HomeMy WebLinkAbout03-17-2015 C9 CompstonMarch 10,2015
To: San Luis Obispo City Council
From: Frank and Kristina Compston
Re: Electronic Cigarette Ordinance
[RECEIVED AR 16 0015 CITY CLERK - -,
COUNCIL MEETING: 03111 -1-15
ITEM NO.� Cq
We are writing this letter as the owner operators of Blue Sky Vapes upon the advice of our
attorney so as to have you reconsider the ordinance that is approved without further action.
We regretfully were out of town and not able to attend the last city council meeting. We had
been in contact with Greg Hermann who was tasked with drafting the current ordinance being
considered. After providing information and being completely transparent in our business
operations we had hopes that all realistic studies would be considered and an unbiased
information based decision would be made. Attached to this letter will be some recent studies
that have been done to represent the manner in which a -cig users would actually use these
products. I ask you to please read with an open mind and consider them in your decision.
The current ordinance up for final approval can be broken into three basic sections.
(vaping will reference the use of an a -cig)
1. Public Vaping
2. Tobacco License
3. Exemption for existing Vape Shops
As to the section in regards to vaping in areas where smoking is not allowed, my opinion is that
it is reasonable at this time.
As to the section in regards to requiring any vape only retailers to now have a "Tobacco Retailers
permit" we would ask you to reconsider and amend this section. If it is a shop such as ours, we
carry absolutely no combustible related tobacco products or paraphernalia. The e- liquids that
we carry are all available in Omg as well as with nicotine. Nicotine in and of itself aside from
traditional tobacco also occurs naturally in a wide variety of plants and vegetables such as
tomatoes, potatoes, eggplant and the list goes on.
As to the section in regards to not allowing existing vape shops to continue to vape in their
business, we would ask you to reconsider and amend this section. In 2010 when the initial
smoking ban was expanded, exemption was offered to any tobacco retailers in operation prior
to the new ordinance. The requirement of a dedicated ventilation system was required. Based
on the precedence by the new ordinance in 2010 any vape only shop conducting business prior
to the new ordinance should be granted the same opportunity. As to our business, we have had
San Luis Obispo City building inspectors perform an inspection and are in compliance as
referenced in their report to be exempt from the proposed ordinance.
To further support allowing vaping in a vape shop are the following points. The purpose of the
city councils request for this ordinance is to protect from exposure of nicotine to minors or the
general public.
1. We do not allow minors into our business
2. All of our samples are in Omg nicotine
3. Any person entering our business is an adult with the knowledge that we allow vaping
inside and they will be exposed to the vapor consisting of three ingredients (vg, pg, natural
and artificial flavorings).
4. We were granted a business license to operate as we have for a period of more than a
year.
A key part of someone's success in making the transition from traditional tobacco to vaping is
having a specialty shop they can go to for information and education on the proper use of the
hardware. The ability to sample flavors and find what appeals to them is also key in that if we
enjoy it we are less likely to return to traditional tobacco. Without the ability to teach someone
how to use their products and find what flavor works for them we are lowering their chance at
making the transition to an extremely lower risk form of receiving their nicotine.
We are not trying to convince you that vaping is completely risk free, merely that studies show
it is an extremely lower risk than the much higher risk tobacco alternatives and as adults a
person should have the right to choose.
Each year the CDC estimates 443,000 people in America alone will die from smoking or exposure
to secondhand smoke and another 8.6 million will live with a serious illness caused by smoking
yet 46.6 million Americans still smoke cigarettes.
There has not been one single report of death or disease attributed to the use of an electronic
cigarette in the world to this day. If as an adult there is an alternative delivery device for nicotine
that as of yet shows extremely lower risk than traditional methods, we should have that choice
available.
I have used vaping as alternative to smoking since November of 2012. We decided to open our
first shop in February of 2013 because there was nothing in this area that had any knowledge of
hardware or any quality e- liquids available. We spent the next six months researching to gain
the knowledge and educate ourselves in what was considered quality hardware and devices.
We also researched e- liquid companies to find those that were using the highest quality
ingredients available. All of the manufacturers that we carry are producing their liquids in either
labs or up to IOS 7 clean rooms with the highest standards in the industry. All packaging is
tamper evident, child - proof, safety warning labeled bottles. We then opened our first shop in
Santa Maria in August of 2013.
Our goal was to provide someone looking for a lower risk alternative to smoking a place to come
with the highest quality products available and the knowledge of them so as to increase their
chances of becoming smoke free.
We have helped from young adults to the elderly and everyone in between with countless
success stories with many of them that have worked their way down to either very low amounts
or even zero nicotine.
If we are not granted exemption from the ordinance it will have devastating impact on our ability
to continue helping those adults that have done their research and have chosen to try a lower
risk nicotine delivery device. The impact would be such that we would not be able to continue
conducting business as there are also aspects of the business in where we must rebuild and test
hardware which requires the ability to use the product.
We ask that you carefully consider the information in this letter and also that attached in
reconsidering the drafting of this ordinance.
Thank You,
Frank and Kristina Compston
Blue Sky Vapes
973 Foothill Blvd.
San Luis Obispo, CA 93405
Mobile (805)266 -8430
Email: frank @blueskyvapes.com
311612015 State lawmaker to ease proposed restrictions on indoor e- cigarette use - Gate House
4§JRThe- ter
By Seth A. Richardson i Print Page
State Capitol Bureau
March 13. 2015 8:26PM
State lawmaker to ease proposed restrictions on indoor e- cigarette use
The author of a bill to ban the indoor use of electronic cigarettes said Friday that she does not want the restrictions to _
be as far reaching as originally proposed.
Rep. Kathleen Willis, D Addison, filed House Bill 2404 in February, which would have prohibited indoor a -cigarette
use, or "vaping," similar to other forms of tobacco. She said she plans to amend the bill by March 20 to limit the ban to j
inside school buildings, on school grounds and inside state -owned facilities.
Willis said she heard from thousands of individuals after she proposed the legislation. She consulted with a -cigarette
users, business owners and healthcare professionals and decided the amended version would be the right compromise.
C
"Until we get the final ruling of what's in the byproduct of electronic cigarettes, it's becoming a very difficult fight to In this Feb. 20, 2014, File photo, a patron
fight," Willis said. "That doesn't mean I'm not up to it, but everybody agrees that electronic cigarettes are a better exhales vapor from an e- cigarette at the
alternative than regular cigarettes and we don't want to discourage people from going and using electronic cigarettes." Henley Vaporium in New York. (AP
Photo /Frank Franklin II, File)
Willis filed the original bill because she was concerned about the potential health effects of vaping.
Electronic cigarettes work by heating oil that sometimes contains nicotine until it becomes water vapor, which users then inhale. When released, the vapor
looks like a cloud of smoke similar to a traditional cigarette.
The devices are frequently used to quit smoking. Scientific research on the products is limited because of how new they are, with some studies showing little to
no effect and others finding harmful chemicals such as formaldehyde.
"It's a new technology. New things are being developed on it all the time," Willis said. "This (amendment) gives us a start on that conversation as we see more
evidence and science and rulings from the federal government."
Matt Fortin, owner of the Springfield vape shop Upper Limits, said he could support the amended bill, especially banning a -cigarette use in schools.
"As long as they're not dictating what businesses can and cannot do with vapor, I don't think it will really have too much effect on us," he said.
Kathy Drea, vice president of advocacy for the American Lung Association in Illinois, supported Willis' original bill but said she would have to wait to comment
on the new legislation until seeing the full text of the amendment.
All nine of the listed co- sponsors are Democrats, including Rep. Sue Scherer of Decatur. Willis said the co- sponsors wanted her to continue with the blanket ban
on indoor a -cigarette use, but they support the compromise.
She expects the new bill to receive bipartisan support.
"Things are a little bit different down in Springfield this year, so we're working through that," Willis said. "But Ibe talked to a number of my Republican
colleagues, and they're just waiting to see the final version of the amendment."
—Contact Seth A. Richardson: seth.richardson @sj- r.com, 782 -3o95 twittencom/SethARichardson.
http:/Iwww.sj-r.com/article/20150313/NEWS/150319702
http: //www.sj -r.com /article/ 20150313/ NEWS /150319702?template= prirttart 1/1
3/16/2015 Electronic cigarettes: no adverse effects on blood and oxygen supply to the heart I ClearStream by FlavourArt
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Electronic cigarette use does not cause any immediate adverse effects on coronary circulation and
oxygen supply to the heart, according to a new study presented today in the European Society of
Cardiology annual congress in Amsterdam.
