October 19, 2018

Implementing the Continuum of Risk: Modified Risk Tobacco Products

By Azim Chowdhury, a Partner, and Adam M. Susser, an Associate, with Keller and Heckman LLP in the firm’s Washington, DC office.

Summary: By setting what is essentially a zero-risk standard for non-combustible tobacco products, the Food and Drug Administration is acting contrary to Congress’s direction and poorly serving public health.