Like all of you, we are closely following all posts and stated concerns. While we cannot spend the days answering each one at a time, we decided to make this one single post to attempt to allay some concerns we see repeating. Your concerns ARE heard and we hope to address all in time. We are new – only posted a few hours. We have a focus on transparency and intend to share as much as possible.
First, and possibly foremost, lets cover something important. Linc Williams (Baldgroove), director of We Are Vapers www.wearevapers.com and Lou Ritter (me), also part of the We Are Vapers production team, are both Consumer Advocates in AEMSA. Neither of us are venders – in any form or fashion. Linc invited the first manufacturers to dinner at VapeStock in Florida and we all discussed the possibilities of an association like this – in concept form. Linc and I have both been integrally involved every step of the way. We are both 100% committed to Tobacco Harm Reduction and finding ways to protect vaping to that end. The Association By-laws include many checks and balances to keep one member = one vote. The By-Laws are thoroughly designed to keep AEMSA professional in both form and function.
AEMSA has a clear and stated mission: voluntary self-regulation for its members and its members only. Our focus is on the PROFESSIONAL e-liquid manufacturer and not the hobbyist. We are creating a model/example and a voice, hopefully, to be heard by those who may be working on potential regulations. Our message is clear: there are ways to reasonably, realistically and sustainably regulate e-liquid manufacturing for consumer protection. Our members are all “Small businesses” (ranging from one to ten+ employees). We invite any/all to participate.
The Mentor/Protégé program is designed to facilitate helping the even smaller operations find ways to raise their standards. The requirements to be a protégé where designed with several considerations:
– Mentoring involves a considerable investment in time on the mentor’s part.
– We will not be able to mentor everyone who asks so we want to make sure the time is invested in a committed protégé.
– The requirements help AEMSA understand the commitment the protégé has made to their business before receiving mentoring.
We also go as far as to say: “AEMSA encourages all USA e-liquid manufacturers to participate directly in this organization and/or raise (and publicize) their own manufacturing standards.” Our focus is clear; we are consumer focused with transparency. We are the ONLY association to publically post our standards for the world to see. While our Charter “members” are “members” they too have to reach compliance and become “certified”.
We have seen posts asking about “cost to become certified” and the answer is no cost. There is an application fee but zero other cost until certified compliant and accepted as a member. Then, and only then, will dues become payable (from that time on).
As we all know, there is no pleasing everyone all the time. This is a complex process. I can affirm, as President of AEMSA, this is all 100% exactly as it appears. AEMSA has no interest in controlling anyone or anything. Our membership started with a few e-liquid manufacturers who were enthusiastic at the idea we proposed. “For the benefit of vaping, lets try to set an example/model for what self-regulation could be.” To approach this goal, we asked ourselves: “If you had to stand in front of the FDA and present an argument for what might constitute reasonable, realistic and sustainable regulation – what would you present?”. The 5 belief statements are the answer to that question and the standards grew from those beliefs.
We added members based on whom we individually and personally knew well enough to approach and keep things internal. As this thread demonstrates, speculations and baseless assumptions proliferate easily. When we reached a point where the detailed process of analyzing each and every line-item in the standards and by-laws became almost prohibitively involved and lengthy, we decided to close applications until we could create a solid foundation to build upon. Each of our members had to voluntarily disclose all their business processes and details to an even greater extent required of new applicants. Had we even tried to include more, chaos would have ensued. We now have that foundation and have re-opened the doors for new applications.
As is the case with any/all Associations, we have expenses. Legal fees are no small part of those expenses. Travel to each and every member facility entails expenses. If we have ten members, ten travels will be necessary (at minimum and probably more). If we get 20 members, means 20 travels (and probably more). Unscheduled inspections are in addition to those travel expenses and must be budgeted for as well. If we are to be available to visit with regulators, who may wish to hear a community point of view on Self-Regulation, possible considerations for establishing governmental regulation, etc., – such will ALSO involve travel expenses. For such a meeting, regulators will have a team of people and we would want at least 2 or 3 representatives. Multiply out the expenses and this effort requires some realistic funding. There are many expenses to running ANY association and AEMSA is no different.
It is true, not every e-liquid manufacturer has an operation generating enough revenue to afford the dues. We are discussing possible ways to address the matter. We do not have all the answers yet – we are just getting started. We feel it is a fair approach to keep dues level for all. While it might be “ideal” to have free, or pocket-money size dues, such would never fund the expenses of an Association like AEMSA. As with ALL associations, some will be able to afford the dues and others may not.
The Standards are a starting place – not an ending place. They will be living documents and refined over time – input and logistics are ongoing considerations. We WANT more members to join and help us make the Standards ever better and more effective – both in the interest of enhancing consumer confidences as well as ensuring manufacturers are comfortable with the “responsible, realistic, and sustainable” factors. Please keep in mind, AEMSA is 100% voluntary. We want e-liquid manufacturers to join and participate. More members can only help shape and improve what the organization can be, do and as a statement to any/all watching that our community can be, and is, responsible.
