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by whatshisface 2310 days ago
>FDA regulates test kits but generally lab developed tests, which are designed and used in single lab, can be offered without FDA review. When HHS declares Public Health Emergency and issues declaration to support EUAs, labs must seek FDA authorization before launching new test.

Normally they can be done without approval, but there is a special regulation on the books that activates when the department of health and human services declares a public health emergency.

1 comments

The natural question is then: why haven't the people in charge issued some sort of exemption or blanket authorization in this case?
Because government bureaucracies cease to function in their original task and become only concerned with their preservation. It’s a lesson that happens over and over and we selectively ignore it.

Remember this folks when voting for people who advocate for a greater role of bureaucratic control of our lives.

Taken literally, you are correct and you advocate good advice - to remember this and presumably weigh it among the pros and cons. However, your phrasing could be interpreted to have a subtext suggesting less bureaucracy is always better.
There's no way to criticize any bureaucracy without having a subtext that less bureaucracy is always better, if the mere implication that less bureaucracy would have prevented the problem is enough to conjure that subtext in the minds of the readers.
Why do we always measure burocracy as an "amount" (something of which there can be "less" or "more"). Surely there can be unnecessary, pointless, frustrating, harmful, nerve-wracking acts burocracy which can require more or less time to be performed. But isn't the real measure we should have one about quality of the outcome and balancing that against any effort endured by the populace?
> Why do we always measure burocracy as an "amount" (something of which there can be "less" or "more").

Because large bureaucracies only ever get modified in the aggregate.

You have a bureaucracy that imposes 500,000 rules. If you want to know which are worth it, you have to evaluate each of the rules individually, because some may be worth it and others not.

Really evaluating 500,000 separate rules would take a large staff multiple lifetimes, so you still have to decide whether the bureaucracy as a whole is doing net good or net harm in order to determine whether it should be suspended for the years it will take to evaluate all the rules.

But by the time you finish the evaluation, years have passed since you started and the facts on the ground may have changed, or new rules proposed, so the evaluations are stale before they're completed and you have to start over.

It leaves you with only the systemic question of whether large bureaucracies are a net positive force as an institution. The answer could reasonably be no.

But notice that the answer is also related to the size. Because if the bureaucracy is smaller, you can finish the evaluation sooner, possibly soon enough that the evaluation results are still relevant by the time you finish. Having fewer rules allows you to have better rules, because the fewer you have the more time and other resources you have to make sure each is doing more good than harm.

> There's no way to criticize any bureaucracy without having a subtext that less bureaucracy is always better, if the mere implication that less bureaucracy would have prevented the problem is enough to conjure that subtext in the minds of the readers.

I would agree it is impossible to prevent all potential misunderstanding when writing for a large audience, but various methods can make this kind of misunderstanding less likely:

- Emphasize qualifiers like "some", "most", "often", "sometimes", "not all", "many", etc.

- Anticipate and explicitly disclaim possible misinterpretations

- Acknowledge valid counter arguments

- Be very precise and explicit about our intended mentioning

As opposed to corporate bureaucracies? If you think the free market magically makes everything efficient and free of politics and bureaucracy, try spending some time in a big company.

Remember this folks when voting for people who advocate for privatizing or de-regulating industries.

> As opposed to corporate bureaucracies?

Corporate bureaucracies can absolutely be just as terrible. But the problem isn't that a bureaucracy exists, it's that there is a law requiring the approval of a specific bureaucracy.

If a corporate bureaucracy is slow and inefficient, that sucks, but it creates an opportunity for somebody else to be less slow and less inefficient. If a government bureaucracy is slow and inefficient, can you start your own and go into competition with them?

Employee counts:

- Google: 100,000

- Procter and Gamble: 100,000

- GlaxoSmithKline: 100,000

(Weird how the figures for the first three random companies I looked up are so close...)

- Health and Human Services: 80,000

- Uber: 20,000

- FDA: 15,000

- Sanofi Pasteur (working on coronavirus vaccine): 15,000

- CDC: 10,000

You think corporate bureaucracies are bad now? What until they’re a legally protected monopoly.
That's a non sequitur. If they are only concerned with self preservation, you would expect them to bend more rules to keep away bad press
Yes, if only there wasn't a CDC around to help develop the tests in the first place. /s

The good comes with the bad. There is a lot of nuance that such blanket statements generally don't capture.

They also tend to lose function when they are gutted by politicians.