I think you have an interesting idea regarding consumer advocate organizations. One thing I’d be worried about with a model like this is the lack of a required approval process. Although the FDA isn’t doing it’s job well enough, I think it’s a good practice to have an approval process that requires research to support the safety of a new product. Of course, it would be much better for the research to be independent and unbiased which often isn’t the case today. I don’t know if private organizations could possibly have the authority to require such an approval process, and without it, we’d all be test subjects until a new product has been in circulation long enough for its effects to be known.

One thing I especially agree with is that the FDA, or any agency, organization, or industry that would hypothetically take its place, needs to be much more accountable for their actions.

There are a few practical problems with the notion of the FDA as well:

1) It creates a moral hazard where people think that anything FDA approved must be safe and therefore they aren’t as cautious about putting things into their body as they ought to be.

2) It leaves an unelected government bureaucracy as the first and only word on the safety of food and medicine which makes it unaccountable to the people.

If the FDA didn’t exist, what would happen? I’m willing to bet that there would be numerous consumer advocacy organizations that would step up to the plate, and just like everything should be in a free society we would have a choice of many sources of information and be free to decide what we believe is safe and healthy and what is not. The FDA doesn’t strictly regulate nutritional supplements but there is an organization called consumerlab that takes products and tests them for purity, lead contamination, etc. and for a fee you can access the results through their website. I think there would be a lot more such organizations if people didn’t have the misconception that the FDA was looking out for them.

If there were a thriving industry of consumer watchdog groups that replaced the FDA what would happen if one of them screwed up? Obviously they would lose public confidence and would risk going out of business. What happens when the FDA screws up? The politicians try to sweep it under the rug as quickly and quietly as possible so as to avoid political ramifications but nothing changes, and there is no recourse. Anyone who thinks we would be less safe under a regulatory system driven by the free markets rather than government intervention should give this some serious thought.

What’s really amazing is seeing the extreme arrogance of some doctors and scientists who criticize the value of natural remedies while at the same time peddling concentrated forms of natural remedies that do a lot to upset the delicate chemical balance inside the human body. I believe that doctors would be less gung-ho about handing out these unnatural pills if they didn’t have political cover from the FDA. As long as they “follow the guidelines” they don’t have to worry about whether their actions destroy the lives of their patients. In fact they don’t even really have to worry that much about their patients at all since the patients usually aren’t the ones paying the bills, but that’s a different topic.