WatchList: Ingredients

CODE RED
Diacetyl (IUPAC systematic name: butanedione or 2,3-butanedione):

A 4-carbon alpha-diketone known as a volatile organic compound (VOC) used to create or enhance primarily buttery-type flavors in foods and beverages (many of the so-called "butter-bomb" chardonnays have added diacetyl to enhance the buttery quality). Diacetyl has come to serve as the umbrella name for the butter-flavoring agents, although NIOSH researchers noted:
“the vapors emitted from butter flavoring are a complex mixture that produces necrosis that cannot be explained by the known toxicological properties of any of its components.” (Hubbs, et al. 2002)
While popcorn manufacturers pulled diacetyl from their recipes, the FDA continued to maintain diacetyl's standing on the GRAS list, despite calls to action from such sources as The Project on Scientific Knowledge and Public Policy at the George Washington University School of Public Health and Health Services, who petitioned the FDA in 2006 to reevaluate diacetyl's inclusion on the list.
"The evidence remains strong: breathing diacetyl vapors causes lung disease, and there is no evidence of a safe exposure level." 
(Followup letter to the FDA from George Washington University Associate Professor of Health Policy and Environmental & Occupational Health, Susan Wood, PhD, and Assistant Research Professor, Environmental & Occupational Health, Celeste Monforton, DrPH, MPH. )
In a recent response to Drs. Monforton and Wood, the FDA stated that they will be following up on the petition to remove diacetyl from the GRAS list.
"Your petition is under active review at this time.  This review will incorporate all the scientific evidence available to the agency and our assessment of its significance for the public health of consumers.   …We also intend to address the issue of diacetyl-containing substitutes in our response.   Although it is highly unusual for the FDA to contemplate food ingredient regulation on the basis of inhalation, we have not ruled out any regulatory option." (FDA Response, January, 2010
It would seem that the FDA, already looking at the e-cigarette industry with an eye toward regulating personal vaporizers as a drug delivery device rather than a tobacco-alternative, might also be looking to grasp control from the industry altogether using diacetyl as a basis for regulating inhaled flavorings.

What Can I Do?
Consumers:
Immediately discontinue use and inform your suppliers that you will not purchase any juice without a signed statement of diacetyl and diacetyl-like substance disclosure to be faxed or mailed to you.

Example:

Dear Sir/Madam,
Recently it has come to my attention that many flavoring companies use diacetyl or diacetyl-like (acetyl propionyl) flavoring agents, which may in turn be added to your product .  Before further purchase I request your signed statement of disclosure as to whether any of your products contain these substances or not.
Thank you in advance,
Vendors/Suppliers:

  • Immediately discontinue use of any and all flavoring agents which contain or which you suspect contain diacetyl or diacetyl-like compounds.
  • Contact your flavoring agent suppliers and ask for a signed statement of diacetyl and diacetyl-like substance disclosure to be faxed or mailed to you.
  • Craft a disclosure letter to be posted on your website, with your advertising materials, and available upon request to consumers and state or federal agencies.
  • Create labeling standards which disclose a basic ingredient list, along with MSDS sheets available for each mixture upon request.

If you are unable to fulfill any or all of these points, it is strongly recommended that you discontinue sales of e-juice, as you may be putting yourself at significant risk of action by the federal government, as well as putting your customers at risk of serious injury or death.

CODE: ORANGE


Nicotine: (IUPAC systemic name (S)-3-(1-methylpyrrolidin-2-yl)pyridine)
From 3dchem.com:

"Nicotine is an organic compound, an alkaloid found naturally throughout the tobacco plant, with a high concentration in the leaves. It constitutes 0.3 to 5% of the plant by dry weight, with biosynthesis taking place in the roots, and accumulates in the leaves.
It is a potent nerve poison and is included in many insecticides. In lower concentrations, the substance is a stimulant and is one of the main factors leading to the pleasure and habit-forming qualities of tobacco smoking.
Nicotine has limited carcinogenic effects, inhibiting the body's ability to destroy potentially cancerous cells; however, nicotine does not promote the development of cancer in healthy cells. In addition to the tobacco plant, nicotine is also found in lower quantities in other members of the Solanaceae (nightshade) family, which includes tomato, potato, eggplant (aubergine), and green pepper. Nicotine alkaloids are also found in the leaves of the coca plant."
Nicotine is a potent poison and it should be noted that any business working with nicotine should engage in Haz-Mat training and protocol, including notifying local Haz-Mat authorities that workers are exposed to this substance on a regular basis.

At this time it it unknown how much of the tobacco absolute/nicotine extract on the market is pharmaceutical grade versus insecticide grade, but should be worth noting that as "vaping" is not yet approved by the FDA as a smoking cessation device or covered under the Federal Food, Drug and Cosmetic Act as a tobacco alternative.  In short, nicotine absolute doesn't appear to be regulated or necessarily even legal for sale to the "average joe" - and this industry, whether it is vendor-side or DIY - seems to be made up entirely of "average joes" at the moment.

Extreme caution in all cases of nicotine handling should be exercised.