Unacceptable on what ethical basis? @fdatobacco surely recognises the reality-based world of youth doing risky things, whatever FDA wants? When kids who would otherwise have smoked take to #vaping instead, there is a clear public health benefit. Preventing that causes harm. 1/7
There is something disturbing about this argument, beyond the obvious indifference to the health and wellbeing of young people from more disadvantaged backgrounds. It’s an attempt to simplify the world by declaring a moral posture rather than deal with the world as it is. 2/7
And why do this? Because @FDATobacco’s favoured #vaping policies - e.g. banning e-liquid flavors and bullying @JUULvapor - are impossible to justify if #ecigs are reducing youth smoking. So that potential benefit can’t be recognised. 3/7
Given regular vaping is highly concentrated in adolescents who smoke; many adolescents give ‘harm reduction’ reasons for vaping; and benefits to a smoker who switches to vaping is far greater than cost to a never-user who takes it up, a net benefit to *youth* is quite likely. 4/7
This destroys the youth-based narrative and political foundations of @FDATobacco’s ‘tough-guy’ stance on vaping. They might be doing harm to youth as well as to adults. And it certainly can’t show it would not cause harm - especially given the rapid declines in youth smoking. 5/7 
The problem for @SGottliebFDA is that the public health test in the Tobacco Control Act does not adopt this moral posture. It does not allow FDA to be a cause of greater harm through poor policy simply because its leaders wish the world was different to how it is in reality. 6/7
So, it is helpful to have this reasoning - however perverse - on the record. Ruling out, a priori, a whole category of important benefits in the rule-making process will not stand up to legal or ethical scrutiny. 7/7
