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However, without the underlying harms, the deterrents are greatly weakened, and there is no justification for a punitive, coercive and stigmatizing policy

From an accountability perspective, it would provide a clear articulation of how the FDA uses its resources and powers to protect public health

Nicotine gets in the way of that process

Avoid Requiring Human Studies It is possible to characterize the risks associated with vaping by analyzing the devices emissions under realistic operating conditions, and there is no need to add to the burdens on applicants by requiring biomarker or pharmacokinetic studies

The instrument was constructed based on the differential exposure to Chinas CSLs across provinces and birth cohorts