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BLUM: I think we ought to back up just a little bit

But the science clearly indicates vaping is not a safe or healthy alternative to smoking

The term alternative nicotine products refers specifically to those nicotine-only products which, unlike NRT products, have been developed for recreational, rather than strictly medicinal, use: these include the aforementioned e-liquid and nicotine pouches, as well as disposable or pre-filled nicotine vaporizers and nicotine toothpicks

We request comment on our proposal to score topped out measures impacted by limited measure choice using specialty defined topped out measures including the proposed defined topped out measure benchmark