Project CBD Sunday: What Should We Do About Vaping?
Thanks to our friends at Project CBD for letting us repost their article.
Regulation – not prohibition – is long overdue.
BY MARTIN A. LEE & ZOE SIGMAN ON SEPTEMBER 27, 2019
There was a time when glossy magazine ads touted the supposed health benefits of cigarette smoking. For years, mainstream media and public officials routinely aided and abetted the false claims of the tobacco industry until the publication of the U.S. Surgeon General’s 1964 report on Smoking and Health. Cigarette commercials were subsequently banned from television, but tobacco products were never outlawed.
More than a half century later, the nicotine capitalists are at it again. This time they’ve been claiming that highly addictive e-cigarettes are safer than smoking. And until now they’ve gotten a free pass from industry-friendly “regulators” who don’t seem to give a hoot about all the toxic crap – especially texturizing and flavoring agents – that’s added to e-cig juice. Aimed at teens as well as adults, Juul ads were extolling the virtues of vaping on national television at the very moment the Center for Disease Control (CDC) issued an alarming report that attributed a sudden outbreak of deaths and pulmonary disease to the consumption of harmful vaping products.
Many of the same sketchy additives that are ubiquitous in e-cigarettes are present in cannabis and CBD vape oil blends. CBD vapes can easily be purchased from head shops, gas stations, internet storefronts, and an assortment of less-than-savory underground sources.
Over 500 people, including teenagers and seniors, have been hospitalized with problems ranging from shortness of breath to severe nausea and coughing up blood. Nine deaths have been reported thus far. The likely cause is “unknown chemical exposure,” according to the CDC, which has not been able to conclusively link a single product or substance to vaping disease incidents. Any number of questionable chemical combinations could be the culprit.
Of those who were stricken by vaping-related lung disease, some had been using only nicotine e-cigarettes. But most cases have involved people who vaped poor quality, unlicensed cannabis oil products. Many of the same sketchy additives that are ubiquitous in e-cigarettes are present in cannabis and CBD vape oil blends. CBD vapes can easily be purchased from head shops, gas stations, internet storefronts, and an assortment of less-than-savory underground sources.
Tobacco smoke and cannabis smoke both contain noxious polyaromatic hydrocarbons and carbon monoxide, but the negative effects of cannabis smoke are significantly mitigated by the cytoprotective and antitumoral properties of THC, CBD, and other cannabis components; thus, there is no causal link between smoking cannabis and cancer.
Some black market vape oil products are also spiked with potent synthetic intoxicants (erroneously described as “synthetic marijuana”) and other dubious compounds, such as vitamin E acetate.
Project CBD has been warning about the potential dangers of toxic vape oil additives, particularly thinning agents and flavoring additives, since 2015, a year before e-cigarettes came under the FDA’s regulatory purview. Thinning agents, such as propylene glycol and polyethylene glycol, and loads of flavoring additives so dear to the processed food industry are approved by the FDA based on data related to oral consumption of ingestible compounds. But there’s little evidence to show that FDA-authorized texturizing agents and flavoring agents are safe when heated and inhaled. Heating or combustion can change a compound into something much more dangerous than the original. Such is the case with many e-cigarette additives that the FDA deems safe for ingestion.
The CDC has not been able to conclusively link a single product or substance to vaping disease incidents.
Let’s be clear: inhaling additive-free, artisanal whole plant cannabis oil with a well-made vaping device is just as safe, if not more so, than smoking organically grown cannabis. Tobacco smoke and cannabis smoke both contain noxious polyaromatic hydrocarbons and carbon monoxide, but the negative effects of cannabis smoke are significantly mitigated by the cytoprotective and antitumoral properties of THC, CBD, and other cannabis components; thus, there is no causal link between smoking cannabis and cancer.
One of the advantages of vaping over smoking is the odorless discretion it affords the consumer in a society that continues to stigmatize cannabis. As the vaping scandal unfolds, one can detect a whiff of moral panic reminiscent of past chapters of cannabis history: The Assassin of Youth is back with a vengeance, lurking in a vape cartridge.
Trade industry groups, who were radio silent on the dangers of vape oil additives before the scandal surfaced, are now professing concern about the health risks of illicit vaping options.
Different groups have been trying to spin the vaping tragedy to advance their own agendas. Prohibitionists are calling for a total ban on vaping cannabis. Trade industry groups, who were radio silent on the dangers of vape oil additives before the scandal surfaced, are now professing concern about the health risks of illicit vaping options. And there’s always China to blame for exporting cheap vape pens with erratic heating coils that turn seemingly benign compounds into carcinogens and cause tainted oil to smolder.
MISGUIDED VAPE ADDITIVE POLICIES
It’s certainly possible to make high quality artisanal vape oil without additives or solvent residues, as is the case with some of the leading cannabis brands. And it’s generally true that state-licensed cannabis companies provide better quality vape oil products than black market sources. But state regulators continue to follow the Food and Drug Administration’s lead with respect to thinning agents and flavoring agents. Consequently, these FDA-approved additives are widely present in e-cigarettes and much of the legal cannabis market, despite a lack of relevant safety data.
Any thinning agent or flavor-enhancing chemical that has not been safety tested for heat and inhalation exposure should be prohibited as a cannabis oil additive.
