

Comment Info: =================

General Comment:Dear Mr. Zeller:

I am writing as an individual consumer to respectfully request an extension of the comment period for the Food and Drug Administration's ("FDA") Proposed Rule Deeming Tobacco Products to be Subject to the Federal Food, Drug, and Cosmetic Act, as amended by the Family Smoking and Prevention and Tobacco Control Act (the "Proposed Rule") published at 79 Fed. Reg. 23,142 and Federal Register No. 2014-09491. On behalf of myself, I am requesting that the comment period for the Proposed Rule be extended by the FDA for an additional 105 days, from its current 75-day period, to 180 days.

The Proposed Rule raises a number of significant issues and questions that are important and relevant to me, as a consumer of products that are proposed for regulation under the Proposed Rule. The Proposed Rule asks about a hundred different questions I might want to respond to. I want to provide my thoughts and comments on many of these issues, but my time to devote to researching and providing thoughtful comments on these important questions is limited. I have already spent many hours researching and dissecting these issues, but they take time. I know that the FDA took many years to even come up with the Proposed Rule, so I do not think it is at all unreasonable to allow the public a mere six months to comment on it. This is our only opportunity, as consumers, to provide our feedback. 

I feel very strongly about e-cigarettes as an alternative to combustible cigarettes. Quite simply, I firmly believe that they saved my life, and the lives of countless others. I wish to provide you with my personal story, as well as science- and evidence-based responses to your questions so that you can take my comment into account. I realize that the FDA has the authority under 21 CFR 10.40 to extend this time frame and that the FDA has exercised this authority on numerous occasions in the past. I would therefore ask that you do so here, so that all stakeholders have the opportunity to provide their comments on this proposed regulation.

E-cigarettes could potentially change the fate of countless Americans and American families.  42.1 million people (CDC, Morbidity and Mortality Weekly Report 2014) 18 years of age and older are smoking. Smokers are estimated to die 10 years before their non-smoking counterparts (New England Journal of Medicine, 21st Century Hazards of Smoking and Benefits of Cessation in the United States). Let's under-estimate the national median income at $45,000 per person for the sake of this example. Let's under-estimate the average tax rate per citizen at %11.00. Every year, every smoker will earn an collective average of 1,849,500,000,000 (1.8t) and pay 203,445,000,000 (203b) in taxes. If smoking electronic cigarettes will prolong the lives of these tax-paying citizens by any measure, it makes sense from both a health and economic standpoint. The above math is vastly flawed in numerous ways, but as a basic example I feel it makes a point. I'm healthier because of my use of e-cigarettes, and I hope the FDA can do whatever it can to help get these devices in the hands of as many legal-age smokers as possible.

I appreciate your consideration of my request and am happy to discuss this issue with you further.

