Bottom-line, Zeller notes a high correlation between teen vaping, juul, high nicotine levels, nicotine salts and flavors. However, FDA has only considered limits to nicotine levels for tobacco cigarettes. And is studying nicotine salts. Elsewhere Zeller states FDA believes Juul a good proxy for all e-cigarettes products based on market share.
User Clip: Zeller on Nictine levels | C-SPAN.org
Appears a classic case of "correlation does not equal causation." The FDA correlated teen use with Juul's flavored cigarettes and then advanced flavors as the causation (i.e. flavor ban). Meanwhile, the role of nicotine levels, nicotine salts, and device design in teen use of Juuls were not considered. Then FDA used assumed generalization of Juul as representative of all vaping [false] to extend their causation hypotheses [false] to all vaping products and users.
User Clip: Zeller on Nictine levels | C-SPAN.org
Appears a classic case of "correlation does not equal causation." The FDA correlated teen use with Juul's flavored cigarettes and then advanced flavors as the causation (i.e. flavor ban). Meanwhile, the role of nicotine levels, nicotine salts, and device design in teen use of Juuls were not considered. Then FDA used assumed generalization of Juul as representative of all vaping [false] to extend their causation hypotheses [false] to all vaping products and users.
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