Instead of this insane regulatory approach, the FDA should scrap the requirement for product applications and should simply promulgate basic safety standards that ensure minimum, uniform requirements for product safety. If the agency allows for a 12-month grace period, we could expect to see these requirements actually take effect within two years.

This argument is fallacious, I believe, because there are many things that changed from one cohort to the next. The introduction of cigarette filters is only one such change. To assume that any observed changes in cancer risk from one cohort to the next must be attributable to one particular change - the filter - is not appropriate, in my view.

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