The needs of more than a quarter of a million people don't matter, according to ASH.
According to a report by Action on Smoking and Health (ASH) out today [link], the needs of 252,000 UK vapers don't matter because most people will only be mildly affected by the arbitrary restrictions imposed by article 20 of the TPD. That is a truly astounding attitude, especially in light of the fact that the expected reduction in smoking prevalence delivered by the entire TPD, including the tobacco provisions, is just 2% over 5 years, which in the UK translates to 183,000 people.
The ASH survey finds that "only" 9% of the UK's 2.8 million current vapers use strengths above the 20mg/ml limit imposed by the TPD. That in itself is bad enough, however the point which ASH so spectacularly miss, is that this cross sectional survey tells us nothing about what strength people used when first using vaping devices. It is entirely possible, indeed probable, that a much larger proportion of those 2.8 million vapers used high strength liquids when they initiated use and then reduced the strength as they became more experienced and learnt the quite different techniques involved in vaping. A peer to peer self selecting survey of 2700 experienced vapers certainly seems to suggest this is true:
(Slide images courtesy of Kevin Crowley)
The restrictions on high strength liquids will prevent many potential switchers from ever getting to that stage because they will not be able obtain sufficient nicotine to satisfy their needs in the early stages. They will also prevent a large number of smokers who use vaping devices to reduce the amount they smoke from succeeding for the same reason. It really is that simple. The numbers involved are by no means trivial. ASH are writing off the needs of 252,000 current vapers and in addition, the needs of 100s of thousands of future switchers and dual users against nothing more than a hope and a prayer that industry might come up with a solution for these people by 20th May 2017. I'm sure it will eventually, but the black market will come up with one quicker.
But it doesn't stop there.
The ASH survey also reports that only 11% of daily vapers use more than 4ml of liquid a day and so will have to refill their devices more than twice a day. Apart from the fact that in a 2ml tank (the maximum capacity imposed by the TPD) only about 1.5ml is usable, the fiddle of having to constantly refill is a further and unnecessary barrier to switching. In terms of risk of poisoning, the stated basis of this policy, it is far easier to get liquid from a bottle (maximum capacity allowed 10ml) than a tank. In any case the nicotine toxicity levels upon which this policy was based have been described as out dated and grossly over exaggerated by scientists currently working in the field.
Finally, the survey reports a shocking increase in the number of people who incorrectly believe that e-cigarettes are equally or more harmful than cigarettes, and an associated decrease in the number who correctly assess them as a lot less harmful. This is hardly surprising given the media treatment of the subject, but equally, a major influence will be the bans which people see imposed all around them. Every time a hospital, a council, a stadium or even a beach in Wales includes vaping in smoking restrictions or imposes a blanket ban instead of carefully crafting a policy which accommodates the needs of all visitors this sends the message that vaping devices are as harmful as cigarettes and something to be feared. The intended message may be that vaping is a benefit to public health and poses no risk to bystanders but the received message is something very different.