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This premise assumes these products have the potential to pose equivalent harm with regard to relative risk, target tissue toxicity, and mechanism, yet studies using established combustible tobacco end points have found less evidence of vaping-related health effects than with combustible cigarettes (164, 165)

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Contract Drafting: Formalize agreements, including NDAs and quality clauses

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Second, barely one year after the Deeming Rule became final, FDA substantially deregulated e-cigarettes by issuing a Guidance purporting to suspend premarket review of e-cigarettes that were on the market as of the effective date of the Deeming Rule by extending the deadline for filing PMTAs for four years (until August 2022)