Our Antigens, Our Selves – Marginal REVOLUTION


In 2013 in the past I wrote, Our DNA, Our Selves, arguing towards the FDA’s crackdown on genetic readouts from corporations like 23andMe. The FDA, nonetheless, proved succesful in its crackdown and that’s the reason speedy at-home antigen exams aren’t obtainable in the present day and why tens of hundreds of persons are dying from COVID unnecessarily. Laws have unintended penalties.

Let’s recap:

Take into account, I swab the within of my cheek and ship the pattern to a agency. The concept the FDA can rule on what the agency can and can’t inform me about my very own genes is absurd–it’s no completely different than the FDA making an attempt to manage what my physician can inform me after a bodily examination or what my optometrist can inform me after a watch examination (Please learn the primary line. “G T A C C A…”).

The concept the FDA can regulate and management what people might find out about their very own our bodies is deeply offensive and, for my part, plainly unconstitutional.

Let me be clear, I’m not offended by all regulation of genetic exams. Certainly, genetic exams are already regulated. To be exact, the labs that carry out genetic exams are regulated by the Clinical Laboratory Improvement Amendments (CLIA) as overseen by the CMS (right here is an excellent primer). The CLIA requires all labs, together with the labs utilized by 23andMe, to be inspected for high quality management, report holding and the {qualifications} of their personnel. The purpose is to make sure that the exams are correct, dependable, well timed, confidential and never dangerous to sufferers. I’m not offended when the purpose of regulation is to assist shoppers purchase the product that they’ve contracted to purchase.

What the FDA needs to do is categorically completely different. The FDA needs to manage genetic exams as a high-risk medical gadget that can’t be offered till and except the FDA permits it’s offered.

Furthermore, the FDA needs to guage not the analytic validity of the exams, whether or not the exams precisely learn the genetic code because the corporations promise (already regulated underneath the CLIA) however the medical validity, whether or not specific recognized alleles are causal for situations or illness. The latter requirement is the death-knell for the merchandise due to the expense and time it takes to show particular genes are causal for ailments. Furthermore, it implies that corporations like 23andMe won’t be able to inform shoppers about their very own DNA however as an alternative will solely be allowed to supply a peek on the sections of code that the FDA has deemed it okay for shoppers to see.

Ten years later we now want speedy antigen exams however the subject, as Michael Mina factors out in an excellent interview with Malcolm Gladwell, is that now we have medicalized all exams and readouts. As an alternative of eager about the person as having a proper to find out about their very own physique, we handled each take a look at or readout as if the one consumer have been a doctor. Thus, as an alternative of eager about the worth of those exams for people and for public well being, the FDA didn’t approve speedy antigen exams as a result of it regarded them as inferior to PCR exams, for a doctor diagnosing illness.

Right here’s Mina (roughly transcribed and evenly edited)

The one pathway that now we have to judge exams like this are medical diagnostic pathways, pathways designed particularly to make sure that a doctor like a detective is getting all the data they should diagnose a sick individual… Now we have so devalued and defunded public well being…that we don’t have a regulatory pathway to approve a take a look at whose main goal is stopping an epidemic versus diagnosing a sick individual. And that has held the whole lot up. All the businesses that may very well be producing these speedy exams within the tens of millions and tens of millions, they’ve been sitting on these exams making an attempt to hone them to allow them to move FDA requirements as a medical diagnostic.

It’s not simply slowing down their approval it’s truly bottle necking the businesses into creating exams that aren’t going to be as scalable as they’re having to make use of costlier reagents and packing the exams with devices to allow them to move FDA evaluate when in actuality they’re simply these little items of papers. If we are able to do a budget model they are often made very quick however the simply gained’t get by means of the FDA.

Gladwell: I discover your clarification unconvincing. How dumb is the FDA?…In case you make the precise argument you made to me…the FDA is just not going to see your logic?

It’s not that they aren’t good it’s that it is a regulatory physique, they simply don’t have a pathway. You may’t apply for approval for a public well being take a look at instrument…In our nation the medical institution is extraordinarily sturdy, you may’t go to get a ldl cholesterol take a look at with out getting a prescription out of your physician. Why can’t we all know that? It’s all by means of this very heavy medical lens and altering that, getting that large ship to show is popping out to be a really, very troublesome activity however resulting in doubtlessly tens or tons of or hundreds of deaths that don’t must be taking place.


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