Saturday, April 28, 2007

On Reducing Bullshit in Food Safety Science and Regulation


<< "Seeing reality is the first step towards changing it." >>

New mission statement for public health agencies:

To play nicely TOGETHER in the sand box and find ways to tolerate and resolve differing minority regulatory science opinions (the approach of the supreme court should be considered);
TO BE HUMBLE by remembering the many regulatory-scientific misadventures in our past, e.g., the blood crises, the Vioxx paradox, SARS farce, the ongoing superbug crisis (add any number of other examples) and to reflect that mad cow disease is perhaps the greatest regulatory-scientific misadventure, amounting to the ultimate doctors’ dilemma and vegetarians’ worst nightmare because of the potential broad impact on foods, drugs, medical devices, cosmetics and other bovine sourced consumer products ......
To work cooperatively and transparently with all fellow Canadian citizens to maximize the health impact of the public health resources being spent;
To resist creating false expectations by making promises we know we can’t keep;
To resist wasting precious public health resources by working in redundancy or reinventing the wheel (mapleleafing) and by fostering progress by adopting or importing innovations that exist elsewhere;
To accept full responsibility for the regulatory-scientific misadventures the same way we celebrate regulatory-scientific successes;
To recognize that spin doctoring, bullshit and "lience" have no place in public health science;
To minimize secrecy because we recognize that secrecy is the ally of corruption, the hiding place of incompetence and the birthplace of bullshit and überbullshit;
To admit that we may not have all the answers all of the time and that our answers are not the only possible answers; and to never again pronounce that "The review process is sound, rigorous and based on the best available scientific information and we can be confident in our conclusions." ..... IT’S A TIME TO BE HUMBLE!

The Ottawa Citizen 2004) Re: Drug test results should not be hidden, AUG. 12.

Recent news coverage, including letters to the editor, regarding the termination of Health Canada scientists, has raised questions regarding Health Canada's scientific processes and decision-making. Health Canada's fundamental priority remains the health and safety of Canadians. Whether reviewing a drug or providing nutrition advice, our activities are carried out with the goal of improving Canadians' health. Health Canada did not take the decision to terminate the employment of these three individuals lightly. Our reasons for dismissal must by law respect the confidentiality of the individuals. Health Canada's actions were based on fundamental management principles, in accordance with the law and with our obligations as public-service managers. Health Canada recognizes the need to have the best possible science to support its decision-making. As with other drugs reviewed and approved by Health Canada, veterinary drugs are approved only after a stringent and comprehensive evaluation. Teams of scientists with a broad range of scientific expertise review drug submissions. It is this breadth of scientific evidence, not the personal opinions of individuals, that is critical to scientific decision- making. Our processes include internal and external peer reviews, discussions at directorate and branch levels, international consultation as well as the use of expert advisory committees. The review process is sound, rigorous and based on the best available scientific information and we can be confident in our conclusions.
Health Canada's Veterinary Drug Directorate (VDD) has an excellent and committed multidisciplinary team of scientists, drug evaluators and support staff. Well regarded internationally, Health Canada and VDD serve the needs of Canadians with integrity and professionalism.

Acting assistant deputy minister, Health Products and Food Branch, Health Canada

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