The FDA is a big part of the vaping problem. State health officials should not take their cues from the FDA when it comes to regulating vape oil additives. Project CBD, in public comments submitted to the FDA, stated: “The precautionary principle mandates that any thinning agent or flavor-enhancing chemical that has not been safety tested for heat and inhalation exposure should be prohibited as a cannabis oil additive.”
The solution isn’t to ban cannabis vaping across the board. Such a misguided policy would be both impractical and counterproductive, boosting black market commerce and increasing risks for users. That’s an example of unnecessary overreach. Rather than banning an entire product category – be it vapes or edibles – state health officials should implement a rigorous regulatory program that prioritizes public health and raises the safety standards for all edibles and food supplements.
VAPING COMMENTS FOR THE FDA
These are excerpts from Project CBD’s comments to the FDA:
CBD consumers frequently assume that vaping cannabis or hemp oil is a healthier method of administration than inhaling smoke, which contains noxious substances that can irritate the lungs. Theoretically a vaporizer heats the cannabis oil concentrate without burning it so the active ingredients are inhaled but no smoke is involved. But there may be a serious downside to vaping CBD oil and other cannabis oil extracts. Vape pens contain a battery-operated heating mechanism, which at high temperatures can transform solvents, thinning agents and flavor additives into carcinogens and other dangerous toxins.
Here are some of our concerns:
- Many vape oil cartridges include propylene glycol (PG) or polyethylene glycol (PEG) as a thinning agent, but neither has been safety tested by the FDA for inhalation when heated. Because of low oral toxicity, PG is classified by the FDA as “generally recognized as safe” for ingestion as a food additive. PG is also the primary ingredient in a majority of nicotine-infused e-cigarette solutions. At high temperatures, PG and other vaping additives convert into carbonyls, a group of cancer-causing chemicals that includes formaldehyde, a toxin linked to spontaneous abortions and low birth weight.
- FDA-approved flavoring agents are prevalent in nicotine e-cig products and CBD/cannabis vape oil cartridges, but these additives were officially approved on the basis of safety tests for ingestion and topical application, not for inhalation as heated compounds. A 2018 study by University of Rochester scientists found that exposure to commonly used e-cigarette flavoring chemicals and liquids is toxic to white blood cells.
- Many flavoring compounds are toxic when heated and inhaled; cinnamon, vanilla and cream flavors among the most toxic. A recent report by Yale University researchers showed that mixing chemical flavoring agents is more dangerous than exposure to a single additive. Moreover, some flavor additives interact with PG and PEG to form noxious acetal compounds. When heated and inhaled these inflammatory chemicals persist in the body for some time and irritate the lungs.
- A chemical called diacetyl is added to e-cigarettes and vape oil cartridges to simulate various buttery flavors, ranging from cream to vanilla and caramel. This particular compound is known to cause “popcorn lung,” a crippling and sometimes fatal respiratory illness. A shocking 2015 study of flavored e-cigarettes found that 39 out of 51 tested brands contained diacetyl. It should be banned from use in vape oil.
Consumers who vape cannabis oil products should not be exposed to harmful compounds.
Project CBD has urged the FDA and state officials to prohibit the use of any thinning agent or flavor-enhancing additive that has not been safety tested for heat and inhalation exposure. A similar standard should apply to additives in nicotine e-cigarettes.
- “Outbreak of Lung Injury Associated with E-Cigarette Use, or Vaping.” Center for Disease Control, Sept 19, 2019. https://www.cdc.gov/tobacco/basic_information/e-cigarettes/severe-lung-d…
- State regulators have mimicked FDA policies when crafting rules about CBD in edibles. Although CBD is much safer than many FDA-approved food additives, CBD has not gotten federal approval as an edible ingredient or a food supplement. In lockstep, California and several other states have banned hemp-derived CBD edibles, citing FDA concerns.
- It’s worth noting that “vaporizing” can refer to two separate forms of administration. There are dry-herb vaporizers, which gently heat whole plant flower to temperatures below combustion to create a true vapor. These vaporizers may very well provide a safer form of inhalation than smoking. Vape pens, on the other hand, are similar to e-cigarettes and involve heating a cartridge filled with cannabis/CBD oil. There is no regulation on how vape pens are manufactured and some can heat to very high temperatures (up to 1000ºF) and inhaling the resulting smoke or vapor. These likely have a less safe profile, and likely have similar risks to smoking.
- Muthumalage, Thivanka, et al. “Inflammatory and Oxidative Responses Induced by Exposure to Commonly Used e-Cigarette Flavoring Chemicals and Flavored e-Liquids without Nicotine.” Frontiers in Physiology, 11 Jan. 2018, www.frontiersin.org/articles/10.3389/fphys.2017.01130/full.
- Eythropel, Hanno C, et al. “Formation of Flavorant–Propylene Glycol Adducts With Novel Toxicological Properties in Chemically Unstable E-Cigarette Liquids.” Oxford Academic, Oxford University Press, 18 Oct. 2018, academic.oup.com/ntr/advance-article/doi/10.1093/ntr/nty192/5134068.
- Allen, Joseph G, et al. “Flavoring Chemicals in E-Cigarettes: Diacetyl, 2,3-Pentanedione, and Acetoin in a Sample of 51 Products, Including Fruit-, Candy-, and Cocktail-Flavored E-Cigarettes.” National Institute of Environmental Health Sciences, Environmental Health Perspectives, 1 June 2016, ehp.niehs.nih.gov/doi/10.1289/ehp.1510185.