Natural Resources Defense Council - Comment

These comments are being submitted on behalf of the Natural Resources Defense Council (NRDC). NRDC is a national, non-profit environmental and public health membership organization with more than 420,000 members nationwide. NRDC has no financial interest in food additive, food products, personal care products or any other product that is regulated by the FDA. We are extremely pleased that the Food and Drug Administration (FDA) is responding to public concerns and allegations of scientific mismanagement, suppression, and secrecy that have clouded the Agency in the past. In these comments we will make recommendations for the enforcement of strong and effective policies to identify, disclose and prevent financial conflicts and competing interests among government scientific and technical experts. We also make recommendations for improved communication with the general public including improvements in the web interface, improved placement and access to documents submitted to FDA, and timely response to FOIA requests and petitions to the Agency. While we appreciate the effort that FDA has put into this process, we are concerned that the questions being asked by FDA to address issues about transparency at the Agency are not structured in a manner that will allow for the substantive changes that are necessary for restoration of public confidence in an Agency charged with protecting public health. To illustrate our concerns about how the Agency has interacted with the public and public interest groups in the past, we are presenting our comments and recommendations in the context of specific products currently regulated by FDA.