1 in Addition to the 19 Constituents FDA Proposes to Add to the List Of
In addition to the 19 constituents FDA proposes to add to the list of Harmful and Potentially Harmful Constituents, FDA should also add compounds that may be carcinogenic or cause pulmonary or cardiovascular harms when inhaled, especially oils and chemicals and chemical classes found in e-cigarette flavorants, and FDA should use as additional criteria California’s Proposition 65 list of carcinogens and reproductive toxicants and the California Air Resources Board’s list of Toxicant Air Contaminants UCSF TCORS Lauren K. Lempert, JD, MPH; Gideon St.Helen, PhD; Jeff Gotts, MD; Shannon Kozlovich, PhD; Matthew Springer, PhD; Bonnie Halpern-Felsher, PhD; Stanton A. Glantz, PhD Docket No. FDA-2012-N-0143 October 2, 2019 FDA is proposing to add the following 19 toxicants that may be found in tobacco products, including electronic cigarettes, to the list of HPHCs: acetic acid, acetoin, (also known as 3-hydroxy-2-butanon3), acetyl propionyl (also known as 2,3-pentanedione), benzyl acetate, butyraldehyde, diacetyl, diethylene glycol, ethyl acetate, ethyl acetoacetate, ethylene glycol, furfural, glycerol, glycidol, isoamyl acetate, isobutyl acetate, methyl acetate, n-butanol, propionic acid, propylene glycol. (These constituents are shown in Table 1 of FDA’s Notice and Request for Comments.) We support adding these 19 toxicants to the HPHC list. The proposed list, however, omits several important toxicants delivered by new products, notably e-cigarettes and heated tobacco products. In addition to the 19 toxicants FDA proposed, the list should be expanded to include other important toxicants and chemical classes delivered by these products. It its especially important for FDA to update the HPHC list to take into account the ingredients, additives, and smoke and aerosol constituents in e- cigarettes and other newly deemed tobacco products (including cigars, hookah, and heated tobacco products such as IQOS) that will likely be included in PMTAs filed in the coming months.
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