Researchers at Onassis Cardiac Surgery Center, lead by principle investigator Dr Konstantinos
Farsalinos, evaluated the effects of electronic cigarette use on the maximal ability of the coronary arteries
to supply with blood and oxygen the heart itself. They recruited 60 participants, 30 smokers and 30
electronic cigarette users. Measurement of maximal coronary blood flow was performed in smokers
before and after smoking 2 cigarettes and, on a separate day, after using an electronic cigarette with
18mg/ml nicotine concentration for 15 minutes. In electronic cigarette users, coronary circulation was
evaluated before and after using the same electronic cigarette device for 15 minutes.
"This is the first study that has examined the effects of electronic cigarette use on coronary circulation ",
said leading researcher Dr Konstantmos Farsalinos. "We know that smoking has immediate adverse
effects, lowering the ability of the coronary arteries to deliver blood to the heart, and our purpose was to
test whether electronic cigarette use has similar effects ", he added.
After smoking 2 cigarettes, the researchers observed a 16% reduction in maximal coronary blood flow
and a 19% elevation in resistance to flow. However, after electronic cigarette use, no difference in
coronary blood flow and resistance was observed compared to the baseline measurement. "The results
are impressive and indicate that, unlike tobacco, electronic cigarette use does not affect the oxygenation
http: // clearstream .flavourart.it /site/ ?p =1171 &fang =en 1/4
3116/2015 Electronic cigarettes: no adverse effects on blood and oxygen supply to the heart I ClearStream by FlavourArt
of the heart", said Dr Farsalinos. "However, we must be cautious and make clear that this does not mean
that there are no implications from long -term use. It is currently impossible to evaluate the effects of
long -term use but currently available evidence strongly suggests that electronic cigarettes are by far less
harmful alternatives compared to tobacco cigarettes."
Public health authorities all over the world are evaluating the regulatory status of electronic cigarettes.
Lately, the European Commission has proposed a medicinal regulation. Dr Farsalmos said:
"Acknowledging the significant potential of electronic cigarettes as smoking alternatives and based on
the scientific evidence which clearly indicated that they are much safer, it is important that health
authorities will regulate these products in a way that will promote rather than restrict their availability
and use by smokers who are unable to quit with currently approved medical methods."
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Are Electronic Cigarettes Safe?
By Kristin Noll- Marsh, CASAA
Recently, there has been media coverage about the safety of electronic cigarettes, which may be confusing and a bit
scary.
Electronic cigarettes are intended to be a less -toxic (or "safer ") alternative to smoking tobacco cigarettes, but not as a
treatment for nicotine addiction. Chinese pharmacist Hon Lik invented an e- cigarette in 2003 with a patented ultrasonic
technology. Hon Lik was a highly motivated inventor, given that his father was dying from lung cancer at the time. Since
then, most Chinese e- cigarette makers have replaced the ultrasonic technology with a heating element that vaporizes
the nicotine solution in the e- cigarette mouthpiece so it can be inhaled.
Read more: ht tp:f ler n erg inq- business - markets. suite70 1.comlarticle.cfmisources for imported ec1garettes #ixzz0TNTSPtUJ
Nicotine
It's well documented that currently available treatments for smokers, nicotine replacement therapies such as patches
and gums, are largely ineffective, with just a 7% success rate after 12 months. This is largely due to the fact that most
smokers aren't just addicted to the nicotine; they are addicted to the actual habit and ritual of smoking a cigarette. It is a
comfort system for them that can be even stronger than nicotine addiction.
However, the greatest danger in cigarette smoking is not the nicotine. Nicotine, while highly addictive, is a stimulant
similar to caffeine and not toxic in low, intermittent doses, which is why it can be used in nicotine replacement
therapies. Nicotine does NOT cause cancer, but is known to have some side effects. Cigarette smoke, on the other hand,
contains more than just nicotine. It contains hundreds of toxic chemicals and dozens of known carcinogens.
Hon Lik seems to have believed that there could be an option for smokers, to still have the act of smoking, while limiting
exposure to the chemicals, toxins and carcinogens found in tobacco smoke. He had to have known that the smoker
would still need relief from the nicotine addiction, so to get them to switch to the less toxic electronic cigarettes; he had
to include doses of nicotine. The typical electronic cigarette liquid contains water, propylene glycol, glycerin, nicotine &
food -grade flavoring.
Read more: httr a: / /www.drL]RS.com /sfx /nicotine- side- effects.fitniI
Diethylene glycol
You may have heard that the FDA found traces (1%) of diethylene glycol in one Smoking Everywhere brand prefilled
cartridge. Diethylene glycol is a highly toxic substance used in tobacco processing (and in anti - freeze), but it is NOT used
to manufacture electronic cigarette liquid. Because it used in tobacco processing, cheaper, less refined nicotine may
become contaminated with traces of diethylene glycol. It can also be a by- product of the manufacture of low -grade
propylene glycol. It is the most likely explanation of how one cartridge may have been contaminated. The other 17
cartridges and other brands tested by independent labs were not found to have been contaminated with diethylene
glycol. Many liquid manufacturers use USP -grade nicotine( the same as used in FDA - approved nicotine patches and
gums) and USP propylene glycol and should not contain any diethylene glycol.
Read more: httpjl en wikipedia.orglwiki /Diethylene glycol
Propylene Glycol
Propylene glycol is commonly confused in the media (and by well- meaning enthusiasts) with diethylene glycol as the
toxic ingredient found in antifreeze. (Anti- freeze is actually most commonly made with ethylene glycol.) While
propylene glycol can be found in some antifreeze, it is actually added to it to make it LESS toxic.
"Antifreeze typically contains ethylene glycol as its active ingredient, but some manufacturers market propylene
glycol -based antifreeze, which is less toxic to humans and pets. The acute, or short-term, toxicity of propylene glycol,
especially in humans, is substantially lower than that of ethylene glycol. Regardless of which active ingredient the
spent antifreeze contains, heavy metals contaminate the antifreeze during service. When contaminated, particularly
with lead, used antifreeze can be considered hazardous and should be reused, recycled, or disposed of properly."
Read more: http://www.epa.goy/waste/conset-ye/`m aterL_ ]ar7�ifree.htm
Propylene glycol is actually approved for human consumption by the FDA and approved for human inhalation by the
EPA. It is a common ingredient in many foods and medicines, such as McCormick (and other brand) imitation food
flavoring, toothpaste, cough syrup, hand sanitizer, lotions, cosmetics and more.
Read more: htto: / /en.wikii)edia.ora /wiki / Proovlene alvcol
Tobacco - specific Nitrosamines
The FDA analysis found "tobacco- specific nitrosamines" in some of the samples tested. These nitrosamines are created
during the curing and processing of tobacco and would be expected to be found, in trace amounts, in nicotine extracted
from processed tobacco. In tobacco smoke, they are found in high concentration and are a leading cause of tobacco -
related cancers. These carcinogens were found in just trace amounts in the electronic cigarette liquid and are found in
other low -risk smokeless tobacco and nicotine products, including chew, snuf, patches, gum and inhalers. A study at
Oxford concluded that the highest levels of these nitrosamines are found in the reaction of tobacco smoke and minimal
in NRTs. Levels of nitrosamines found in electronic cigarettes are at or below those found in NRTs.
Read more:
http: / /en.wikipedia.org /wiki /Tobacco- specific_nitrosamines
htto: / /www.ecassoc.ora /downloads /Response -to- the - FDA- Summarv.odf
http:/ /carcin.oxfordmournal_s.orgLcgi /reprint /18`/3/587pdf
Food Flavorings
Artificial food flavorings are often called "the great unknown" when it comes to electronic cigarettes. While all flavorings
are FDA - approved for human consumption, very little is known about the short or long -term health effects of the
inhalation of the ingredients in artificial flavors.
One thing to know is that the artificial flavor drops used in electronic cigarette liquids are highly concentrated, so very
little is needed to add sufficient flavor. Most of the flavors are already mixed in a propylene glycol base and make up
between 10% to 25% of the total electronic cigarette liquid. What is inhaled into the lungs could be reduced further
when vaporized and mixed with air.
One known flavoring agent — diacetyl — has been shown to be linked to bronchiolitis obliterans, a condition also known
as "popcorn lung." Diacetyl is used in some artificial butter flavors. Several workers at microwave popcorn factories, who
had long -term exposure to high concentrations of diacetyl, reported a higher incidence of asthma or bronchiolitis
obliterans. It is not known if the much lower levels of diacetyl that might be found in some electronic cigarette liquid
flavors pose a similar health risk, but some electronic cigarette users choose to err on the side of caution and avoid
flavors which contain diacetyl.
Other than diacetyl, no other artificial flavorings have been widely reported to be linked to respiratory illness or disease
in factory workers or consumers.
