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.   

 

2023 High School Seniors Preferred Alcohol and Marijuana, But Almost Abandoned Cigarettes

 

My readers know that I have followed the results of the annual Monitoring the Future Survey (MTF) for many years, focusing on alcohol, marijuana and tobacco use among high school seniors.  The 2023 MTF results, released in December (here), indicate that past 30-day (i.e., current) use of all products declined from the previous year (as seen in chart at left).    

Despite its illegality, drinking alcohol retained its decades-long top-substance status among seniors at 23%, down significantly from 28% in 2022.  Marijuana was second at 18%, one point higher than the 17% of seniors vaping nicotine in the past 30 days, which was a significant 4 percentage point decline from the year before.  Happily, current smoking remained at the bottom of the chart, at a new low of 2.9%.    

Another fascinating MTF finding (not on my chart) is that 18% of seniors currently consumed flavored alcohol, one point higher than those who vaped nicotine.  Protecting teens from flavors has driven the FDA’s attempts to ban vape flavoring and these products are being prohibited outright in jurisdictions across the country.  Flavored alcohol is far more dangerous for teens, but those products are apparently beyond the FDA’s reach, and no one has yet established a Campaign for Alcohol Free Kids. 

 

FDA Creates, Decries Illegal E-Cigarette Tsunami

 

An article in the LA Times January 2^nd bemoaned the “thousands of new flavored products…pouring into the country from China.”  It claimed, “Nearly all the new products are disposable e-cigarettes, according to sales data gathered from gas stations, convenience stores and other shops. The products generated $3.2 billion in the first 11 months of this [sic] year.”

The response from Brian King, director of the FDA Center for Tobacco Products, was naïve: “Those committing illegal acts don’t advertise their crimes, and those trying to import illegal tobacco products into the United States are no different.  The FDA and our federal partners are using tools, like import alerts, to stop these illegal tobacco products at the border and to deter countless others.” (emphasis added)

Dr. King ignores history.  A contemporary account of the first day of Prohibition in the U.S., January 17, 1920, noted, “Canadian liquor in quantities from one gallon to a truckload is being hidden in the northern woods and distributed by automobile, sled and iceboat, on snowshoes and skis.”

Neither Dr. King nor his FDA colleagues are going to stop the illegal vape tsunami.  When the FDA issued a toothless warning letter last May to the Chinese maker of Esco Bars e-cigarettes, it failed to note that the product’s name is a salute to one of history’s most successful illegal importers – Pablo Escobar. 

My readers will recognize another tobacco prohibitionist in the LA Times article -- Stanford University’s Bonnie Halpern-Felsher.  I’ve criticized her previous research, but here she comes across as a realist: “FDA whacks one product and then the manufacturers get around it and the kids get around it.  It’s too easy to change your product a little bit and just relaunch it.”

Halpern-Felsher wants all vapes banned… for the children, foreseeing a vaping apocalypse: “If we continue down this path that we’re on, we’re just going to have new and continuing generations of young people addicted to nicotine.”

Yes, regardless of what the FDA or anyone else does, some teens and young adults will become addicted to nicotine.  But as shown in the chart below, few will die from nicotine over the next 30 years, as almost none of these vaping youth smoke.