The Paperwork Reduction Act: A Fine Alternative to Hysteria
It's watchdog versus watchdog in the hyperventilating sweepstakes over soda pop labels. In this corner, we have the Center for Science in the Public Interest (CSPI) filing a petition with the FDA to require that non-diet soda containers display "a series of rotating health notices..." In the other corner, we have the Center For Consumer Freedom (CFCF) salivating at the mere thought of taking a swing at such an easy target. May the best PR campaign win.

From Winston's point of view, the CSPI – CFCF bout looks less like a steel cage death match between two adversaries than a symbiotic relationship with each watchdog feeding off the other in their endless quest for money and publicity. In fact, given the breathless apocalyptic claims from each camp, it's hard to tell the two apart.

Fortunately for FDA, and the public, there is an alternative to making a decision on the CSPI petition based on escalating hyperbole; the agency adhering to the criteria and procedures set forth in the Paperwork Reduction Act (PRA). The PRA governs federally-mandated disclosures of information to the public, including proposed labeling requirements.

Under the PRA, the agency and OMB need to ensure that the proposed labeling requirement meets a series of standards such as that the label "is necessary for the proper performance of the functions of the agency, including that the information has practical utility..." Any proposed label would also need to comply with the requirements the Data Quality Act (DQA).

Yes, it is a dog-eat-dog world. Which is why Winston prefers the cool, calm dictates of the PRA and the DQA to the latest tales told by watchdogs, full of sound and fury. Signifying nothing.