14. Department of Health and Human Services · Minor
Impose a lengthy cooling-off period on FDA reviewers
Printed page 460 14. Department of Health and Human Services
“The FDA should impose a lengthy cooling off period for reviewers, preventing them from working for companies they regulated.”
What has happened
- Not started
No cooling-off period was imposed on FDA reviewers. The post-employment restrictions applying to FDA staff are now the government-wide statutory ones in 18 U.S.C. 207 alone, the executive-branch ethics pledge having been revoked on 2025-01-20 and not replaced; nothing in the window lengthens them for drug reviewers. Full-text Federal Register search for "post-employment restriction" since 2025-01-20 returns 0 documents, and the three cooling-off bills in the 119th Congress (H.R. 510, H.R. 3554 / S. 1850, H.R. 3582) are about regulators generally, financial regulators and Foreign Military Sales, and all sit in committee.
No action found yet. This entry is the starting point, not a finding.
- Not started
The record moved nearby, and away from the ask. Executive Order 14148, section 2(e), revoked Executive Order 13989 (Ethics Commitments by Executive Branch Personnel) on day one, and no replacement pledge has been issued since. EO 13989 was the only extra-statutory cooling-off instrument reaching FDA personnel: its revolving-door limbs bound appointees leaving government to a two-year restriction on communicating back with their former agency, and senior appointees to a lobbying ban running past the end of the administration. It is adjacent rather than contrary because it never reached the people this Quote names — the pledge bound "every appointee in every executive agency", not the career staff who review applications — so its revocation lengthened no reviewer's cooling-off period and shortened none either. What it does settle is that the only restrictions now applying to a departing FDA reviewer are the government-wide statutory ones in 18 U.S.C. 207.
Research log
What was searched, and what didn’t count as evidence
Research notes
- The companion 15-year ask at p. 452 is #1203.
- One search covered this ask together with the other asks on its pages.
- EO 13989’s operative text was read at govinfo.gov/content/pkg/FR-2021-01-25/html/2021-01762.htm to check its scope before attaching the revocation: section 1 binds “every appointee in every executive agency”, and paragraphs 4 to 6 of the pledge are the post-employment limbs. It is pre-window, so it is context and not Evidence; EO 14148, which revokes it inside the window, is the Evidence.
- No replacement ethics pledge was found: a search of the titles of the presidential documents in the Federal Register and the White House presidential actions we keep and search, for “ethic”, “pledge”, “post-employment” and “cooling” over the window, returns only an unrelated Ratepayer Protection Pledge proclamation (2026-03-04).
- Action
- restrict
- Object
- FDA reviewers' post-government employment
- ID
- 1241