You can use all the quantitative data you can get, but you still have to distrust it and use your own intelligence and judgment.
-- Alvin Toffler
Last week (October 1 at the at the Center for Strategic and International Studies), FDA Commish Peggy Hamburg noted that the recently enacted FDA Safety and Innovation Act provides the agency with new authorities surrounding information-sharing with foreign regulators, as well as user fees to pay for some of those activities.
Information-sharing “makes complete sense. There’s too much work to be done, you have to do it together across nations with an agreed-on set of standards and outcome measures. But if we rely on an inspection done by another country and then there’s a problem, everybody’s going to say, ‘How could you possibly have let that happen?’ So I think we do have to be realistic about that.”
If FDA takes action based on information collected by other regulatory authorities “and something goes wrong, there’s going to be a price to pay. So I think that there’s going to be a pendulum that’s going to go back and forth as we move towards systems that hopefully will work in a more enduring way.”
In other words, there has to be political accountability for domestic regulatory decisions. No argument there. But that doesn’t mean the use of non-US data should be verboten. And it doesn’t mean there shouldn’t be a predictable way the agency uses such data in domestic regulatory matters.
That is both “realistic” and “enduring.”
No foreign policy, no matter how ingenious, has any chance of success if it is born in the minds of few and carried in the hearts of many.”
-- Theodore Roosevelt
