On Friday afternoon, December 9th, during the Christmas season, Health Canada released its overdue legally-mandated review of the Tobacco and Vaping Products Act (TVPA). From the timing, it seemed they wanted to avoid any publicity.

The review pays lip service to vaping as a less harmful source of nicotine, and a pathway to quitting, for Canada’s 3.8m smokers, but then goes on at great length about youth vaping, while largely ignoring the health of the Canadians who still smoke.

Health Canada’s self-congratulatory review of the TVPA concluded that “in general, the TVPA appears to be making progress towards achieving its vaping-related objectives and that amendments at the level of the Act are not necessary at this time.”

They report that the objective of controlling youth vaping has largely been achieved. 85% of youth aged 15-24 have not even vaped once in the last 30 days, and this number has not changed between 2019 and 2021. Overall, only 1.1% of Canada’s daily vapers have never smoked. Vaping is not leading to tobacco use by young persons, as “youth smoking rates are at an all-time low in Canada and the US.” Now it is time for Health Canada to pay attention to the health benefits of vaping for Canadians who smoke.

Health Canada is not following the science and promoting vaping as a way to quit smoking

Health Canada is not following the science on vaping as an effective way to quit smoking and as a long-term less harmful alternative to smoking. The report notes that most academics “recommended that Health Canada adopt a harm reduction approach to vaping. They favoured an approach more in-line with the United Kingdom and New Zealand who have implemented proactive public education campaigns to promote switching from cigarettes to vaping products.”

Health Canada says its actions are limited by the lack of a comprehensive assessment of the health hazards and potential benefits of vaping, but by September 2022 the UK government had already posted the full text of its 1,468-page evidence update, including health risks, on its website. The review concluded that vaping is 20x safer than smoking. The widely-respected Cochrane Collaboration has announced that it is certain that e-cigarettes help smokers quit. There is no need to wait while Health Canada repeats these studies.

The 2021 Evaluation of the Health Portfolio Tobacco and Vaping Activities recommended that vaping-related information on the Government of Canada’s website be updated, but this has yet to be done. Meanwhile, Health New Zealand has created a “Vaping Facts” website that clearly states “Vaping has helped many people quit smoking and is a legitimate way to become smoke-free.”

Communication Issues

The TVPA review states that “Work could be undertaken to communicate the relative risk of smoking, in comparison to vaping, to people who smoke.” This essential work is long overdue. Official statistics from 2019 show that 54% of Canadians, and 39% of family doctors, falsely believe that vaping is as dangerous, or more dangerous, than smoking. Only 4% of respondents correctly stated that vaping is much safer than smoking. So far, nothing has been done to correct this misinformation.

Section 30.43 of the TVPA actually prohibits telling smokers the truth about vaping: “To ensure that the public has access to accurate information in order to make well-informed decisions about vaping products, the TVPA prohibits the promotion of vaping products that could cause a person to believe that their use may provide a health benefit or that compares the health effects of using a vaping product versus a tobacco product.” This is nonsensical. The Honourable Carolyn Bennett, Minister of Mental Health and Addiction and Associate Minister of Health says “Vaping products offer the 3.8 million Canadians who smoke a less harmful source of nicotine than tobacco products, and do help people to stop smoking”. However, Section 30.43 of the TVPA prevents someone running a vape shop from giving this information to a potential customer! This section of the TVPA is an affront to free speech should be eliminated immediately.

The review mentions two possible ways to resolve the problem of providing information to smokers about the benefits of switching to vaping without encouraging non-smoking youth to start.

One option is to allow the “use of permitted statements that convey the health benefits of using vaping products or that compare the health effects of using vaping products to those associated with tobacco product use.” This refers to statements such as:

1. If you are a smoker, switching completely to vaping is a much less harmful option

2. While vaping products emit toxic substances, the amount is significantly lower than in tobacco smoke

These non-controversial statements come from a draft consultation in September 2018, but they have never been implemented.

Secondly “Some provinces recommended the inclusion of a mandatory leaflet in cigarettes packages that would explain the health benefits of vaping and other NRT products as a way to promote harm reduction to those who smoke.” This simple idea for providing highly targeted information has been discussed for years but was never implemented.

Canada’s Tobacco Strategy (CTS) fails to recognize long-term benefits of switching

“The CTS recognizes the potential of harm reduction – helping those who cannot or do not wish to quit using nicotine to identify less harmful options …. choosing to use these products in the context of harm reduction should be considered a temporary measure to support smoking cessation.”

The Lower-Risk Nicotine Use guidelines published by the Centre for Mental Health and Addictions (CAMH) disagree that the use of less harmful products should be temporary as “Continued use of e-cigarettes may reduce risk of relapse to combustible tobacco.” Combustible cigarettes are so dangerous that anything that prevents people from relapsing back to smoking is worth doing.

Lack of product availability

The least harmful commercial nicotine products are tobacco-free oral nicotine pouches, such as “Zyn” and “Velo,” but all of these products are unauthorized for sale in Canada. In defiance of the science, they are called a serious health risk by Health Canada.

While Health Canada is lamenting that “To date, no vaping products have been approved under the Food and Drugs Act for therapeutic use as a smoking cessation aid,” the UK Government is actively encouraging vape manufacturers to produce a vape that can be made available on prescription.

Conclusion

Health Canada has spent $7.1 million on youth vaping, which has killed no -one in Canada.

It has done nothing to inform Canadian adults who smoke about the benefits of vaping, either as a scientifically-proven way to quit, or as a safer long-term alternative source of nicotine.

Every month that Health Canada delays, another 4,000 Canadians die from tobacco use.