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Healthy Skepticism Library item: 12095

Warning: This library includes all items relevant to health product marketing that we are aware of regardless of quality. Often we do not agree with all or part of the contents.

 

Publication type: report

Subcommittee on Science and Technology, US FDA
FDA Science and Mission at Risk: Report of the Subcommittee on Science and Technology
: Subcommittee on Science and Technology, US FDA 2007 Nov
http://www.fda.gov/ohrms/dockets/ac/07/briefing/2007-4329b_02_01_FDA%20Report%20on%20Science%20and%20Technology.pdf


Abstract:

Table of Contents

FDA Mission Statement……………………………………………………………iii

1.0 Executive Summary………………………………………………………….1

1.1 Overview……………………………………………………………………….1 1.2 Major Findings………………………………………………………………..3 1.2.1 The FDA cannot fulfill its mission because its scientific base has eroded and its scientific organizational structure is weak………3 1.2.2 The FDA cannot fulfill its mission because its scientific workforce does not have sufficient capacity and capability………….4 1.2.3 The FDA cannot fulfill its mission because its information technology (IT) infrastructure is inadequate…………………………..5 1.3 Summary Statement and Recommendations………………………..6 1.4 The Structure of This Report……………………………………………..8

2.0 Context: The Changing FDA Environment…………………………….9

2.1 Growing Disparity between Responsibilities and Resources…..9 2.2 The Criticality of Science…………………………………………………12 2.3 The Changing Nature of Science………………………………………16

3.0 Discussion of Key Findings and Recommendations………………20

3.1 Science: Capability, Capacity and Organization…………………..20 3.1.1 Finding: FDA does not have the capacity to ensure the safety of food for the nation……………………………………………………..21 3.1.2 Finding: The development of medical products based on “new science” cannot be adequately regulated by the FDA……………….24 3.1.3 Finding: There is insufficient capacity in modeling, risk assessment and analysis…………………………………………………30 3.1.4 Finding: The FDA science agenda lacks a coherent structure and vision, as well as effective coordination and prioritization…….33 3.2 Workforce: Securing Critical Scientific Capability and Capacity38 3.2.1 Finding: The FDA has substantial recruitment and retention challenges…………………………………………………………………..40 3.2.2 Finding: The FDA has an inadequate and ineffective program for scientist performance…………………………………………………42 3.2.3 Finding: The FDA has inadequate funding for professional development………………………………………………………………..42 3.2.4 Finding: The FDA has not taken sufficient advantage of external and internal collaborations…………………………………….43 3.3 Information Infrastructure……………………………………………..45 3.3.1 Finding: The Subcommittee believes that there is evidence of important, but slow, progress to improve information sciences and technology at the FDA over the past few years, yet significant gaps remain………………………………………………46 3.3.2 Finding: The FDA lacks the information science capability and information infrastructure to fulfill its regulatory mandate…………47 3.3.3 Finding: The FDA cannot provide the information infrastructure support to regulate products based on new science………………………………………………………………………49 3.3.4 Finding: The FDA IT infrastructure is obsolete, unstable, and lacks sufficient controls to ensure continuity of operations or to provide effective disaster recovery services……………………….50 3.3.5 Finding: The IT workforce is insufficient and suboptimally organized……………………………………………………………………51

4.0 Overarching Findings of this FDA Review…………………………..53 4.1.1 Finding: The FDA has experienced decreasing resources in the face of increasing responsibilities…………………………………..53 4.1.2 Finding: Recommendations of excellent FDA reviews are seldom followed……………………………………………………………56

List of Appendices
A. Subcommittee to the FDA Science Board……………………………..A-1
B. The State of Science at the Food and Drug Administration……..B-1
C. Center for Food Safety and Applied Nutrition (CFSAN)…………..C-1
D. Center for Veterinary Medicine (CVM)…………………………………D-1
E. Center for Drug Evaluation and Research (CDER)………………….E-1
F. Center for Biologics Evaluation and Research (CBER)……………F-1
G. National Center for Toxicological Research (NCTR)……………….G-1
H. Center for Devices and Radiological Health (CDRH)………………H-1
I. Genomics…………………………………………………………………………I-1
J. Surveillance/Statistics………………………………………………………J-1
K. Information Technology (IT)……………………………………………..K-1
L. Task 1: Outline of Core FDA Regulatory Functions…………………L-1
M. Task 2: Identify Limitations of Today’s Regulatory Science, Mapped to Regulatory Functions………………………………………..M-1


Notes:

Free access to full report (.pdf)

 

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Far too large a section of the treatment of disease is to-day controlled by the big manufacturing pharmacists, who have enslaved us in a plausible pseudo-science...
The blind faith which some men have in medicines illustrates too often the greatest of all human capacities - the capacity for self deception...
Some one will say, Is this all your science has to tell us? Is this the outcome of decades of good clinical work, of patient study of the disease, of anxious trial in such good faith of so many drugs? Give us back the childlike trust of the fathers in antimony and in the lancet rather than this cold nihilism. Not at all! Let us accept the truth, however unpleasant it may be, and with the death rate staring us in the face, let us not be deceived with vain fancies...
we need a stern, iconoclastic spirit which leads, not to nihilism, but to an active skepticism - not the passive skepticism, born of despair, but the active skepticism born of a knowledge that recognizes its limitations and knows full well that only in this attitude of mind can true progress be made.
- William Osler 1909