

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

General Comment:Dear Mr. Zeller:

I am writing as an individual consumer to 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 FDA, took more than three years to issue its 241-page Proposed Regulation (and accompanying 81-page regulatory impact analysis), has given we, the consumers and manufactures, a mere 75 days to comment. While responding in that timeframe is challenging, the FDA has also posed approximately 99 requests for information about THR products (this does not include repeat questions or questions specifically pertaining to cigars). Given the length of time FDA has taken to release the proposed regulations, the massive amount of information FDA is requesting, the length of the document itself, and the devastating impact these regulations will have on a product that is estimated to be approximately 99% less hazardous than combustibles, the 75-day comment period is grossly inadequate.

The Proposed Rule raises a number of significant issues and questions that are important and relevant to me, as a consumer of these 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 very 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 may save my life. Myself and others may wish to provide you with a personal story, as well as, perhaps, scientific 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.

I cannot help but question just who (besides the FDA) is pushing for so many of these regulations.  My motto is always ‘Follow the Money’ and in most instances that has led me to the truth.  I am assuming anyone related to the tobacco industry as well as the pharmaceutical companies, are behind so much of the regulations as they are the ones losing tremendous financial resources!  Obviously I do not want to engage, knowingly, in something that is detrimental to my health.

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

