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That standard requires the agency to consider the risks and benefits to the population as a wholeas laid out by Congress in the Federal Food, Drug, and Cosmetic Actincluding users and non-users of tobacco products

(I have been a member of CRA since August 2008.) You can read the full text of my email and frustration of non-action and little response from CRA here: 5

Now, one viable type of smokeless tobacco product that is more utilized by many adults today is chewing tobacco

First, data was drawn from both men and women of varying ages and socioeconomic conditions, allowing for broader representativeness and source triangulation