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Second, due to the cluster sampling design for YATPS and YAEPS, there was a risk that retailers would alert one another to the survey, potentially causing the RVR to be under-reported

(Notably, the FDA doesnt have to actually evaluate the public health data for companies to receive carte blanche that can happen later.) The guidance is troubling for several reasons, said Mitch Zeller, a former head of the Center for Tobacco Products at the FDA