Read more: http: / /www.osha.gov /dsg/ guidance /diacetyl- guidance.html
Now you have the facts. You should decide for yourself if you consider electronic cigarettes safe (or at least safer than
tobacco cigarettes) for YOU.
Technical Report July - August 2013
Peering through the mist: What does the chemistry of contaminants in electronic cigarettes
tell us about health risks?
Igor Burstyn, PhD
Department of Environmental and Occupational Health
School of Public Health
Drexel University
1505 Race St., Mail Stop #1034
Philadelphia, PA 19102
USA
Tel: 215.762.2909 1 Fax: 215.762.8846
igor.burstyn@drexel.edu
Abstract
The aim of this paper is to review available data on chemistry of aerosols and liquids of electronic cigarettes and to make
predictions about compliance with occupational exposure limits of personal exposures of vapers (e- cigarette users) to
compounds found in the aerosol. Both peer- reviewed and "grey" literatures were accessed and more than 9000
observations of highly variable quality were extracted. Comparisons to the most universally recognized workplace
exposure standards, Threshold Limit Values (TLVs), were conducted under "worst case" assumptions about both
chemical content of aerosol and liquids as well as behavior of vapers. The calculations reveal that there was no evidence
of potential for exposures of e- cigarette users to contaminants that are associated with risk to health at a level that
would warrant attention if it were an involuntary workplace exposures by approaching half of TLV. The vast majority of
predicted exposures are «1% of TLV. Predicted exposures to acrolein and formaldehyde are typically <5% TLV.
Considering exposure to the aerosol as a mixture of contaminants did not indicate that exceeding half of TLV for
mixtures was plausible. Only exposures to the declared major ingredients -- propylene glycol and glycerin -- warrant
attention because of precautionary nature of TLVs for exposures to hydrocarbons with no established toxicity.
Comparing the exposure to nicotine to existing occupational exposure standards is not valid so long as nicotine -
containing liquid is not mislabeled as nicotine -free. It must be noted that the quality of much of the data that was
available for these assessment was poor, and so much can be done to improve certainty in this risk assessment.
However, the existing research is of the quality that is comparable with most workplace assessments for novel
technologies. In summary, an analysis of current state of knowledge about chemistry of liquids and aerosols associated
with electronic cigarettes indicates that there is no evidence that vaping produces inhalable exposures to contaminants
of the aerosol that would warrant health concerns by the standards that are used to ensure safety of workplaces.
However, the aerosol generated during vaping as a whole (contaminants plus declared ingredients), if it were an
emission from industrial process, creates personal exposures that would justify surveillance of health among exposed
persons in conjunction with investigation of means to keep health effects as low as reasonably achievable. Exposures of
bystanders are likely to be orders of magnitude less, and thus pose no apparent concern.
Keywords: vaping, e- cigarettes, tobacco harm reduction, risk assessment, aerosol, occupational exposure limit
Technical Report July - August 2013
Introduction
Electronic cigarettes (also known as e- cigarettes) are generally recognized as a safer alternative to combusted tobacco
products (reviewed in [1]), but there are conflicting claims about the degree to which these products warrant concern
for the health of the vapers (e- cigarette users). A vaper inhales aerosol generated during heating of liquid contained in
the e- cigarette. The technology and patterns of use are summarized by Etter [1], though there is doubt about how
current, complete and accurate this information is. Rather conclusive evidence has been amassed to date on
comparison of the chemistry of aerosol generated by electronic cigarettes to cigarette smoke [2 -8]. However, it is
meaningful to consider the question of whether aerosol generated by electronic cigarettes would warrant health
concerns on its own, in part because vapers will include persons who would not have been smokers and for whom the
question of harm reduction from smoking is therefore not relevant, and perhaps more importantly, simply because
there is value in minimizing the harm of those practicing harm reduction.
One way of approaching risk evaluation in this setting is to rely on the practice, common in occupational hygiene, of
relating the chemistry of industrial processes and the emissions they generate to the potential worst case of personal
exposure and then drawing conclusions about whether there would be interventions in an occupational setting based on
comparison to occupational exposure limits, which are designed to ensure safety of unintentionally exposed individuals.
In that context, exposed individuals are assumed to be adults, and this assumption appears to be suitable for the
intended consumers of electronic cigarettes. "Worst case" refers to the maximum personal exposure that can be
achieved given what is known about the process that generates contaminated atmosphere (in the context of airborne
exposure considered here) and the pattern of interaction with the contaminated atmosphere. It must be noted that
harm reduction notions are embedded in this approach since it recognizes that while elimination of the exposure may
be both impossible and undesirable, there nonetheless exists a level of exposure that is associated with negligible risks.
To date, a comprehensive review of the chemistry of electronic cigarettes and the aerosols they generate has not been
conducted, depriving the public of the important element of a risk - assessment process that is mandatory for
environmental and occupational health policy making.
The present work considers both the contaminants present in liquids and aerosols as well as the declared ingredients in
the liquids. The distinction between exposure to declared ingredients and contaminants of a consumer product is
important in the context of comparison to occupational or environmental exposure standards. Occupational exposure
limits are developed for unintentional exposures that a person does not elect to experience. For example, being a bread
baker is a choice that does not involve election to be exposed to substances that cause asthma that are part of the flour
dust (most commonly, wheat antigens and fungal enzymes). Therefore, suitable occupational exposure limits are
created to attempt to protect individuals from such risk on the job, with no presumption of "assumed risk" inherent in
the occupation. Likewise, special regulations are in effect to protect persons from unintentional exposure to nicotine in
workplaces ( http : / /www.cdc.gov /niosh /docs /81- 123 /pdfs /0446.pdf; accessed July 12, 2013), because in environments
where such exposures are possible, it is reasonable to protect individuals who do not wish to experience its effects. In
other words, occupational exposure limits are based on protecting people from involuntary and unwanted exposures,
and thus can be seen as appropriately more stringent than the standards that might be used for hazards that people
intentionally choose to accept.
By contrast, a person who elects to lawfully consume a substance is subject to different risk tolerance, as is
demonstrated in the case of nicotine by the fact that legally sold cigarettes deliver doses of nicotine that exceed
occupational exposure limits[9]: daily intake of 20 mg of nicotine, assuming nearly 100% absorption in the lungs and
Technical Report July - August 2013
inhalation of 4 m3 of air, corresponds to roughly 10 times the occupational exposure limit of 0.5 mg /m3 atmosphere over
8 hours[10]. Thus, whereas there is a clear case for applicability of occupational exposure limits to contaminants in a
consumer product (e.g. aerosol of electronic cigarettes), there is no corresponding case for applying occupational
exposure limits to declared ingredients desired by the consumer in a lawful product (e.g. nicotine in the aerosol of an
electronic cigarette). Clearly, some limits must be set for voluntary exposure to compounds that are known to be a
danger at plausible doses (e.g. limits on blood alcohol level while driving), but the regulatory framework should reflect
whether the dosage is intentionally determined and whether the risk is assumed by the consumer. In the case of
nicotine in electronic cigarettes, if the main reason the products are consumed is as an alternative source of nicotine
compared to smoking, then the only relevant question is whether undesirable exposures that accompany nicotine
present health risks, and the analogy with occupational exposures holds. In such cases it appears permissible to allow at
least as much exposure to nicotine as from smoking before admitting to existence of new risk. It is expected that
nicotine dosage will not increase in switching from smoking to electronic cigarettes because there is good evidence that
consumers adjust consumption to obtain their desired or usual dose of nicotine[11]. The situation is different for the
vapers who want to use electronic cigarettes without nicotine and who would otherwise not have consumed nicotine.
For these individuals, it is defensible to consider total exposure, including that from any nicotine contamination, in
comparison to occupational exposure limits. In consideration of vapers who would never have smoked or would have
quit entirely, it must be remembered that the exposure is still voluntary and intentional, and comparison to
occupational exposure limits is legitimate only for those compounds that the consumer does not elect to inhale.
The specific aims of this review were to:
1. Synthesize evidence on the chemistry of liquids and aerosols of electronic cigarettes, with particular emphasis
on the contaminants.
2. Evaluate the quality of research on the chemistry of liquids and aerosols produced by electronic cigarettes.
3. Estimate potential exposures from aerosols produced by electronic cigarettes and compare those potential
exposures to occupational exposure standards.
