Friday, November 22, 2019

Department of Public Health
250 Washington St
Boston, MA 02108

Submitted by: Chairman Steven Hoffman and Commissioner Shaleen Title

Thank you for the opportunity to submit this testimony about 105 CMR 801, Severe Lung Disease Associated With Vaping Products. As with our verbal testimony, we submit this written testimony as two individuals, in the furtherance of our collective goal to promote the health and the well-being of the people of Massachusetts.

Like you, we are deeply concerned about the rising number of vaping-related diseases and death, and like you, we are committed to minimizing the number of illnesses. As you know, the Commission has quarantined all THC vaping products for medical patients except for those exclusively used for vaporizing dry flower, and we are updating our regulations regarding marijuana vape products.

And, like you, we are concerned about the health of medical marijuana patients and the risk of inadvertently causing more people to obtain THC vape products particularly from informal sources, which at a national level are linked to the majority of cases. We share the same urgency in minimizing these risks and responding with appropriate regulations as quickly and safely possible.

We are here today to follow up on our request to share with us whether you have collected any evidence implicating regulated THC products, and if so, which products and where they were purchased, in order to inform our regulations. Of course, we are committed to maintaining the confidentiality of any patient data.

In particular, we follow up on previous requests to ask for one specific item of information: the source of the THC products used by people who became sick.

We are appreciative of your decision to track vaping-related illnesses over the last two months, particularly to track and release to the public the type of substance used, whether THC or nicotine or both.

CDC clinical guidance states that it is important to ascertain two items of information: the type of substance used, and where the substance was obtained.

We request you to release to our agency where the substances were obtained.

If that information has not been tracked, we are requesting you to update the mandatory vaping illness reporting form with an additional question asking where the product was obtained.

Knowing whether any of the people who became sick or died used a regulated THC vape product will not only inform our regulations but also allow us to inform patients and consumers who may have purchased the same product and may be using those products today.

We share the same goal of preventing further illness and death, and seek your collaboration in collecting this information, and if you have not been collecting it, to begin collecting and investigating it now.

Please also consider sharing this information with the public to empower the people of Massachusetts so that they can make more informed decisions regarding their own health.

To reiterate, we are appreciative of the opportunity to address you today in our own individual capacities. Thank you for your time and consideration. We look forward to continuing to work together and cooperate for the sake of public health and safety.