as on all anti-smoking policies combined. In some sense this is good news, because it slows them down a lot. But it makes them entirely reactionary, defining their policies in terms of industry actions: Whatever “the industry” tries to do, FCTC tries to interfere with. This is especially true for the major tobacco companies, which is to say, the companies that have introduced heat-not-burn devices. It does not matter to FCTC that people, not companies, want and use heat-not-burn; in their mind, attacking heat-not-burn use is attacking PMI and BAT. Consumers are an afterthought for them, at best.

One might hope that FCTC’s relative silence suggests they are not entirely opposed to a low-risk product that replaced almost 20% of the smoking in Japan and has made impressive inroads in other countries. But keep in mind that they did not get around to seriously attacking e-cigarettes until the last couple of years. They are slow, not flexible.

Amusingly, some of FCTC’s most emphatic policy recommendations focus on setting up research centers, what someone might call spy agencies, devoted to reporting on industry activities in a particular country or region. FCTC calls this “monitoring,” and the goal is to strangle innovations in their crib and be ready to “respond to myths created by the tobacco industry” (by which they mean “contradict anything said by industry, regardless of whether it is true or not”). The obvious subtext is “we blew it on e-cigarettes, and are only now managing to trick people into believing they are dangerous, so we have to get ahead of the next innovation.”

Of course, they already failed to do that with heat-not-burn. These are not good spy agencies. Their expensive monitoring efforts would have been more effective if they just had on staffer whose job it was to read Twitter.

Still, whatever industry wants to sell, FCTC will want to stop, and they will probably get organized about heat-not-burn over the next year. Their catch-up playbook is easy to predict based on what happened with e-cigarettes. It includes pressuring countries where the products are not yet popular to preemptively ban them, spreading disinformation about risks from the products, and demanding that all anti-cigarette efforts be expanded to cover the new product. Indeed, they will probably push for anti-cigarette efforts to be redirected to focus more on the low-risk product than on smoking.

The only policy area in which the FCTC agenda differentiates among tobacco products is smoking place bans, because the ostensible goal is trying to protect people from environmental smoke (never mind that their policies do not really protect people). They will inevitably lobby governments to include heat-not-burn products in all smoking place bans, even those that do not cover e-cigarettes.

To finish on a more optimistic note, regulators in many rich countries are much friendlier with big corporations than with their smaller competitors. FCTC hates PMI and BAT far more than they hate the independent vapor sector (though they are quite happy to destroy the latter also). US FDA, by contrast, has an institutional preference for dealing with big companies who can navigate the agency’s kafkaesque procedures. They would prefer to eliminate small vapor product companies (and are on a path to do so) and deal only with the majors.

FDA recently approved the sale of BAT’s current Eclipse heat-not-burn products, based on them being “substantially equivalent” to long-extant, though barely noticed, RJR products (as of last year, RJR is a wholly-owned subsidiary of BAT). They did not have to do this, and have denied “substantial equivalence” applications by smaller companies for reasons that could have been used in this case.

On the other hand, FDA is still sitting on PMI’s application to sell iQOS as a “modified risk tobacco product,” a more onerous approval process than “substantial equivalence.” They are already in violation of the legal deadline for responding to the application, and anything could happen. But the Eclipse approvals bode well. Positive outcomes can be expected in rich countries with self-confident regulators (and thus ignore FCTC pressure) who have a cozy relationship with big business. Unfortunately, most of the world’s smokers have little protection from the FCTC.


As passionate as we are about reduced risk products Heat Not Burn UK will campaign strongly for your own personal right to choose when it comes to harm reduction, as we believe the more options out there the better.

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There’s a new HnB study – and you should ignore it

new HnB study

I’ve been involved in e-cig advocacy for years, so I’ve seen some truly awful studies. It takes a lot to surprise me these days because I’ve seen it all: Badly conducted experiments, tortured statistics, misrepresented data and straight-out bad science. It isn’t often I find myself shaking my head at just how crap something is, but step forward anyway South Korea’s Ministry of Food and Drug Safety, because you’ve achieved it.

After Japan, South Korea is one of the biggest markets in the world for Heat not Burn products. For South Koreans, conventional vaping is just a niche hobby; if you want to quit smoking you go with HnB. The country is also one of the most varied markets. As well as the now-familiar iQOS and BAT’s newer Glo, there’s an indigenous competitor, too – the Lil from Korean Tobacco and Ginseng. We’re still waiting for KT&G to send us a Lil, by the way, but when they do you’ll be the first to know what it’s like.

UPDATE: We now have the Lil! Read our detailed review of it here.

