Goal of Barack’s Memo???

Recently our President, Barack Obama, issued a memo asking Dr. Amy Guttmann, chair, Presidential Commission for the Study of Bioethical Issues, for a review of human subjects protection.

 http://www.whitehouse.gov/the-press-office/2010/11/24/presidential-memorandum-review-human-subjects-protection

 This all stemmed from the recently discovered information regarding a study that the US Public Health Service conducted in Guatemala.  While I don’t disagree that the matter deserves some attention, I feel the tasks requested require some review.

1.  Convene a Panel – Sounds like a good start to any complicated issue

 2.  Thoroughly review Federal regulations and international standards to determine if they are adequate – When I think of all the time spent to develop and re-review Federal regulations and ICH; it’s hard to believe that a panel will find a gap in their given 9 month time period.  I wonder how many people read ICH E6 on a daily basis.  I have to admit; rarely a week goes by without me picking it up.  I wonder if they will include the Declaration of Helsinki, as FDA doesn’t.  Which reminds me, don’t we have at least two Federal bodies that do this as a day job?

 3.  Conduct a thorough fact-finding investigation into the specific Guatemalan study – What do we say here in Indiana about closing the barn door after the horses have left?  Or is it cows?  At any rate, I understand the intent, but so much time has passed, I’m not sure this will add value.

 4. Seek insights and perspectives of international experts (include a Guatamalan) and have a meeting outside the US – Sounds like a good approach, but again, is this an ICH junior?  Will individuals from FDA, OHRP and ICH be excluded to get a truly unique view?

This is a serious revelation that deserves serious attention.  I fear it is duplicative at a time when we don’t have enough time and resources to do a job once.  Anyone want to take a bet that not much is found in this mission?