Should nicotine for vaping be limited to 20mg/ml?
The Australian Senate Inquiry is considering the Vaporised Nicotine Products Bill 2017 which proposes an arbitrary 20 mg/ml upper limit (2%) for nicotine e-liquid for vaping, as set by the European regulators. Is this too low?
Some users require higher concentrations of nicotine. In the UK, 6% of vapers use >20 mg/ml nicotine e-liquid. Many vapers also start with a high strength initially and reduce nicotine concentration later. It is the most highly nicotine-dependent smokers who need higher doses of nicotine. These smokers are at the greatest risk of smoking-related disease and are more likely to relapse on low nicotine levels.
There is no risk from higher nicotine concentrations to the user. Research has shown that users titrate their nicotine dose by vaping more or less intensely to get the dose of nicotine they need.
In fact, there is more risk from weaker concentrations. Weaker e-liquids result in more intense vaping, more liquid use and higher vapour volumes with more toxins. Although the risk of vaping is very small, it is better to reduce the risks where possible and reduce vapour volume.
First generation devices require a higher nicotine concentration to achieve effective nicotine levels. These devices can be useful for people unable to use a refillable or more complex device, especially those with mental illness or other disabilities. A 20 mg/ml limit would make devices such as Juul (45 mg/ml) and NJoy Daily (50 mg/ml) unavailable for Australian smokers.
There may be some risk to children from accidental poisoning. However, there is no evidence that modestly higher concentrations are more harmful. Most cases result in prompt vomiting and serious outcomes are rare. This risk should be managed like all other potential household poisons such as bleach, by mandatory child-resistant containers, education, safety warnings and first-aid advice.
What is a reasonable nicotine upper limit?
In its application to the TGA in 2016, the New Nicotine Alliance asked for an upper nicotine limit of 36 mg/ml. One study by Konstantinos Farsalinos found that it takes up to 50 mg/ml nicotine concentration to achieve similar nicotine delivery to cigarettes.
In the UK, nicotine up to a concentration of 75 mg/ml is not classified as a poison and is exempt from the official UK 'Poisons Rules 1982'.
There is no clear evidence on which to base an upper limit. The limit should be based on a risk-benefit analysis. The risks of higher levels are minimal and there are substantial potential benefits for users.
In my view it should be at least 50-75 mg/ml. A 20 mg/ml limit will be too low for some vapers and may lead to more harm to health than lower levels.
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