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In fact, it is unrealistic to try to compare the nicotine intake of vape and cigarettes one by one for the following reasons: Nicotine is absorbed in different ways: cigarettes release nicotine through combustion, which is rapidly absorbed after entering the lungs, and the effect comes quickly and violently

[77] This is done to treat or prevent problems with distal circulation, or ventilation

We have some discretion for interpretation, but the courts recently have limited or have taken a view for the most part that federal agencies have limited discretion to interpret rules, FDA Commissioner Robert Califf, MD, said at APHAs Policy Action Institute, just a few days prior to the Loper decision