Anyway, lots of South Koreans like HnB. All three products are selling well despite recent tax rises on the tobacco sticks for them, and smokers seem to be switching in pretty large numbers. So, as you’d expect, people who make a living telling smokers to quit are getting annoyed that the tobacco industry is doing their job better than they can.

So the knives are out for HnB in South Korea, and the Ministry of Food and Drugs just decided to have another go. This time their weapon of choice is an “independent” report by a group of Korean researchers that claims HnB isn’t less dangerous than smoking. At this point I’m going to stick in a disclaimer and say that there’s no formal evidence that it is less dangerous than smoking. That’s going to take decades of research and data collection, and with the products being so new we obviously don’t have that yet. What we do know is that, according to absolutely everything we understand about toxicology, it would be very surprising indeed if they weren’t significantly safer.

The shocking details

So what does this report say? Well, nothing good. It’s basically a toxicological analysis of the sticks for all three of the devices on the market. The media aren’t reporting any details of the study – such as the methods it used or even who conducted it – so there’s no way to tell what sort of science is behind this, but going by the results it’s extremely poor.

The headline conclusion is that HnB is no safer than smoking because it has nasty chemicals in it. This is in fact true; HnB sticks – and the vapour they produce – do have nasty chemicals in them. The problem is that, while true, this isn’t actually very informative. As any toxicologist will happily tell you, almost everything has nasty chemicals in it. If the mere presence of nasty chemicals was actually a problem, none of us would live long enough to be born.

What matters is how much of those chemicals is present. This is often expressed as “The dose makes the poison,” and it isn’t exactly a radical new concept that the “independent researchers” weren’t aware of yet – it goes back to Paracelsus, and he died in 1541. Some public health activists might claim there’s “no safe level” of whatever they’re attacking this week – second-hand smoke, alcohol, sugar – but they’re talking rubbish. The fact is that there’s a safe level of anything – arsenic, cyanide, even plutonium. That safe level might be extremely low, but it does exist. No matter how toxic or carcinogenic something is, there’s a level below which it just isn’t going to do you any harm.

Obviously, if it’s above that level there is potential for harm, but it isn’t a simple harm/no harm binary. If you swallow slightly above the safe level of arsenic you might feel a bit ill, but you’re not going to die. Similarly, if you inhale slightly above the safe level of some of the chemicals in cigarette smoke your risk of some cancers may rise slightly, but it’s not going to skyrocket like it would if you were firing up 20 Bensons every day.

And the authors of this shoddy study totally ignore that fact. They accurately picked up on the fact that HnB tobacco contains some of the same carcinogens as any other tobacco, but they totally ignored the relative concentrations in the vapour – and that is the only thing that matters. If they’d done their job properly they would have analysed the relative quantities and estimated a relative risk for that; instead they just found some nasty stuff and said “Yep, just as bad!” Sorry, but there’s no excuse for that – and their own data blows their argument to bits.

According to the report, analysis of HnB tobacco sticks found that they contained “up to five” human carcinogens. Just to put that into perspective, cigarette smoke contains at least 33 and even a humble carrot has over a dozen. If this report shows anything it’s that using an HnB device is, at least in terms of cancer risks, about as dangerous as eating salad.

Grasping at straws

The team also looked at two other components of both smoke and vapour – nicotine and tar. This is where they really lost contact with reality. They claimed that two of the products they tested produced more tar than an actual cigarette. This is where I would really like to know how they carried out the experiment, because in normal use there is just no way this is true. Tar is a mixture of combustion products, produced when tobacco burns – and HnB devices don’t burn the tobacco. It’s easy to see this by comparing the filters of a used Heet and a smoked cigarette; it’s tar that turns cigarette filters brown.

As for nicotine, their complaint about that was that all three products contained as much nicotine as a cigarette. Yes, they do. They’re supposed to, because if they don’t the devices won’t do what they’re supposed to do – give smokers an acceptable alternative to cigarettes. Any alternative to smoking depends on delivering enough nicotine that smokers are satisfied and don’t reach for a cigarette to deal with their cravings. Basically, the study is criticising HnB for being fit for purpose.

So does this study raise serious concerns about the risks of heated tobacco? Well, I think you can already guess what I’m going to say about that, can’t you? No, of course it doesn’t. It’s picking up on something that we already knew – that HnB vapour does contain some carcinogenic substances, although fewer of them and at lower levels than smoke does. It’s a reduced harm product, after all. The whole point is that, even if the harm isn’t totally eliminated, it’s much lower than continuing to smoke. That’s what basic toxicology tells us – and any study that conflicts with basic principles of science is wrong.