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As a veterinarian, I've long been involved with medicines that were mainstream prior to the establishment of the FDA in 1938 due to working with hundreds of clients in the USDA certified organic realm. Why do I use medicines such as botanicals? Due to the complete prohibition of antibiotics and synthetics under the Organic Foods Production Act of 1990. Between 1906 and 1938, botanical medicines were produced to be safe and to what the label said was on them. They are grand-fathered by FDA's own admission, but by administrative procedures they have been shut out of commerce ever since the pharmaceutical synthetic juggernaut beginning around 1940.

Agreed, industry often seeks regulation when there is confusion in the marketplace and they can shore up confidence. Same in the organic sector, and similar to meat packing, really large players have gotten involved.

How does this relate to your excellent insight into why FDA was formed and how it could reformed, at least to some accountable degree?

Just like Underwriters Labs and the BBB and now Yelp, there should be a 3rd party review system of proposed medicines by accredited reviewers. The Organic Materials Review Institute is the gold standard for what's allowed to be used in USDA certified organic crop, livestock and processing. Their reviews rake materials over the coals and are consistent with what the USDA National Organic Program has accepted by what has been petitioned for use through the open public process of the National Organic Standards Board (which I was on for 5 years). Their review process is long and tedious and ultimately fraught with bureaucracy, but ultimately fair to both consumer and manufacturer to make sure materials are in line with the statute.

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