Methods
Literature search
Articles published in peer- reviewed journals were retrieved from PubMed (_h_ttp: / /www.ncbi.nlm.nih.gov /pubmed /)
using combinations of the following keywords: "electronic cigarettes ", "e- cigarettes ", "smoking alternatives ",
"chemicals ", "risks ", "electronic cigarette vapor ", "aerosol', "ingredients ", "e- cigarette liquid ", "e -cig composition ", "e-
cig chemicals ", "e -cig chemical composition ", "e -juice electronic cigarette ", "electronic cigarette gas ", "electronic
cigars ". In addition, references of the retrieved articles were examined to identify further relevant articles, with
particular attention paid to non -peer reviewed reports and conference presentations. Unpublished results obtained
through personal communications were also reviewed. The Consumer Advocates for Smoke -free Alternatives
Association (CASAA) was asked to review the retrieved bibliography to identify any reports or articles that were missed,
The papers and reports were retained for analysis if they reported on the chemistry of e- cigarette liquids or aerosols.
No explicit quality control criteria were applied in selection of literature for examination, except that secondary
reporting of analytical results was not used. Where substantial methodological problems that precluded interpretation
of analytical results were noted, these are described below. For each article that contained relevant analytical results,
the compounds quantified, limits of detection, and analytical results were summarized in a spreadsheet. Wherever
possible, individual analytical results (rather than averages) were recorded (see electronic Appendix A:
Technical Report July - August 2013
https: Hdi. dropboxusercontent. com/ u/ 4285761/CASAA /eAnnendixA.xisx). Data contained in Appendix A is not fully
summarized in the current report but can be used to investigate a variety of specific questions that may interest the
reader. Each entry in Appendix A is identified by a Reference Manage ID that is linked to source materials in a list in
Appendix B (linked via Ref /D: littps: lldl.drol)boxusereontent- coni /u /4285761 /CASAAIAppendixB.i -t[j and attached electronic
copies of all original materials (Biobliography.zip: https: Hdi.drg2boxitserc:ontent.com /u/ 4285761 /CASAA /bibliography.zip).
Comparison of observed concentrations in aerosol to occupational exposure limits
For articles that reported mass or concentration of specific compounds in the aerosol (generated by smoking machines
or from volunteer vapers), measurements of compounds were converted to concentrations in the "personal breathing
zone",' which can be compared to occupational exposure limits (OELs). The 2013 Threshold Limit Values (TLVs)[10] were
used as OELs because they are the most up to date and are most widely recognized internationally when local
jurisdictions do not establish their own regulations (see litip: / /www.ilo.org; osliene/part -iv/ occupational- hy�,icneiite,n /575;
accessed July 3, 2013). Whenever there was an uncertainty in how to perform the calculation, a "worst case" scenario
was used, as is the standard practice in occupational hygiene, where the initial aim is to recognize potential for
hazardous exposures and to err on the side of caution. The following assumptions were made to enable the calculations
that approximate the worst -case personal exposure of a vaper (Equation 1):
1. Air the vaper breathes consists of a small volume of aerosol generated by e- cigarettes that contains a specific
chemical plus pristine air;
2. The volume of aerosols inhaled from e- cigarettes is negligible compared to total volume of air inhaled;
3. The period of exposure to the aerosol considered was normalized to 8 hours, for comparability to the standard
working shift for which TLVs were developed (this does not mean only 8 hours worth of vaping was considered
(see point 4) but rather that amount of breathing used to dilute the day's worth of vaping exposure was 8
hours);
4. Consumption of 150 puffs in 8 hours (an upper estimate based on a rough estimate of 150 puffs by a typical
vaper in a day[1]) was assumed to be conservative;
5. Breathing rate is 8 liters per minute [12,13];
6. Each puff contains the same quantity of compounds studied.
[mg /m3] = mg /puff x puffs /(8 hr day) x 1/(m3 air inhaled in 8 hr) Eq. 1
The only exception to this methodology was when assessing a study of aerosol emitted by 5 vapers in a 60 m3 room over
5 hours that seemed to be a sufficient approximation of worst -case "bystander" exposure[6]. All calculated
concentrations were expressed as the most stringent (lowest) TLV for a specific compound (i.e. assuming the most toxic
form if analytical report is ambiguous) and expressed as "percent of TLV ". Considering that all the above calculations
are approximate and reflecting that exposures in occupational and general environment can easily vary by a factor of 10
around the mean, we added a 10 -fold safety factor to the "percent of TLV" calculation. Details of all calculations are
provided in an Excel spreadsheet (see electronic Appendix C:
littps: /Idl.dropboxuserc otitent. com/ Ld4285761 /C:ASAA/eAppendix+C:.Asx ).
No systematic attempt was made to convert the content of the studied liquids into potential exposures because
sufficient information was available on the chemistry of aerosols to use those studies rather than making the necessary
Atmosphere that contains air inhaled by a person
4
Technical Report July - August 2013
simplifying assumptions to do the conversion. However, where such calculations were performed in the original
research, the following approach as used: under the (probably false — see the literature on formation of carbonyl
compounds below) assumption of no chemical reaction to generate novel ingredients, composition of liquids can be
used to estimate potential for exposure if it can be established how much volume of liquid is consumed in given 8 hours,
following an algorithm analogous to the one described above for the aerosols (Equation 2):
[mg /m3] = mg /(mL liquid) x (mL liquid) /puff x puffs /(8 hr day) x 1/(m3 air inhaled in 8 hr) Eq. 2
Comparison to cigarette smoke was not performed here because the fact that e- cigarette aerosol is at least orders of
magnitude less contaminated by toxic compounds is uncontroversial [2 -8].
Results and discussion
General comments on methods
In excess of 9,000 determinations of single chemicals (and rarely, mixtures) were reported in reviewed articles and
reports, typically with multiple compounds per electronic cigarette tested [2- 8,14 -42]. Although the quality of reports is
highly variable, if one assumes that each report contains some information, this asserts that quite a bit is known about
composition of e- cigarette liquids and aerosols. The only report that was excluded from consideration was work of
McAuley et al.[23] because of clear evidence of cross - contamination — admitted to by the authors — with cigarette
smoke and, possibly, reagents. The results pertaining to non - detection of tobacco - specific nitrosamines (TSNAs) are
potentially trustworthy, but those related to PAH are not since it is incredible that cigarette smoke would contain fewer
polycyclic aromatic hydrocarbons (PAH; arising in incomplete combustion of organic matter) than aerosol of e- cigarettes
that do not burn organic matter [23]. In fairness to the authors of that study, similar problems may have occurred in
other studies but were simply not reported, but it is impossible to include a paper in a review once it is known for
certain that its quantitative results are not trustworthy. When in doubt, we erred on the side of trusting that proper
quality controls were in place, a practice that is likely to increase appearance of atypical or erroneous results in this
review. From this perspective, assessment of concordance among independent reports gains higher importance than
usual since it is unlikely that two experiments would be flawed in the same exact manner (though of course this cannot
be assured).
It was judged that the simplest form of publication bias — disappearance of an entire formal study from the available
literature — was unlikely given the exhaustive search strategy and the contested nature of the research question. It is
clearly the case that only a portion of all industry technical reports were available for public access, so it is possible that
those with more problematic results were systematically suppressed, though there is no evidence to support this
speculation. No formal attempt was made to ascertain publication bias in situ though it is apparent that anomalous
results do gain prominence in typical reviews of the literature: diethylene glycol[43,44] detected at non - dangerous levels
(see details below) in one test of 18 of early - technology products by FDA[22] and one outlier in measurement of
formaldehyde content of exhaled air [4] and aldehydes in aerosol generated from one e- cigarette in Japan [37]. It must
be emphasized that the alarmist report of aldehydes in experiments presented in [37] is based on the concentration in
generated aerosol rather than air inhaled by the vaper over prolonged period of time (since vapers do not inhale only
aerosol). Thus, results reported in [37] cannot be the basis of any claims about health risk, a fallacy committed both by
the authors themselves and commentators on this work [44].
5
Technical Report July - August 2013
It was also unclear from [37] what the volume of aerosol sampled was — a critical item for extrapolating to personal
exposure and a common point of ambiguity in the published reports. However, in a personal exchange with the authors
of [37][July 11, 2013], it was clarified that the sampling pump drew air at 500 mL /min through e- cigarette for 10 min,
allowing more appropriate calculations for estimation of health risk that are presented below. Such misleading
reporting is common in the field that confuses concentration in the aerosol (typically measured directly) with
concentration in the air inhaled by the vaper (never determined directly and currently requiring additional assumptions
and modeling). This is important because the volume of aerosol inhaled (maximum —8 L /day) is negligible compared to
the volume of air inhaled daily (8L /min); this point is illustrated in the Figure.
A similar but more extreme consideration applies to the exposure of bystanders which is almost certainly several orders
of magnitude lower than the exposure of vapers. In part this is due to the absorption, rather than exhalation, of a
portion of the aerosol by the vapers: there is no equivalent to the "side- stream" component of exposure to conventional
cigarettes, so all of the exposure to bystanders results from exhalation. Furthermore, any environmental contamination
that results from exhalation of aerosol by vaper will be diluted into the air prior to entering a bystander's personal
breathing zone. Lastly, the number of puffs that affects exposure to bystander is likely to be much smaller than that of a
vaper unless we are to assume that vaper and bystander are inseparable.
