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Expert Analysis

A Little 'Guidance': All You Need For Preemption?

Law360, New York (February 3, 2012, 1:18 PM EST) -- Over the past decade, the the U.S. Food and Drug Administration has relied on guidance rather than formal note and comment rulemaking to achieve its regulatory aims and implement congressional mandates. Stephen M. Johnson, Good Guidance Good Grief, 72 MO. L. REV.695, 695 (2007)....

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