Nicotineproducten zonder tabak

Reactie

Vraag1

I welcome the opportunity to provide feedback, and submit the following in the hope that it will be helpful in updating the legislation.

I am primarily a user of Electronic Cigarettes, and of Snus, as well as tobacco free nicotine pouches. I am also a consumer advocate for Tobacco Harm Reduction products (hereafter referred to as THR) for the simple reason that I firmly believe these products saved my life, and have a desire to pass that opportunity on to other smokers, many of whom will not be aware.

As part of my advocacy effort I run the safer nicotine wiki (https://safernicotine.wiki) and have created some content, but by no means all of it, as a wiki the site is edited by volunteers. I may refer to pages on the wiki in this comment.

I am not paid in any way for my advocacy, and in fact pay for the bandwidth and time required to maintain the site.

It would be counterproductive to extend smoke free coverage to THR products, these products provide a direct substitute for smoking. As such they should be encouraged, and allowed, except where some sort of harm can be proven.

Vaping for example does not appear to pose a risk from second hand vapour, as can be seen in the following link. Indeed even under conditions described as high level exposure, bystanders where not exposed to hazardous chemicals. Full details available here: http://tobaccoanalysis.blogspot.com/2017/05/vape-shop-air-sampling-by-california.html

Snus and tobacco free pouches do not produce emissions of any sort, so clearly do not need to be included.

Heated Tobacco Products (hereafter referred to as HTP) have also been found to have higher emissions of some potentially hazardous chemicals compared to vaping. However the levels are low enough that the risk to bystanders is negligible.

Risks posed by various THR products are discussed on this page, that is primarily for busting the myth that alternative products are as harmful as cigarettes: https://safernicotine.wiki/mediawiki/index.php/Myth:_Alternative_nicotine_products_are_as_dangerous_as_smoking

Given this evidence, I believe the benefits of encouraging the smoker to switch to THR products far outweigh the risks to bystanders, and as such it would be counterproductive to include THR products in the ban.

Bijlage