Originally posted by: Thump553
Originally posted by: microbial
The FDA is not immune from the phenomena of political policy and lobbying trumping science. Not the least in the last 8 years.
Having said that--would anyone really argue to allow the drug industry and the food industry to self-regulate themselves?
Not me.
Seems to me, a more sensible alternative would be to populate the agency with more professional scientists and less administrivial hacks, and insulate the agency from political pressure. Same goes for a number of other agencies.
Private industry might not be too thrilled with that kind of change.
At last, someone who has a rational answer.
The FDA is populated with highly knowledgeable and professional people. Only the very top are appointees and political people, and I don't think its nec fair to assume they are all Micheal Brownies. The people on the ground, the regulators and inspectors are well educated and professional people. And I can tell you, Pharmas are scared shitless of them.
(A number are ex-FBI at that, and know how to find things you may try to hide.)
FDA has the right to come into your facility at anytime for any reason unannounced, and demand to see your manufacturing records, SOPs, manufacturing deviation records, customer complaints (manu's required to keep,) training files, as well as observe any process they want for as long as they want. And these inspectors do, and often.
If they don't like what they see, they can and will cite you and require you to make the necc process changes. These citations become public record. Sanctions can run from simple change requirements to fines to revoking/suspending sales licenses to even prison terms (in a very very extreme case.) They are a
big fucking deal. Want to read about the program? Here's a recent search of
Warning Letters. A mid-level citation as far as things go. Search FDA 483 for more severe observations. A consent decree is a double anal fist fuck you
do not want to happen, that will cost you millions of $$, big market share, years on your competitors, frequent and hostile FDA visits, and can destroy your company if you aren't too big to weather it.
Different products have different standards. Pharmaceuticals are the most tightly regulated, and least tolerant to errors. Medical devices are lower, and food is much lower than that. Things like herbs and supplements are not regulated at all. (things like hydroxycut and herbs like echinacea fall into the later.)
If, IF, by some means you managed to "corrupt" a FDA inspector or even agency, Pharmas are still regulated by any regulatory agency in which they sell products. For big things like drugs or med devices, this could mean every country in the world. Canadian have their own agencies that will do inspections (can't just roll up on you on US soil like FDA can, but can shut you out of their country if you refuse) as do the EU, Japan, Brazil and SA. ISO audits.. Customers do their own audits, such as the Red Cross and or any company you supply raw materials to (and they are required by FDA et al.) FDA is the most aggressive, but all can F you up if you are doing something non-compliant (and get the FDA on your ass.)
Now a non regulated product like supplements can be grinding up rats and selling it as a magic dick potion, and its not under FDA's jurisdiction. OTOH, if I'm working in a drug manuf lab, and I have an SOP that says I have to open the lab door with my left hand, and I open it w/ my right, the FDA can cite you if they catch you. And the level of control they want you to have over your process goes nearly down to that level. Seriously. For
everything.
Everything you needs to be described in a written SOP, training files for those doing it, a validation report showing it works, a monitoring program to see that its properly done that way, a calibration program if there's a spec or measurement involved, a traceablity procedure to document everytime it was done, and a change control program to govern any proposals to do it a different way and that it addresses all the aforementioned requirements.
Now, its a perfectly reasonable debate to whether the way the FDA regulates is the most effective or not. Casually throwing around accusations of corruption or conspiracy is just plain ignorant.
Working in the industry, I'm glad the FDA regs are there. They are a blunt instrument, not always fair or the most effective, but it does create a foundation of standards to follow. People get busy, tired, lazy or sometimes don't think everything thru. Some people just don't give a shit. You need this framework to ensure people are motivated to do things properly and safe or
some people
will take shortcuts and endanger a large number of people. FDA or no, some people do stupid things anyway.
Just look at the shit going on in China for an example of what happens when people are left to their own devices. They can do things cheaper and faster in some ways, but OTOH, but in the US you don't have to worry that your toothpaste is going to poison you, formula will kill your baby, drugs have a good chance to kill you
if they work at all, and lab tests actually provide the data and results they are supposed to and doctors can make good decisions based on them.