Dan Troy is right. The more FDA’s critics attack the agency, the more conservative some of the career staff becomes. This is partially defensive (think “turtle retreating inside the shell”) — but it’s worse. It’s the FDA sliding down the slippery slope of the Precautionary Principle wherein safety, rather than being a relative concept, becomes finite. And that’s just not possible. Perfection is an ideal to strive for, not a reality to wait on. If the FDA’s professional staff chooses to wait for perfection then new drugs will simply not come to market and the implications of that are just too profound to ignore. It’s time for an FDA BRAC process to begin. It’s time that Bureaucrats Realize Actions Count.