Yes.
All of it.
That misguided studies are being used to fuel public fear, in order to effect or substantiate policy decisions.
The 2nd Isn't very Fightable. Because the % might be moved around by Margin of Error amounts. But the True Population mean kinda Is what it Is.
The 1st can be Challenged with Counter Studies. But that takes Monies beyond what Grass Root Campaigns can generate. Could get Titled Reassures to Expound on a Studies Limitations.
The 3rd is Really what needs to Change. Saying you have to jump over a Bar on a Case by Case bases is kinda like say'n... "We reserve the Right to deny any PMTA if we just happen to feel like it."
Seems like some published Standard Levels should be Established as to what Constitutes an Approvable PMTA for an e-Cigarette/e-liquid. And to what is the Baseline Level of use for Teens no matter what is done Policy Wise.
Right Now, the PMTA process is asking OEM's to jump over Imaginary Bars of Unknown Height.
A New HHS Secretary / FDA Commissionaire should Change This. And should Extend PMTA Submission Deadlines until Standard Levels can be Set.