implications or that preempt State law.” 65 Fed.Reg. at 81103 (emphasis added). Further, despite our specifically asking the FDA to address whether their current position can be reconciled with the December 2000 statement, the Colacicco Amicus brief is completely silent on the 2000 statement. See Letter to Counsel for the Government Re: Follow-Up Questions for the Amicus Brief, Colacicco v. Apotex, Civ No. 05-5500 (Doc. No. 44) (E.D.Pa. May 4, 2006); Colacicco Amicus at 20. Nonetheless, although consistency of an administrative agency’s , position is a factor, as Chevron made clear, there is no longer any justification for not giving deference to an agency’s interpretation of law merely because it is not the agency’s longstanding position. Chevron, 467 U.S. at 863-64, 104 S.Ct. 2778 (<HOLDING>). “On the contrary, the agency, to engage in
holding that an agencys interpretation of its own regulations is entitled to deference holding that where statute is ambiguous deference is appropriately accorded to agencys interpretation holding that agency interpretation which is reasonable is entitled to deference holding the fact that the agency has from time totime changed its interpretation  does not  lead us to conclude that no deference should be accorded the agencys interpretation of the statute an initial agency interpretation is not instantly carved in stone see also horn 376 f3d at 179 we cannot agree with plaintiff that the fdas position is entitled to no deference  simply because it represents a departure from its prior position holding that a longstanding agency interpretation was no longer entitled to chevron deference given that the agency had changed its position on the issue