Agency Information Collection Activities: Submission for OMB Review; Comment Request; FTC File No. P14504 #00007

Submission Number:
George Packard
Initiative Name:
Agency Information Collection Activities: Submission for OMB Review; Comment Request; FTC File No. P14504
Hello, In the interest of full disclosure, I own and operate a small brick and mortar electronic cigarette store in rural northern Wisconsin. I am a former smoker of 15 years who has tried several of the prescription and OTC nicotine replacement therapies and medications to help me to quit smoking to no avail. I am a firm believer that E-Cigarettes are less harmful to their user than a cigarette and there is a lot of qualified data to support this conclusion. I am also a realist who believes that sensible regulations are a good thing for any industry. I also feel that minors should not be allowed to purchase these products, a sentiment shared by the entire vape industry. The issue that is of the most concern to the FTC at this time is marketing and I do not envy those of you who are tasked with making a decision on what is an "appropriate" advertisement aimed at consenting adult user of the products and what is not. The largest hurdle that will have to be overcome is creating a criteria for differentiating between advertisements aimed at minors and those that are aimed at adults because both age groups enjoy similar things. For example, I (31, male) am currently using an e-liquid that is watermelon bubblegum flavored. Many in the anti-vaping camp have said that bubblegum flavored liquids were developed to entice children and, frankly, they are incorrect as I sell several bottles of this particular flavor a week and estimate that the average age of the purchasers is about 35. Yes, adults like bubblegum too. They also like fruity, creamy, and bakery flavors. There is no difference between the tastebuds of a 17-year-old and an 18-year-old. I read the comments submitted last year and feel that there is ample research to dispute many of the claims made by anti-vaping special interest groups and many uneducated individual, should they choose to listen. It would be nearly impossible to appease someone who's mind is already made up on the subject. One statement stands out in my mind. You can find it in submission #27 from the American Lung Association. They cite a study by 'The Truth Initiative' that states that 84% of those aged 13-21 (of which a portion were legal consumers in most states) have seen an advertisement for an electronic cigarette, the vast majority (71%) being retail displays/product packaging. What they choose not to tell you is that very similar numbers of that age group has also seen ads for Crestor and Lipitor with no ill effects. Please ask yourself what harm could come to someone who is not the intended audience of a product advertisement? I'll bet that you have been exposed to hundreds, if not thousands, of potential advertisements this week that have no effect on your daily lives and the decisions that you make and you haven't been harmed. I ask on the behalf of myself and all of the rest of the consenting adults who choose to use these products that you approach the subject of electronic cigarette advertisements with a level head and an open mind. Thank You George Packard