It is unhelpful to report results in cigarette - equivalents, as in [42], because this does not enable one to estimate
exposures of vapers . Moreover, there is no value in comparison of the content of e- cigarette aerosol to cigarette smoke
when the two products produce emissions that are orders of magnitude apart. To be useful for risk assessment, the
results on the chemistry of the aerosols and liquids must be reported in a form that enables the calculations in Equations
1 and 2. It must be also be noted that typical investigations consisted of qualitative and quantitative phases such that
quantitative data is available mostly on compounds that passed the qualitative screen. This biased all reports on
concentration of compounds towards both higher levels and chemicals which a particular lab was most adept at
analyzing.
Declared Ingredients: comparison to occupational exposure limits
Propylene glycol and glycerin have default or precautionary TLV of 10 mg/m3 over 8 hours set for all organic mists with
no specific exposure limits or identified toxicity (l ittp:/ Iwww .osha.gov /dts /chemicalsampling /data /CH 243600.,html;
accessed July 5, 2013). These interim TLVs tend to err on the side of being too high and are typically lowered if
evidence of harm to health accumulates. For example, in a study that related exposure of theatrical fogs (containing
propylene glycol) to respiratory symptoms [45], "mean personal inhalable aerosol concentrations were 0.70 mg /m3
(range 0.02 to 4.1)" [46]. The only available estimate of propylene concentration of propylene glycol in the aerosol
indicates personal exposure on the order of 3 -4 mg /m3 in the personal breathing zone over 8 hours (under the
assumptions we made for all other comparisons to TLVs) [2]. The latest (2006) review of risks of occupational exposure
to propylene glycol performed by the Health Council of the Netherlands (known for OELs that are the most protective
that evidence supports and based exclusively on scientific considerations rather than also accounting for feasibility as is
the case for the TLVs) recommended exposure limit of 50 mg /m3 over 8 hours; concern over short -term respiratory
effects was noted [http: / /www.Rezondheidsraad.nl/ sites /default /files/2007020SH.pdf; accessed July 29, 2013].
Assuming extreme consumption of the liquid per day via vaping (5 to 25 ml /day and 50 -95% propylene glycol in the
liquid )b, levels of propylene glycol in inhaled air can reach 1 -6 mg /m3. It has been suggested that propylene glycol is
b This estimate of consumption was derived from informal reports from vaping community; 5 ml /day was identified as a high but not
rare quantity of consumption and 25 ml /day was the high end of claimed use, though some skepticism was expressed about
Technical Report July - August 2013
very rapidly absorbed during inhalation [4,6] making the calculation under worst case scenario of all propylene glycol
becoming available for inhalation credible. It must also be noted that when consuming low- nicotine or nicotine -free
liquids, the chance to consume larger volumes of liquid increases (large volumes are needed to reach the target dose or
there is no nicotine feedback), leading to the upper end of propylene glycol and glycerin exposure. Thus, estimated
levels of exposure to propylene glycol and glycerin are close enough to TLV to warrant concern.
Nicotine is present in most liquids and has TLV of 0.5 mg /m3 for average exposure intensity over 8 hours. If
approximately 4 m3 of air is inhaled in 8 hours, the consumption of 2 mg nicotine from e- cigarettes in 8 hours would
place the vaper at the occupational exposure limit. For a liquid that contains 18 mg nicotine /ml, TLV would be reached
upon vaping — 0.1 -0.2 ml of liquid in a day, and so is achieved for most anyone vaping nicotine - containing e- cigarettes[1].
Results presented in [24] on 16 e- cigarettes also argue in favor of exceedance of TLV from most any nicotine - containing
e- cigarette, as they predict >2mg of nicotine released to aerosol in 150 puffs (daily consumption figure adopted in this
report). But as noted above, since delivery of nicotine is the purpose of nicotine - containing e- cigarettes, the comparison
to limits on unintended, unwanted exposures does not suggest a problem and serves merely to offer complete context.
If nicotine is present but the liquid is labeled as zero - nicotine [24,43], it could be treated as a contaminant, with the
vaper not intending to consume nicotine and the TLV, which would be most likely exceeded, is relevant. However, when
nicotine content is disclosed, even if inaccurately, then comparison to TLV is not valid. Accuracy in nicotine content is a
concern with respect to truth in advertising rather than unintentional exposure, due to self - regulation of consumption
by persons who use e- cigarettes as a source of nicotine.
Overall, the declared ingredients in the liquid would warrant a concern by standards used in occupational hygiene,
provided that comparison to occupational exposure limits is valid, as discussed in the introduction. However, this is not
to say that the exposure is affirmatively believed to be harmful; as noted, the TLVs for propylene glycol and glycerin
mists is based on uncertainty rather than knowledge. These TLVs are not derived from knowledge of toxicity of
propylene glycol and glycerin mists, but merely apply to any compound of no known toxicity present in workplace
atmosphere. This aspect of the exposure from e- cigarettes simply has little precedent (but see study of theatrical fogs
below). Therefore, the exposure will provide the first substantial collection evidence about the effects, which calls for
monitoring of both exposure levels and outcomes, even though there are currently no grounds to be concerned about
the immediate or chronic health effects of the exposure. The argument about nicotine is presented here for the sake of
completeness and consistency of comparison to TLVs, but in itself does not affect the conclusions of this analysis
because it should not be modeled as if it were a contaminant when declared as an ingredient in the liquid.
Polycyclic Aromatic Hydrocarbons
Polycyclic aromatic hydrocarbons (PAH) were quantified in several reports in aerosols [5,6,42] and liquids [7,18,41].
These compounds include well -known carcinogens, the levels of which are not subject to TLV but are instead to be kept
"as low as reasonably achievable" (the so called ALARA principle)[10]. For PAH, only non - carcinogenic pyrene that is
abundant in the general environment was detected at 36 ng /cartridge in 5 samples of liquid [7]; PAHs were not detected
in most of the analyses of aerosols, except for chrysene in the analysis of the aerosol of one e- cigarette[42].
Tobacco - Specific Nitrosamines
whether the latter quantity was truly possible. High - quality formal studies to verify these figures do not yet exist but they are
consistent with report of Etter (2012).
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Technical Report July - August 2013
The same risk assessment considerations that exist for PAH also hold for carcinogenic tobacco - specific nitrosamines
(TSNAs)[47] for which no occupational exposure limits exist because (a) these exposures do not appear to occur in
occupational settings often enough to warrant development of TLVs, and (b) it is currently accepted in establishing TLVs
that carcinogens do not have minimal thresholds of toxicity. As expected because the TSNAs are contaminants of
nicotine from tobacco leaf, there is also evidence of association between nicotine content of the liquid and TSNA
concentrations, with reported concentrations <5 ng /cartridge tested [7]. Smaller studies of TSNA content in liquids are
variable, with some not reporting any detectable levels [17,32,34] and others clearly identifying these compounds in the
liquids when controlling for background contamination (n= 9)[22]. Analyses of aerosols indicate that TSNAs are present
in amounts that can results in doses of <ng /day[5,32] to µg /day [8] (assuming 150 puffs /day) (see also [42]). The most
comprehensive survey of TSNA content of 105 samples of liquids from 11 manufactures indicates that almost all tested
liquids ( >90 %) contained TSNAs in µg /L quantities [35]. This is roughly equivalent to 1/1000 of the concentration of
TSNAs in modern smokeless tobacco products (like snus), which are in the ppm range [47]. The TSNA concentration of
the liquids is orders of magnitude less than smokeless tobacco products, though the actual dosage from e- cigarettes vs.
smokeless tobacco remains to be clearly understood. For example, 10 µg /L (0.01 ppm) of total TSNA in liquid[35] can
translate to a daily dose of 0.000025 - 0.00005 µg from vaping (worst case assumption of 5 ml /day); if 15 g of snus is
consumed a day [48] with 1 ppm of TSNAs [47] and half of it were absorbed, then the daily dose is estimated to be 0.008
µg, which is 160 -320 times that due to the worst case of exposure from vaping. Various assumptions about absorption
of TSNAs alter the result of this calculation by a factor that is dwarfed in magnitude compared to that arising from
differences considered above. This is reassuring because smokeless tobacco products, such as snus, pose negligible
cancer risk[49], certainly orders of magnitude smaller than smoking (if one considers the chemistry of the products
alone). In general, it appears that the cautious approach in face of variability and paucity of data is to seek better
understanding of predictors of presence of TSNA in liquids and aerosols so that measures for minimizing exposure to
TSNAs from aerosols can be devised. This can include considering better control by manufactures of the nicotine.
