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In its announcement on July 28, 2017, FDA noted A key piece of the FDAs approach is demonstrating a greater awareness that nicotine while highly addictive is delivered through products that represent a continuum of risk and is most harmful when delivered through smoke particles in combustible cigarettes. (FDA, 2017) This paper looks at the emerging evidence base for placing newer products, such as novel Tobacco Heating Products and electronic cigarettes, on a risk continuum and concludes that currently this can only be done on a model or estimated basis grounded on toxicant emissions, toxicant exposure, and biological testing data

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