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Btw, one reason this approval went fast is because Roche has good reputation given body of work.

This suggests an alternate regulatory paradigm: clear the company, not every drug/device.

Similar to how CLIA works, where a lab is cleared and then can roll out new tests.
That clearance would need to be maintained, but it works for labs.

Normally, a CLIA lab director can roll out a new laboratory developed test without submitting it for “pre-market review”.

In this emergency, FDA CDRH gained ability to bottleneck this normally fast process.
One secret of regulatory review is that it’s not fully based on rule-of-law or even science.

A huge part of it is the *reputation* of applicant in regulator’s eyes, as well as regulator’s rep with public.

This book is “pro FDA” but discusses this thesis.
press.princeton.edu/books/paperbac…
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