Right now, our “industry” has no voice at all. We are all sitting around waiting to see what “they” impose. AEMSA hopes to create a VOICE for vaping where there are no other opportunities to he beard. Our goals are presented on our “Mission” page and they are clear, we represent manufacturers who voluntarily request participation. We created standards to promote professionalism and hopefully be considered as a model for actual regulation. My quote from the site shares my personal sentiments: “We can watch disinformation, and fear from ignorance, continue to disseminate or we can co-create a structure to educate, inform and facilitate.”
Some of the issues we see expressed in this thread:
WTAs: The Standards include WTAs will not be “added” as an additional ingredient. They are not prohibited, just unacceptable as in added ingredient in its own right. There are many concerns related to the topic of WTAs and our discussion was lengthy. There are some extremely expensive chemicals used in the extraction of WTAs and those making them refuse to divulge those ingredients (“trade secrets”). Not knowing what chemicals are used in the process, we cannot confirm if the product(s) meets “GRaS”. Therefore, we cannot responsibly allow them as additives at this time. As more accurate and verifiable information becomes available, we will be monitoring and considering if any amendment(s) to the standards become warranted.
Food COLORINGS: We know some of our members use them. We are investigating the issue. As with many aspects of vaping, there are no long term tests or research analyzing ingestion via inhalation vs digestion. Please know, we are aware of this issue and are considering with respect and diligence.
ECF: Let us be VERY clear on this point. ECF likes the idea what we are hoping to accomplish – as a proactive and responsible step/example/message. I have no way of knowing if they agree with all we are trying to accomplish or not. So far, we have no indication from ECF as to their official stance on AESMA or any of our detailed Standards. At this time, ECF has no involvement in AEMSA. ECF only received our documents within the last 36 hours prior to post. They felt this was a significant effort and worthy of getting the information out to all ECF members right away.
DIY: Once again, we are an organization for Professional e-liquid Manufacturers ONLY. We have nothing to do with DIY. Our members’ DIY nic is subject to the same quality and content accuracy standards as all other nicotine. However, in unflavored/DIY nic, we do not yet impose any maximum content level.
While we cannot spend the days responding to each and every post here – we are listening and we do care. AEMSA representatives will appear on the Vape Team show ( www.vapeteam.com ) on Wednesday night to further discuss some points and answer some questions. We will also be going to VaporCon2 and look forward to this opportunity to meet attendees and answer questions.
We hope you will all give us some time to share, answer questions, allay concerns and most of all grow into something you may find to be worthwhile. Such cannot happen overnight. Today is merely day one. We now have the foundation in place and we are ready to start building on that foundation. AEMSA needs time to get on its feet, grow and mature. We think we have built a good starting point.
Below, please find our fee structure. As we have said, we believe in transparency. There are costs, as some are outlined above, to run an association. Such costs are REAL and cannot be avoided. This is merely a reality of any association. Some may agree and others may not. That does not change the facts – these expenses are all real and as a non-profit organization, we have even higher accounting standards WE MUST FOLLOW.
Thank you again for your input. Your comments, ideas and concerns ARE being heard. We will not be able to satisfy everyone – sort of goes without saying – but we truly hope the foundation we built has an opportunity to become a positive contribution to vaping and a voice vehicle. None of us want stifling and oppressive regulations.
Lou Ritter – AEMSA President
What does AEMSA membership cost?
Your membership dues will support the AEMSA’s mission of preserving and promoting Tobacco Harm Reduction. AEMSA operates through the process of VOLUNTEER self-regulation of e-liquid manufacturing. We hope to represent our members at the local, state, and national level. Membership is voluntary and annual. Membership is ownership/entity based and non-transferable/non-refundable. However, members are free to cancel their memberships at any time (subject to no-refund of dues paid and/or owed).
Building and operating an association requires funding. Our fees are based on budgets that include, but not limited to: legal fees, web development, accounting fees, travel to every member site for inspections, possible travel to regulatory meetings and more. While there is currently zero payroll, we may have to hire various services and/or professionals over time. Our fees are not scaled and applicant business operational size is not a factor.
We understand dues may be a concern for some. Any/all Associations have dues and expenses. We, here at AEMSA, are dedicated to keeping costs (and dues) at a minimum. Dues do not become due until an applicant has been confirmed as an approved “Member” but the application fee is due with the application.
AEMSA has developed a membership dues structure.
$500 due with application (nonrefundable)
Monthly Dues $425
Can prepay (annual of $5100.00)
Monthly payments must be set up with an auto debit system