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10, 11, 12, 13, 15 The results of the present study indicated a graded increase in the UACR with both the number of cigarettes per day and the Brinkman index and support the hypothesis of a doseresponse association

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The undersigned public health, medical, civil righs and community organizations conclude that the Draft Guidance fails to recognize the well-established history of signficant variations in youth flavor preferences over time, often caused by regulatory decisions, and this fundamental flaw threatens to open the regulatory door to a wide array of FDA-authorized products that would appeal and be accessible to youth, without signficant countervailing health benefits to adults who smoke