Monday, March 17, 2025

The Real Cost of FDA’s “Real Cost” E-Cigarette Campaign

 

FDA staff just published a study in the American Journal of Preventive Medicine titled, “The Impact of ‘The Real Cost’ on E-cigarette Initiation among U.S. Youth.” 

The authors describe the campaign advertisements in the study’s appendix:

“Scary Enough.”  Metal monsters representing toxic metal inhalation

“Addiction Isn’t Pretty: Toilet.”  A teen reaches into a toilet to retrieve an e-cigarette thrown there by another teen, then takes a hit before walking out.

“Toxic Taxidermy.”  The interior of a taxidermy shop showing badly preserved animals who talk about formaldehyde in e-cigarettes.

“Don’t Pollute Yourself.”  A serene natural landscape where a pipeline starts dumping sludge, portraying toxic chemicals, into a lake, which is shaped like lungs.

The FDA authors used a nonpublic survey dataset to measure children’s exposure to the ads, and then they performed a “discrete-time survival analysis… to examine the impact of the exposure index on e-cigarette initiation at follow-up by using logistic regression models that controlled for the above-mentioned demographic and environmental variables.”

In other words, they estimated how many kids age 11-18 did not start using e-cigarettes because of the FDA campaign.  They said the ads prevented 444,252 children from starting to use e-cigarettes in 2023-2024, with a 95% confidence interval between 73,639 and 814,866.

Given that their estimate was more like a guesstimate, the authors should have rounded to the thousands or ten thousands. But, for this exercise, let’s assume the authors’ approach is valid, and that the ads prevented people from using e-cigarettes.  We can also assume that the effect that the authors claimed for 18-year-olds – basically adults – applies to the entire adult smoking population of nearly 27 million, per the 2023 NHIS.

Applying the authors’ analytics to the adult population, the FDA Real Cost Campaign prevented 654,477 adult smokers from switching to far less harmful, even life-saving, e-cigarettes.  The 95% confidence interval is 144,770 and 1,164,098.

I don’t believe the FDA ought to be evaluating its own campaign based on a secret dataset.  Between 2023 and 2024, teen vaping declined, so it’s easy for the FDA staff to claim that a concurrent FDA campaign was responsible.  Even worse, these FDA employees attest that they have “no financial disclosures” and that “The findings and conclusions in this report are those of the authors and do not necessarily represent the official position of the Food and Drug Administration.”  You gotta be kidding me.