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This "public health" standard is a black box in practice, and the FDA's interpretation of it contradicts its statutory mission to minimize risks and maximize benefits for "the population as a whole." It is therefore hard to take Farrelly seriously when he declares that "we are a data driven agency and will continue to follow the science to inform our review of premarket tobacco applications." The FDA is not simply "follow[ing] the science." It is engaging in fallible predictions and making value judgments about whether adults should be allowed to buy products they want—products that could literally save their lives if they are appealing enough to motivate and maintain the switch from smoking to vaping—based on its perception of the likelihood that teenagers, who are not legally allowed to buy ENDS, might also be inclined to use those products

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