Volatile Organic Compounds
Total volatile organic compounds (VOC) were determined in aerosol to be non- detectable[3] except in one sample that
appeared to barely exceed the background concentration of 1 mg /m3 by 0.73 mg /m3[6]. These results are corroborated
by analyses of liquids[18] and most likely testify to insensitivity of employed analytic methods for total VOC for
characterizing aerosol generated by e- cigarettes, because there is ample evidence that specific VOC are present in the
liquids and aerosols.` Information on specific commonly detected VOC in the aerosol is given in Table 1a. It must be
observed that these reported concentrations are for analyses that first observed qualitative evidence of the presence of
a given VOC and thus represent worst case scenarios of exposure when VOC is present (i.e. zero exposures are missing
from the overall summary of worst case exposures presented here). For most VOC and aldehydes, one can predict the
concentration in air inhaled by a vaper to be «1% of TLV. The only exceptions to this generalization are:
(a) acrolein: —1% of TLV (average of 12 measurements) and measurements at a mean of 2% of TLV ( average of
150 measurements)[39,40] and
(b) formaldehyde: between 0 and 3% of TLV based on 18 tests (average of 12 measurements at 2% of TLV, the
most reliable test) and an average of 150 results at 4% of TLV [39,40].
`The term "VOC" loosely groups together all organic compounds present in aerosol and because the declared ingredients of aerosol
are organic compounds, it follows that "VOC are present"
Technical Report July - August 2013
Levels of acrolein in exhaled aerosol reported in [6] were below 0.0016 mg /m3 and correspond to predicted exposure of
<1% of TLV (Table 2). It must re- emphasized that all calculations based on one electronic cigarette analyzed in [37] are
best treated as qualitative in nature (i.e. indicating presence of a compound without any particular meaning attached to
the reported level with respect to typical levels) due to great uncertainty about whether the manner in which the e-
cigarette was operated could have resulted in overheating that led to generation of acrolein in the aerosol. In fact, a
presentation made by the author of [37] clearly stated that the "atomizer, generating high concentration carbonyls, had
been burned black" [39,40]. In unpublished work,[39] there are individual values of formaldehyde, acrolein and glyoxal
that approach TLV, but it is uncertain how typical these are because there is reason to believe the liquid was overheated;
considerable variability among brands of electronic cigarettes was also noted. Formaldehyde and other aldehydes, but
not acrolein, were detected in the analysis one e- cigarette [42]. The overwhelming majority of the exposure to specific
VOC that are predicted to result from inhalation of the aerosols lie far below action level of 50% of TLV at which
exposure has to be mitigated according to current code of best practice in occupational hygiene[50].
Finding of an unusually high level of formaldehyde by Schripp et al. [4] — 0.5 ppm predicted vs. 15- minute TLV of 0.3 ppm
(not given in Table 2) — is clearly attributable to endogenous production of formaldehyde by the volunteer smoker who
was consuming e- cigarettes in the experimental chamber, since there was evidence of build -up of formaldehyde prior to
vaping and liquids used in the experiments did not generate aerosol with detectable formaldehyde. This places
genera lizability of other findings from [4] in doubt, especially given that the only other study of exhaled air by vapers
who were not current smokers reports much lower concentrations for the same compounds [6] (Table 2). It should be
noted that the report by Romagna et al.[6] employed more robust methodology, using 5 volunteer vapers (no smokers)
over an extended period of time. Except for benzene, acetic acid and isoprene, all calculated concentrations for
detected VOC were much below 1% of TLV in exhaled air [6]. In summary, these results do not indicate that VOC
generated by vaping are of concern by standards used in occupational hygiene.
Diethylene glycol and ethylene glycol became a concern following the report of their detection by FDA[43], but these
compounds are not detected in the majority of tests performed to date [3,14,16,18,22]. Ten batches of the liquid tested
by their manufacture did not report any diethylene glycol above 0.05% of the liquid [41]. Methods used to detect
diethylene glycol appear to be adequate to be informative and capable of detecting the compound in quantities «1% of
TLV[14,16,22]. Comparison to TLV is based on a worst case calculation analogous to the one performed for propylene
glycol. For diethylene glycol, TLV of 10 mg /m3 is applicable (as in the case of all aerosols with no know toxicity by
inhalation), and there is a recent review of regulations of this compound conducted for the Dutch government by the
Health Council of the Netherlands (jurisdiction with some of the most strict occupational exposure limits) that
recommended OEL of 70 mg /m3 and noted lack of evidence for toxicity following inhalation
[http: / /www.gezondheidsraad.ni/ sites /default /files /200703OSH.pdf; accessed July 29; 2013]. In conclusion, even the
quantities detected in the single FDA result were of little concern, amounting to less than 1% of TLV.
Inorganic compounds
Special attention has to be paid to the chemical form of compounds when there is detection of metals and other
elements by inductively coupled plasma mass spectrometry (ICP- MS)[8,25]. Because the parent molecule that occurs in
the aerosol is destroyed in such analysis, the results can be alarmist and not interpretable for risk assessment. For
example, the presence of sodium (4.18 µg /10 puffs)[25] does not mean that highly reactive and toxic sodium metal is in
the aerosol, which would be impossible given its reactivity, but most likely means the presence of the ubiquitous
compound that contains sodium, dissolved table salt (NaCI). If so, the corresponding daily dose of NaCl that arises from
9
Technical Report July - August 2013
these concentrations from 150 puffs is about 10,000 times lower than allowable daily intake according to CDC
(http: / /www.cdc.gov /features /dssodium /; accessed July 4, 2013). Likewise, a result for presence of silica is meaningless
for health assessment unless the crystalline form of Si02 is known to be present. When such ambiguity exists, a TLV
equivalence calculation was not performed. We compared concentrations to TI-Vs when it was even remotely plausible
that parent molecules were present in the aqueous solution. However, even these are to be given credence only in an
extremely pessimistic analyst, and further investigation by more appropriate analytical methods could clarify exactly
what compounds are present, but is not a priority for risk assessment. It should also be noted that one study that
attempted to quantify metals in the liquid found none above 0.1 -0.2 ppm levels [7] or above unspecified threshold [18].
Table 1b indicates that most metals that were detected were present at <1% of TLV even if we assume that the
analytical results imply the presence of the most hazardous molecules containing these elements that can occur in
aqueous solution. For example, when elemental chromium was measured, it is compared to TLV for insoluble chromium
IV that has the lowest TLV of all chromium compounds. Analyses of metals given in [42] are not summarized here
because of difficulty with translating reported units into meaningful terms for comparison with the TLV, but only
mercury (again with no information on parent organic compound) was detected in trace quantities, but arsenic,
beryllium, chromium, cadmium, lead and nickel were not. Taken as the whole, it can be inferred that there is no
evidence of contamination of the aerosol with metals that warrants a health concern.
Consideration of exposure to a mixture of contaminants
All calculations conducted so far assumed only one contaminant present in clean air at a time. What are the
implications of small quantities of various compounds with different toxicities entering the personal breathing zone at
the same time? For evaluation of compliance with exposure limits for mixtures, Equation 3 is used:
OELmixture =E,n 1(CiMV), Eq. 3
where Ci is the concentration of the ith compound (i= 1,...,n, where n >1 is the number of ingredients present in a mixture)
in the contaminated air and TI-Vi is the TLV for the ith compound in the contaminated air; if OELmixture > 1, then there is
evidence of the mixture exceeding TLV.
The examined reports detected no more than 5 -10 compounds in the aerosol, and the above calculation does not place
any of them out of compliance with TLV for mixture. Let us imagine that 50 compounds with TI-Vs were detected. Given
that the aerosol tends to contain various compounds at levels, on average, of no more than 0.5% of TLV (Table 1), such a
mixture with 50 ingredients would be at 25% of TLV, a level that is below that which warrants a concern, since the
"action level" for implementation of controls is traditionally set at 50% of TLV to ensure that the majority of persons
exposed have personal exposure below mandated limit [50]. Pellerino et al.[2] reached conclusions similar to this
review based on their single experiment: contaminants in the liquids that warrant health concerns were present in
concentrations that were less than 0.1% of that allowed by law in the European Union. Of course, if the levels of the
declared ingredients (propylene glycol, glycerin, and nicotine) are considered, the action level would be met, since those
ingredients are present in the concentrations that are near the action level. There are no known synergistic actions of
the examined mixtures, so Equation 3 is therefore applicable. Moreover, there is currently no reason to suspect that the
trace amounts of the contaminants will react to create compounds that would be of concern.
