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25 Op. O.L.C. 220: Disclosure of Conflicts of Interest of Members of FDA Advisory Panels

October 5, 2001

Special government employees who serve as members of a Food and Drug Administration advisory panel and who seek waivers of conflicts of interest must publicly disclose any conflicts of interest they may have that relates to the work to be undertaken by the panel. The FDA may not waive a panel member’s conflict until the panel member makes the public disclosure. The FDA has considerable discretion to determine how detailed the panel member’s disclosure must be, so long as such disclosure is adequate to inform the public of the nature and magnitude of the conflict.

https://www.justice.gov/d9/olc/opinions/2001/10/31/op-olc-v025-p0220_0.pdf