Thank you, Mr. Chair, and committee members.
I appreciate the invitation and the opportunity to present to you today. I'm going to present my notes in shorthand, because I don't want to bore you with repetition
Obviously, there's a debate going on. The horse has left the barn: e-cigarettes are a part of our culture today, and to pretend otherwise is foolish and will cost us in the long run.
I will frame my remarks using your study questions and begin with the potential risks, benefits, and challenges. Certainly the public health challenge that is posed by e-cigarettes is how to balance the harm reduction approach with the precautionary principle. Our preferred option is that no one inhales anything into their lungs other than clean, fresh air, a phrase that I think I stole that from the Lung Association. I'll give credit where it's due.
A harm reduction approach recognizes that human beings sometimes behave in ways that are detrimental to their own health and well-being. That's unfortunate, but it's a fact of life. Accepting this, public health authorities establish policies and programs that aim to reduce the harms associated with these behaviours. lt is a principle that supports choosing the lesser of two evils as a means of reducing the societal and personal costs of our own poor choices. On the other hand, we have the precautionary principle that states that complete evidence of a potential risk isn't required before taking action to mitigate the effects of that potential risk. This is also a foundational principle of many public health policies and programs; the two go hand in hand. How do you balance them in this situation?
Clearly, e-cigarettes appear to have potential as a harm reduction tool, but they also pose potential risks for which we don't have complete evidence at this point. As has been stated before, studies are revealing that e-cigarettes seem to contain fewer toxins than traditional cigarettes, but there are serious quality control concerns with what is actually in the e-cigarettes. As has been noted, no e-cigarette product has been systematically evaluated and approved as a smoking cessation device by any governmental agency either here in Canada or abroad. Having said that, I take from an earlier comment that you've heard from the U.K. yesterday, and certainly their Medicines and Healthcare Products Regulatory Agency is currently in the process of reviewing some of these products. We should keep a close watch on their results. I would urge one bit of caution around the remarks coming out of the U.K. It's a very different smoking cessation environment. They're still debating smoking in public spaces there, meaning smoking in pubs, which is still happening. So it's a different kind of landscape. I'm not saying I disagree with their approach, but it is a different cultural environment when it comes to smoking and that has to be taken into consideration.
As has been discussed, e-cigarettes have potential risks, including the direct health risks to users and non-users, as well as their potential as a gateway to traditional smoking. There's just not enough research on these topics, but what we do know, as mentioned before, is that there are wide variations in the nature of toxicity and in the contents of the emissions of e-cigarettes. We know that the short-term effects of e-cigarette use include eye and respiratory irritation caused by exposure to propylene glycol. In terms of the evidence regarding e-cigarette use and more serious diseases, such as cancer, we are decades away from knowing about that, as it takes that long for those diseases to show up.
ln addition to the concerns about the direct health impacts, there's an extensive and really heated debate about whether e-cigarettes will prove to have a positive or negative impact on population health and tobacco control. Are they a gateway? Do we know? We don't know yet. Some studies show possibly. Some are saying, yes, non-smokers are interested and maybe they'll try it, but it's really smokers and former smokers who have the greatest interest in them. We just don't have enough information right now.
Next, I'll speak to the question about the manner in which different jurisdictions have chosen to regulate e-cigarettes. Front-line public health organizations across this country have fought the tobacco wars for decades and have achieved great success in reducing smoking rates through a combination of education, cessation support, policy, and legislation. They are not willing to see these accomplishments destroyed by the re-establishment of smoking as an acceptable behaviour. As you've seen recently, in Toronto and Vancouver, their municipal governments have enacted bans on the public use of e-cigarettes that match the current bans on smoking in public and it's likely going to be replicated in other Canadian jurisdictions.
lnternationally, results from the 2014 World Health Organization survey indicate that 27% of countries have regulated e-cigarettes as consumer products, 6% as therapeutic products, and 10% as tobacco products. However, 51% of countries have no regulatory approach in place at all. The survey also indicated that 39 countries have advertising bans. E-cigarette use in public places is banned by 30 countries. Pre-market review is required by 19 countries. Vendor licences are required in only 9 countries, but 29 countries have already banned the sale of e-cigarettes to minors. Those are some great examples of what other countries are doing right now.
As has been discussed, nicotine is a controlled substance and is addictive. As such, the federal government's current prohibition on nicotine-containing e-cigarettes is appropriate. This prohibition, however, is ineffective and enforcement efforts have been minimal.
Nicotine-containing e-cigarettes are readily available in the United States through the Internet, and probably within walking distance of this committee room, so any policies on managing these products in Canada must presume their general availability. It's a porous border.
What we know is that prohibition doesn't work. It doesn't matter what the substance is. If somebody wants to get their hands on something, they're going to get their hands on it. And if there's money to be made in giving it to those people, others will find a way to make it happen. What we are dealing with in Canada is effectively an unregulated environment and steps do need to be taken to address the situation.
I'm going to echo some of the recommendations that have already been heard, but I think they bear repeating. Canada currently prohibits anyone from making health claims about e-cigarettes until evidence supporting such claims is documented and the government grants regulatory approval for the sale of the product. To date, no e-cigarette manufacturer has gone through this process and, in all honesty, they have no good reason to do so. The status quo suits their business model as long as interdiction and enforcement remain marginal at best. Why would you jump through the hoops and add to the cost of your product when it's a porous market? They can sell them. Estimates range that it could be upwards to a $4-million market in Canada now, and it's only growing.
To the best of my knowledge the Government of Canada has no regulatory instrument at its disposal to compel manufacturers to submit their products for scientific testing. E-cigarettes are a new technology and possibly a new regulatory tool will be required. Until that time, and at the very least, all e-cigarettes should be reviewed for safety under the Canada Consumer Product Safety Act.
As previous speakers have mentioned, we are encouraging the federal government to ban the use of e-cigarettes in all public places under its jurisdiction. We are also calling for the government to place a ban on the advertising, promotion, and sponsorship of e-cigarettes, similar to those in place for tobacco products. The Government of Canada should also regulate e-cigarette solutions with fruit or candy flavours, and the manufacturers and importers should be required to disclose to governmental authorities information about the content and emissions of their products.
Finally, funding is required for additional research into the health effects of e-cigarettes, their efficacy as a smoking cessation device, the epidemiology and toxicology of e-cigarette use, and their psycho-social impact on existing tobacco-control efforts.
Smoking tobacco kills and millions of current smokers will die prematurely from their smoking unless they quit. We know that. We also know this burden falls predominantly on the most disadvantaged in Canadian society. It is the poor who smoke the most. Let's not forget that.
Traditional cigarette smoking remains the most significant and preventable cause of chronic disease today, but given recent cuts to the federal tobacco strategy, it is highly unlikely that that will change in the future. If we don't keep up the war on tobacco, we're always going to be slipping.
The emergence of electronic cigarettes provides a radical alternative to tobacco. However, in order to maximize the potential benefits associated with e-cigarettes, we simultaneously need to minimize the potential harms and risks to society. To do so will require appropriate regulation, careful monitoring, and risk management. What was needed a decade ago was an early and coherent response by the federal government that included a well-funded research program that coordinated with programming and policy and produced useful results within a 3-year to 5-year timeframe. We're long past an early response.
I do urge the government not to lose out on the opportunity for a coherent response now. Thank you.