

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

General Comment:Re: Request for Extension of Comment Period: Docket No. FDA-2014-N-0189

As owners of JRILY Enterprises, LLC, DBA eJuiceMonkeys, we’ve conducted a preliminary review of the 240-page proposed regulations. We respectfully request the Food and Drug Administration (FDA) extend the comment period for proposed rule “Deeming Tobacco Products to be Subject to the Federal Food, Drug, and Cosmetic Act, as Amended by the Family Smoking Prevention and Tobacco Control Act; Regulations on the Sale and Distribution of Tobacco Products and Required Warning Statements for Tobacco Products.” 

We are a small liquid manufacturer and online retailer/distributor, employing fewer than 350 people. We started eJuiceMonkeys as a result of our own personal experience with personal vaporizers (electronic cigarettes), and we have grown to unexpected levels without advertising or marketing. This is because we provide customers a quality product with responsible, continuous support. Our growth means we now contribute to our economy in a much larger way. We provide double the federal minimum wage jobs, generate our own income, make repeated large purchases from other domestic businesses, support charitable organizations and pay over $100,000 annually in state and federal taxes. 

The preamble to the proposed rule identifies approximately 70 topics and issues the Agency requests comments on. Many of these issues are complex and difficult, and relate to an extremely diverse array of products. Clearly, the lengthy time period the Agency required to formulate and propose these regulations is evidence that the issues in the proposal are multi-faceted and challenging. FDA cannot expect any interested party, and in particular, any manufacturer, to conduct a meaningful review and analysis allowing detailed and thoughtful comment in such a short period. 

The  initial 75-day comment period for the proposed rule simply does not provide enough time for emerging, small businesses like ours to adequately analyze the entire proposal, or provide substantive comments on the numerous questions posed in it. We need more time to address items in the 240-page document, as they will deal a devastating economic blow to our business, and may well close its doors.

Therefore, eJuiceMonkeys again respectfully requests the FDA extend the comment period to 180 days. This will help ensure the final rule is based on adequate and meaningful administrative records. Thank you in advance for your consideration of this request.

Sincerely,

Sharon A. Goodson
Alan W. Goodson
Co-owners JRILY Enterprises LLC, DBA eJuiceMonkeys

