FDA Unveils New Smoker Numbers to Justify a Menthol Ban

 

In its proposed rule to ban menthol cigarettes, the FDA makes a bizarre claim: “In 2019, there were more than 18.5 million current smokers of menthol cigarettes ages 12 and older in the United States.”

The agency derived this number from the National Survey on Drug Use and Health (NSDUH), which reported that 18.3 million adults and 260,000 youth 12-17 years old smoked menthol cigarettes in 2019.

Using that same survey, however, the total number of smokers in 2019 was 46.2 million -- 45.6 million adults and 600,000 youth age 12-17.

No federal official or agency has ever suggested there were that many smokers in 2019.  The CDC and the FDA only acknowledged the existence of 34 million adult smokers and 886,000 youth smokers, using the National Health Interview Survey (NHIS) and National Youth Tobacco Survey (NYTS), respectively. 

The CDC and FDA use the NYTS youth number (886,000), which is nearly 50% higher than the 600,000 reported by the NSDUH.  This is further evidence of why the NYTS numbers should never be the final word for youth tobacco use (here and here). 

Using the FDA’s NSDUH number for adult smokers, the comparison with the NHIS number it formerly used is almost as bad, and in the opposite direction.  Now the agency menthol claim implies that there were 45.6 million adult smokers in 2019 (NSDUH), but before it only acknowledged 34 million (NHIS).

What did the FDA do with 286,000 youth and 11.6 million adult smokers?

When they want to emphasize big smoking numbers, the FDA and CDC use NSDUH and NYTS data.  When they prefer smaller numbers, they use the NHIS.  I have highlighted this deception since 2009. 

It is time to hold these agencies accountable, especially when the FDA uses this manipulation to justify punitive regulation. 

 

 

Federal Officials, Please Pay Attention to Federal Surveys: E-Cigarettes Are Not Gateway Products

I noted in 2013 that the CDC director’s claim – that “many kids are starting out with e-cigarettes and then going on to smoke conventional cigarettes” – was pure gateway speculation (here).  Youth surveys had just started collecting information that teens were using e-cigarettes, but there was zero evidence that they were “going on to smoke.”

In January I presented data from the CDC’s National Youth Tobacco Survey showing that e-cigarette experimentation since 2011 did not produce an epidemic of teen smoking (here).  The 2017 Monitoring the Future survey, illustrated in the chart at left, provides further evidence of a steady decline in cigarette smoking among high school seniors.  In 2017, the smoking rate in MTF dropped below 10% for the first time in history.  At 9.7%, the rate is almost half that of 2011 (18.7%), while the vaping rate remained at 16-17%.  Meanwhile, high school seniors used alcohol and marijuana at far higher rates than cigarettes (33% and 23% respectively).  Nineteen percent of seniors reported being drunk in the past month.

MTF vaping data in 2014-2016 didn’t specify the liquids used; in 2017 MTF collected information on non-specific vaping and vaping nicotine and marijuana in the past month.  Nonspecific vaping, illustrated by the green line in the chart, was around 16%, nicotine vaping was 11%, and marijuana vaping was 4.9% in the past month.

Federal officials are still obsessed with the vape-to-smoke gateway, despite virtually no evidence.  FDA Commissioner Scott Gottlieb recently tweeted a warning: “The [e-cigarette] industry isn’t sustainable if it leads to a whole generation of youth initiation on tobacco.” (here) 

I tweeted a reply urging Dr. Gottlieb to look at his agency’s data from the “…PATH survey of 9,909 never-smoking teens. One year later, 219 (2.2%) had smoked in past 30 days. All awful, but 175 (80%) had no prior tobacco product use; only 11 had used e-cigs. FDA data shows vaping not major gateway to teen smoking [here].” (emphasis added)

Federal officials should stop claiming that vaping is a gateway to smoking, because evidence is absent in all federal surveys.

1.7 Million High Schoolers Vaped in 2016, As Both Vaping and Smoking Declined

The Centers for Disease Control and Prevention 2016 National Youth Tobacco Survey (NYTS) shows that 1.08 million (7.2%) American high school students used e-cigarettes in the past 30 days, 580,000 (3.9%) smoked, and 660,000 (4.4%) used both products.

Compared with 2015, smoking declined by about 14% and vaping by 28%.

The apparent spike in e-cigarette use from 2013 to 2014 was partially due to what scientific researchers refer to as an artifact, as it stemmed from a change in the survey design.  Questions about e-cigarette use were bundled with those for other rarely used tobacco products until 2014, when they appeared in a separate section. 

The NYTS also collected information on how many days e-cigarettes were used in the past month.  The chart below shows that 7 out of 10 students who vaped but did not smoke used e-cigarettes five days or fewer.  This is basically “party” or “weekend” vaping, rather than regular use.  While half of high school students who vaped and smoked used e-cigs five or fewer days, 22% used them all 30 days.

Last June, the CDC published selected information from the 2016 NYTS (here), listing smoking and vaping rates separately, effectively double-counting the 660,000 high-schoolers who vaped and smoked.  The CDC only released the full NYTS data set earlier this month (here).
   

The federal data confirm that e-cigarette experimentation by youth since 2011 has not produced an epidemic of smoking.  In fact, the decline in youth smoking accelerated to a record low rate.