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Reduced nicotine rule: a terrible idea to be pursued relentlessly

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Presentation to FDLI conference 26th October 2017. For more information and full report see: https://www.clivebates.com/fda-wants-to-reduce-nicotine-in-cigarettes-what-could-possibly-go-wrong-and-right/

Published in: Health & Medicine
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Reduced nicotine rule: a terrible idea to be pursued relentlessly

  1. 1. Reduced Nicotine Rule A terrible idea (...to be pursued relentlessly) Clive Bates Counterfactual FDLI meeting 26 October2017 Washington DC
  2. 2. A terrible idea 1 % 1. A prohibition
  3. 3. A terrible idea • Stockpile cigarettes or trade with stockpilers • Import conventional cigarettes via internet • Switch to other combustible products: hand rolling tobacco, pipes, cigars, hookahs, shisha • Contraband or counterfeit conventional cigs • Counterfeit low-nicotine with high nicotine • Take advantage of product innovation • Take advantage of process innovation • Switch to ANDS – non-combustibles • Add nicotine liquid to low-nicotine cigarettes • Other substance use – e.g. marijuana • Alternative risk behaviours • Fraudulent solutions and quack remedies • Some mixture of above – including dual use • Quit smoking, tobacco and nicotine use • Use very low nicotine cigarettes? 1. A prohibition 2. Unpredictable response
  4. 4. A terrible idea 1. A prohibition 2. Unpredictable response 3. Little relevant research
  5. 5. A terrible idea 1. A prohibition 2. Unpredictable response 3. Little relevant research 4. Perverse consequences
  6. 6. A terrible idea U.S. Tobacco Control Act §907.d.3 1. A prohibition 2. Unpredictable response 3. Little relevant research 4. Perverse consequences 5. Poor mandate Limitation on Power Granted to the Food and Drug Administration Because of the importance of a decision of the Secretary to issue a regulation A. banning all cigarettes, all smokeless tobacco products, all little cigars, all cigars other than little cigars, all pipe tobacco, or all roll-your-own tobacco products; or B. requiring the reduction of nicotine yields of a tobacco product to zero, the Secretary is prohibited from taking such actions under this Act
  7. 7. A terrible idea 1. A prohibition 2. Unpredictable response 3. Little relevant research 4. Perverse consequences 5. Poor mandate 6. Brutal politics
  8. 8. A terrible idea Regulate toxins Raise taxes Control additives Plain packaging 1. A prohibition 2. Unpredictable response 3. Little relevant research 4. Perverse consequences 5. Poor mandate 6. Brutal politics 7. Superior alternatives
  9. 9. A terrible idea 1. A prohibition 2. Unpredictable response 3. Little relevant research 4. Perverse consequences 5. Poor mandate 6. Brutal politics 7. Superior alternatives
  10. 10. To be pursued relentlessly 1. Alternatives essential
  11. 11. To be pursued relentlessly 1. Alternatives essential 2. Proportionate regulation
  12. 12. To be pursued relentlessly 1. Alternatives essential 2. Proportionate regulation 3. Coercion paradox
  13. 13. To be pursued relentlessly 1. Alternatives essential 2. Proportionate regulation 3. Coercion paradox 4. An ‘agency threat’
  14. 14. Counterfactual Weapons don’t have to be used to be useful www.clivebates.com @clive_bates

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