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"This is a measure that has really passed the scream test

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"Given the extreme risks cigarette smoking poses to the public health," said Mitch Zeller, who runs the Center for Tobacco Products at the FDA, "new proposed warnings of this type are critical to promote greater public understanding of the risks associated with cigarette smoking." In 2009, Congress first directed the FDA to require warning images on cigarette packages

or (7) customer negligence