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In 2011, the FDA drafted a guidance document (15) that was intended to help e-cigarette manufacturers submit ( a ) documentation of substantial equivalence (SE) if the product was similar enough to a tobacco product already on the market, or ( b ) a premarket tobacco product application (PMTA) if the product was substantially different

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For these tests, SRM 1196 is typically placed on a mattress, a piece of upholstered furniture or furniture components to verify if these items have been manufactured to meet mandatory and voluntary federal, state or industry guidelines for resistance to ignition by burning cigarettes