Editor’s Note: The author correctly highlights in the article below that FDA is required by OMB Circular A-4, Regulatory Analysis, “to analyze options that are not currently legal so as to inform the president and Congress when there are more efficient ways of solving a particular social problem than Congress had envisioned.”
From: Mercatus Center/George Mason University — Public Interest Comments, Docket No: FDA-2011-N-0921
Michael L. Marlow
Introduction