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124 Given potential monetary and feasibility challenges that were associated with reporting all 93 HPHCs on FDA's list, FDA released an accompanying 2012 draft guidance that provided an abbreviated list of HPHCs that manufacturers of cigarettes, smokeless tobacco, and roll-your-own tobacco would be required to report to FDA

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Thorax 1998;53: Supplement 5 Part 1 pp 1-17

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A second or third violation for a tobacco product licensee not only results in increased penalties but could cause a suspension or revocation of your license, which would prohibit you from legally selling tobacco products in California

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