Over the years we have heard various rumors about the FDA regulating the production and selling of hookahs and hookah products. This month, Social Smoke took a trip to the FDA Headquarters in Washington D.C. to hear from scientist and speak before representatives of the proposed FDA regulations to provide our perspective on what the actual impact of these regulations on public health.

Proposed Regulations
The proposed FDA regulations would greatly impact the way hookahs are consumed in the US by:

  • Freezing the state of the market as it was in 2007 by banning products introduced to the market after 2007. (This is product specific so if a brand changed its recipe on a flavor after 2007 that new product would be banned)
  • Regulating accessories. This includes hoses and coals.
  • Enforcing various sells controls

The stated goal of the FDA’s proposed regulations is to increase public safety. Remember that as you keep reading.

Grandfather Clause

The most important clause of these regulations is the Grandfather Clause. The Grandfather clause proposes that all hookah tobacco produced after 2007 will be systematically banned, while any tobacco with a production date of 2007 and before is to register with the FDA and applicable to distribute. The reality is that these proposed guidelines don’t eliminate tobacco in the market, but instead,changes the competitive landscape. In other words, this clause has winners and losers. Most US based hookah tobacco companies would fall under the proposed guidelines while other older Mid-East and North African companies would be free to distribute their product.

The Grandfather Clause would put the majority of US based tobacco manufacturers out of business while allowing older foreign companies, which already violate current federal labeling guidelines, to flourish without competition.

The most frustrating part of this proposal is that it wouldn’t have a positive impact on the ‘health’ of the American consumer because the tobacco is still available. In fact, it could create more harm than good, because foreign products wouldn’t be subject to screening. So essentially, no one would know content or nicotine count.

The Science

This section is second because frankly it appears science is an afterthought to the creation of the FDA guidelines as well.
Social Smoke stated at the FDA that there are negative health effects any time material is combusted and inhaled.
The scientific community has made many advances in their study of hookah smoking and have identified many harmful chemicals and effects of smoking. That said, most studies used cigarette smoking as a baseline to compare hookah smoking to. However, at this point, scientific fact loses its leverage.. Every scientist reported their findings by comparing a 45 min or 1 hour hookah session to one cigarette. This odd comparison was even called into question by Dr. Ashley ,the Director of the Office of Science at the Center for Tobacco Products (CTP), at the FDA. He asked if it would make more sense to compare 1 hookah session with 10 (or more) cigarettes based on what the average smoker smokes in one day. We raised the exact same statement in our speech.
Comparing the toxicity levels of one hookah session to 1 cigarette is inaccurate, and furthermore separating toxicity levels from use frequency does nothing more than blow one gigantic smoke cloud over any chance of truly understanding the effects of smoking. The FDA has made all speeches and slides available in the public record. Take the time to check it out.  You’ll find that the data as reported states that the amount of hookah smokers decline use with age, smoke socially with friends, and use the pipe very infrequently. The scientist seemed eager to show that smoking hookah is far more dangerous than cigarette smoking, and blood and toxicity levels based on actual use patterns was conveniently ignored.

This is not to make light of the negative health effects of smoking hookah, because we already said that smoking hookahs isn’t healthy, but it specifically highlights the disconnect between the data as reported and reality. Science is held to a higher standard than normal discourse and we’re hoping our comments and questions by Dr. Ashely and others will help push the scientific community to provide a more complete picture of the true harmful effects of hookah smoking especially when compared to cigarette smoking.

In Summary

As we stated at the FDA, combusting any material and inhaling it is never healthy, so it would make sense that efforts are focused on creating safe manufacturing standards and marketplace guidelines. The Grandfather Clause of the proposed regulation will not improve public safety but will surely destroy US based manufacturers. Passing the regulations based on an arbitrary cut off date makes for good political theater but does little to accomplish the stated goal of improving public health and safety.