COMPREHENSIVE E‐CIGARETTE REGULATION AS A STEP TOWARD HARM REDUCTION

While we agree with Kenkel (2016) that e-cigarettes hold potential for reducing the public health harms from combustible tobacco products, based on the currently available evidence, we are not as convinced that e-cigarettes are as safe as he claims. The central premise of harm reduction is that the substitute product, when used under normal conditions, results in a lower public health burden. We have concerns about the quality of the science cited that has investigated harms of these nascent products, and the underappreciated problem of dual e-cigarette and cigarette use (potentially driven by inconsistent and inadequate nicotine delivery among some e-cigarette products). Finally, we reiterate our recommendation for a stronger and more comprehensive set of regulations for e-cigarettes to help minimize the negative impacts of e-cigarettes (e.g., youth initiation) and maximize their potential benefits (i.e., smoking cessation).