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Here’s how it works: Manufacturers can test anywhere from five to 10 products at a time. For our example we’re going to use seven e-liquids because that’s the number of test repetitions that FDA asks for, and it makes the explanation simpler. The extracted vapor from the seven e-juices is combined into a single composite sample, and seven repetitions of the test are done. In each series of seven, one of the seven liquids being tested is left out of one repetition. At the end, a scientist analyzing the results uses statistical wizardry to measure the HPHCs based on what’s in the six reps that include a particular liquid and what isn’t in the one it was excluded from. FDA seems to want to handle this one company at a time. I think they’ll take each applicant’s plans and obstacles into account. In these trials, Wheeler said, we’re testing the same liquids both ways—the old-fashioned way of doing them individually, and the new pooled method—and we’re comparing the results.

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