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Furthermore, peer-reviewed publications examining the epidemiology, symptomology and management of pathogens affecting Cannabis are more widespread than ever before

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That creates a target for legal challenge for being arbitrary and capricious. This is a reasonable concern given the FDAs recent track record in other tobacco cases: The agencys regulation of premium cigars was struck down last year for being arbitrary and capricious, and e-cigarette makers have prevailed on challenges to its regulatory processes in the U.S

& O'Kearney, R

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