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Technical Report July - August 2013
Conclusions
By the standards of occupational hygiene, current data do not indicate that exposures to vapers from contaminants in
electronic cigarettes warrant a concern. There are no known toxicological synergies among compounds in the aerosol,
and mixture of the contaminants does not pose a risk to health. However, exposure of vapers to propylene glycol and
glycerin reaches the levels at which, if one were considering the exposure in connection with a workplace setting, it
would be prudent to scrutinize the health of exposed individuals and examine how exposures could be reduced. This is
the basis for the recommendation to monitor levels and effects of prolonged exposure to propylene glycol and glycerin
that comprise the bulk of emissions from electronic cigarettes other than nicotine and water vapor. From this
perspective, and taking the analogy of work on theatrical fogs [45,46], it can be speculated that respiratory functions
and symptoms (but not cancer of respiratory tract or non - malignant respiratory disease) of the vaper is of primary
interest. Monitoring upper airway irritation of vapers and experiences of unpleasant smell would also provide early
warning of exposure to compounds like acrolein because of known immediate effects of elevated exposures
( http: / /www.atsdr.cdc.gov /toxprofiles /tp124- c3.pdf; accessed July 11, 2013). However, it is questionable how much
concern should be associated with observed concentrations of acrolein and formaldehyde in the aerosol. Given highly
variable assessments, closer scrutiny is probably warranted to understand sources of this variability, although there is no
need at present to be alarmed about exceeding even the occupational exposure limits, since occurrence of occasional
high values is accounted for in established TLVs. An important clue towards a productive direction for such work is the
results reported in [39,40] that convincingly demonstrate how heating the liquid to high temperatures generates
compounds like acrolein and formaldehyde in the aerosol. A better understanding about the sources of TSNA in the
aerosol may be of some interest as well, but all results to date consistently indicate quantities that are of no more
concern than TSNA in smokeless tobacco products. Exposures to nicotine from electronic cigarettes is not expected to
exceed that from smoking due to self- titration[11]; it is only a concern when a vaper does not intend to consume
nicotine, a situation that can arise from incorrect labeling of liquids[24,43].
The cautions about propylene glycol and glycerin apply only to the exposure experienced by the vapers themselves.
Exposure of bystanders to the listed ingredients, let alone the contaminants, does not warrant a concern as the
exposure is likely to be orders of magnitude lower than exposure experienced by vapers. Further research employing
realistic conditions could help quantify the quantity of exhaled aerosol and its behavior in the environment under
realistic worst -case scenarios (i.e., not small sealed chambers), but this is not a priority since the exposure experienced
by bystanders is clearly very low compared to the exposure of vapers, and thus there is no reason to expect it would
have any health effects.
The key to making the best possible effort to ensure that hazardous exposures from contaminants do not occur is
ongoing monitoring of actual exposures and estimation of potential ones. Direct measurement of personal exposures is
not possible in vaping due to the fact the aerosol is inhaled directly, unless, of course, suitable biomarkers of exposure
can be developed. The current review did not identify any suitable biomarkers, though cotinine is a useful proxy for
exposure to nicotine - containing liquids. Monitoring of potential composition of exposures is perhaps best achieved
though analysis of aerosol generated in a manner that approximates vaping, for which better insights are needed on
how to modify "smoking machines" to mimic vaping given that there are documented differences in inhalation
patterns[51]. These smoking machines would have to be operated under a realistic mode of operation of the atomizer
to ensure that the process for generation of contaminants is studied under realistic temperatures. To estimate dosage
(or exposure in personal breathing zone), information on the chemistry of aerosol has to be combined with models of
the inhalation pattern of vapers, mode of operation of e- cigarettes and quantities of liquid consumed. Assessment of
11
Technical Report July - August 2013
exhaled aerosol appears to be of little use in evaluating risk to vapers due to evidence of qualitative differences in the
chemistry of exhaled and inhaled aerosol.
Monitoring of liquid chemistry is easier and cheaper than assessment of aerosols. This can be done systematically as a
routine quality control measure by the manufacturers to ensure uniform quality of all production batches. However, we
do not know how this relates to aerosol chemistry because previous researchers have failed to appropriately pair
analyses of chemistry of liquids and aerosols. It is standard practice in occupational hygiene to analyze the chemistry of
materials generating an exposure, and it is advisable that future studies of the aerosols explicitly pair these analyses
with examination of composition of the liquids used to generate the aerosols. Such an approach can lead to the
development of predictive models that relate the composition of the aerosol to the chemistry of liquids, the e- cigarette
hardware, and the behavior of the vaper, as these, if accurate, can anticipate hazardous exposures before they occur.
The current attempt to use available data to develop such relationships was not successful due to studies failing to
collect appropriate data. Systematic monitoring of quality of the liquids would also help reassure consumers and is best
done by independent laboratories rather than manufactures to remove concerns about impartiality (real or perceived).
Future work in this area would greatly benefit from standardizing laboratory protocols (e.g. methods of extraction of
compounds from aerosols and liquids, establishment of "core" compounds that have to be quantified in each analysis
(as is done for PAH and metals), development of minimally informative detection limits that are needed for risk
assessment, standardization of operation of "vaping machine ", etc.), quality control experiments (e.g. suitable positive
and negative controls without comparison to conventional cigarettes, internal standards, estimation of %recovery, etc.),
and reporting practices (e.g. in units that can be used to estimate personal exposure, use of uniform definitions of limits
of detection and quantification, etc.), all of which would improve on the currently disjointed literature. Detailed
recommendations on standardization of such protocols lie outside of scope of this report.
All calculations conducted in this analysis are based on information about patterns of vaping and the content of aerosols
and liquids that are highly uncertain in their applicability to "typical' vaping as it is currently practiced and says even less
about future exposures due to vaping. However, this is similar to assessments that are routinely performed in
occupational hygiene for novel technology as it relied on "worst case" calculations and safety margins that attempt to
account for exposure variability. The approach adopted here and informed by some data is certainly superior to some
currently accepted practices in the regulatory framework in occupational health that rely purely on description of
emission processes to make claims about potential for exposure (e.g.[52]). Clearly, routine monitoring of potential and
actual exposure is required if we were to apply the principles of occupational hygiene to vaping. Detailed suggestions on
how to design such exposure surveillance are available in [53].
In summary, analysis of the current state of knowledge about the chemistry of contaminants in liquids and aerosols
associated with electronic cigarettes indicates that there is no evidence that vaping produces inhalable exposures to
these contaminants at a level that would prompt measures to reduce exposure by the standards that are used to ensure
safety of workplaces. Indeed, there is sufficient evidence to be reassured that there are no such risks from the broad
range of the studied products, though the lack of quality control standards means that this cannot be assured for all
products on the market. However, aerosol generated during vaping on the whole, when considering the declared
ingredients themselves, if it were treated in the same manner as an emission from industrial process, creates personal
exposures that would justify surveillance of exposures and health among exposed persons. Due to the uncertainty
about the effects of these quantities of propylene glycol and glycerin, this conclusion holds after setting aside concerns
about health effects of nicotine. This conclusion holds notwithstanding the benefits of tobacco harm reduction, since
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Technical Report July - August 2013
there is value in understanding and possibly mitigating risks even when they are known to be far lower than smoking. It
must be noted that the proposal for such scrutiny of "total aerosol' is not based on specific health concerns suggested
by compounds that resulted in exceedance of occupational exposure limits, but is instead a conservative posture in the
face of unknown consequences of inhalation of appreciable quantities of organic compounds that may or may not be
harmful at doses that occur during vaping.
Key Conclusions:
• Even when compared to workplace standards for involuntary exposures, and using several conservative (erring
on the side of caution) assumptions, the exposures from using e- cigarettes fall well below the threshold for
concern for compounds with known toxicity. That is, even ignoring the benefits of e- cigarette use and the fact
that the exposure is actively chosen, and even comparing to the levels that are considered unacceptable to
people who are not benefiting from the exposure and do not want it, the exposures would not generate concern
or call for remedial action.
• Expressed concerns about nicotine only apply to vapers who do not wish to consume it; a voluntary (indeed,
intentional) exposure is very different from a contaminant.
• There is no serious concern about the contaminants such as volatile organic compounds (formaldehyde,
acrolein, etc.) in the liquid or produced by heating. While these contaminants are present, they have been
detected at problematic levels only in a few studies that apparently were based on unrealistic levels of heating.
• The frequently stated concern about contamination of the liquid by a nontrivial quantity of ethylene glycol or
diethylene glycol remains based on a single sample of an early technology product (and even this did not rise to
the level of health concern) and has not been replicated.
• Tobacco - specific nitrosamines (TSNA) are present in trace quantities and pose no more (likely much less) threat
to health than TSNAs from modern smokeless tobacco products, which cause no measurable risk for cancer.
• Contamination by metals is shown to be at similarly trivial levels that pose no health risk, and the alarmist claims
about such contamination are based on unrealistic assumptions about the molecular form of these elements.
• The existing literature tends to overestimate the exposures and exaggerate their implications. This is partially
due to rhetoric, but also results from technical features. The most important is confusion of the concentration
in aerosol, which on its own tells us little about risk to heath, with the relevant and much smaller total exposure
to compounds in the aerosol averaged across all air inhaled in the course of a day. There is also clear bias in
previous reports in favor of isolated instances of highest level of chemical detected across multiple studies, such
that average exposure that can be calculated are higher than true value because they are "missing" all true
zeros.
• Routine monitoring of liquid chemistry is easier and cheaper than assessment of aerosols. Combined with an
understanding of how the chemistry of the liquid affects the chemistry of the aerosol and insights into behavior
of vapers, this can serve as a useful tool to ensure the safety of e- cigarettes.
• The only unintentional exposures (i.e., not the nicotine) that seem to rise to the level that they are worth further
research are the carrier chemicals themselves, propylene glycol and glycerin. This exposure is not known to
cause health problems, but the magnitude of the exposure is novel and thus is at the levels for concern based on
the lack of reassuring data.
13
Technical Report July - August 2013
Acknowledgements
Funding for this work was provided by The Consumer Advocates for Smoke -free Alternatives Association (CASAA)
Research Fund. CASAA is an all- volunteer, donation - funded, non - profit organization devoted to defending consumer
access to and promoting tobacco harm reduction; for more information, see http: / /casaa.org /. CASAA exercised no
editorial control over the author's writing or analysis: the author, not the funder, had full control of the content. The
author is thankful to Dr Carl V Phillips, the CASAA Scientific Director, for frank discussion of relevant scientific matters, as
well as Drs. Uchiyama and Laugesen for access to presently unpublished data. Lastly, the contribution of Charity Curtis,
Masters of Public Health student at Drexel University to the initial literature search was greatly appreciated.
14
Technical Report July - August 2013
Figure: Illustrating the difference between concentrations in the aerosol generated by vaping and inhaled air in a day.
Panel A shows black square that represents aerosol contaminated by some compound as it would be measured by a
"smoking machine" and extrapolated to dosage from vaping in one day. This black square is located inside the white
square that represents total uncontaminated air that is inhaled in a day by a vaper. The relative sizes of the two squares
are exaggerated as the volume of aerosol generated in vaping relative to inhaled air is much smaller in the figure. Panel
B shows how exposure from contaminated air (black dots) is diluted over a day for appropriate comparison to
occupational exposure limits that are expressed in terms of "time- weighted average" or average contamination over
time rather than as instantaneous exposures (with the exception of "ceiling limits" that do not affect the vast majority of
comparisons in this report). Exposure during vaping occurs in a dynamic process where the atmosphere inhaled by the
vaper alternates between the smaller black and larger white squares in Panel A. Thus, the concentration of
contaminants that a vaper is exposed to over a day is much smaller than that which is measured in the aerosol (and
routinely improperly cited as reason for concern about "high" exposures).
�►
B
15
Technical Report July - August 2013
Table 1a: Exposure predictions based on analysis of aerosols generated by smoking machines: Volatile Organic
Compounds
Compound
N"
Estimated concentration in
personal breathing zone
Ratio of most stringent TLV ( %)
Reference
PPM
mg/m3
Calculated
directly
Safety factor
10
Acetaldehyde
1
0.005
0.02
0.2
[5]
3
0.003
0.001
0.01
0.1
[4]
12
0.004
0.04
[8]
1
0.00004
0.0001
0.001
[3]
1
0.0002
0.001
0.008
[3]
150
0.001
0.004
0.04
[39,40]
1
0.008
0.03
3
[37]
Acetone
1
0.002
0.0003
0.003
[37]
150
0.0004
0.0001
0.001
[39,40]
Acrolein
12
0.001
1
13
[8]
150
0.002
2
20
[39,40]
1
0.006
6
60
[37]
Butanal
150
0.0002
0.001
0.01
[39,40]
Crotonaldehyde
150
0.0004
0.01
0.1
[39,40]
Formaldehyde
1
0.002
0.6
6
[5]
3
0.008
3
30
[4]
12
0.006
2
20
[8]
1
<0.0003
<0.1
<1
[3]
1
0.0003
0.1
1
[3]
150
0.01
4
40
[39,40]
1
0.009
3
30
[37]
Glyoxal
1
0.002
0.006
2
20
[37]
150
6
60
[39,40]
o- Methylbenzaldehyde
12
0.001
0.05
0.5
[8]
p,m- Xylene
12
0.00003
0.001
0.01
[8]
Propanal
3
0.002
0.01
0.1
[4]
150
0.0006
0.002
0.02
[39,40]
1
0.005
0.02
0.2
[37]
Toluene
12
0.0001
0.003
0.03
[8]
Valeraldehyde
150
0.0001
0.0001
0.001
[39,40]
# average is presented when N >1
16
Technical Report July - August 2013
Table 1b: Exposure predictions based on analysis of aerosols generated by smoking machines: Inorganic Compound?
Element
quantified
Assumed
compound containing
the element for
comparison with TLV
N"
Estimated
concentration in
personal
breathing zone
(Mg/M'
Ratio of most stringent TLV ( %)
-
Reference
Calculated
directly
Safety factor
10
Aluminum
Respirable Al metal &
insoluble com ounds
1
0.002
0.2
1.5
[25]
Barium
Ba & insoluble compounds
1
0.00005
0.01
0.1
[25]
Boron
Boron oxide
1
0.02
0.1
1.5
[25]
Cadmium
Respirable Cd &
compounds
12
0.00002
1
10
[8]
Chromium
Insoluble Cr (IV)
compounds
1
3E -05
0.3
3
[25]
Copper
Cu fume
1
0.0008
0.4
4.0
[25]
Iron
Soluble iron salts, as Fe
1
0.002
0.02
0.2
[25]
Lead
Inorganic compounds as Pb
1
7E -05
0.1
1
[25]
12
0.000025
0.05
0.5
[8]
Magnesium
Inhalable magnesium oxide
1
0.00026
0.003
0.03
[25]
Manganese
Inorganic compounds, as
Mn
1
8E -06
0.04
0.4
[25]
Nickel
Inhalable soluble inorganic
compounds, as Ni
1
2E -05
0.02
0.2
[25]
12
0.00005
0.05
0.5
[8]
Potassium
KOH
1
0.001
0.1
1
[25]
Tin
Organic compounds, as Sri
1
0.0001
0.1
1
[25]
Zinc
Zinc chloride fume
1
0.0004
0.04
0.4
[25]
Zirconium
Zr and compounds
1
3E -05
0.001
0.01
[25]
Sulfur
SOZ
1
0.002
0.3
3
[25]
# The actual molecular form in the aerosol unknown and so worst case assumption was made if it was physically possible (e.g. it is not
possible for elemental lithium & sodium to be present in the aerosol); there is no evidence from the research that suggests the metals
were in the particular highest risk form, and in most cases a general knowledge of chemistry strongly suggests that this is unlikely.
Thus, the TLV ratios reported here probably do not represent the (much lower) levels that would result if we knew the molecular
forms.
## average is presented when N >1
17
Technical Report July - August 2013
Table 2: Exposure predictions for volatile organic compounds based on analysis of aerosols generated by volunteer
va pers
Compound
N"
3
Estimated
concentration in
personal breathing
zone
(ppm)
0.04
Ratio of most stringent TLV ( %)
Reference
Calculated directly
Safety factor 10
2- butanone (MEK)
0.02
0.0007
0.2
0.007
[4]
1
0.002
6
2- furaldehyde
3
0.01
0.7
7
[4]
Acetaldehyde
3
0.07
0.3
3
[4]
Acetic acid
3
0.3
3
30
[4]
Acetone
3
0.4
0.2
2
[4]
Acrolein
1
<0.001
<0.7
<7
[6]
Benzene
3
0.02
3
33
[4]
Butyl hydroxyl toluene
1
4E -05
0.0002
0.002
[6]
Isoprene
3
0.1
7
70
[4]
Limonene
3
0.009
0.03
0.3
[4]
1
2E -05
0.000001
0.00001
[6]
m,p- Xyelen
3
0.01
0.01
0.1
[4]
Phenol
3
0.01
0.3
3
[4]
Propanal
3
0.004
0.01
0.1
[4]
Toluene
3
0.01
0.07
0.7
[4]
# average is presented when N >1
18
Technical Report July - August 2013
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