Sunday, July 12, 2020
By:
Over the last couple weeks, I've gone on a unit tangent and now here's a citation tangent. Aside from the tangent part, this is a beautiful example of me using some of the policy knowledge I've gained over the course of the summer.
A few weeks ago, I watched a briefing on the international pharmaceutical supply chain. The gist I got out of it was that there is a tendency for people to advocate for protectionist pharmaceutical trade policies, especially in a COVID-19 world. That, of course, is not inherently bad, but in advocating for these positions, people would often use unsettled statistics to support their position. Even that isn't terrible, people have legitimate gripes about statistics and variables and context all the time. These contests are a vital part of the pursuit of knowledge after all BUT, if you're going to use statistics that are widely disputed or easily disputed, you really ought to share your sources for them.
To make a long story short, I received my weekly newsletter from a government official that made statistical assertions without citing their sources. In response, I wrote a lengthy letter to said official sharing my own research into the matter and my concerns about the lack of sources provided. Here's what it said:
Hello.
This afternoon (7/12/2020), I received your weekly newsletter/update that included several statistics regarding the U.S. pharmaceutical supply chain. Two assertions gave me pause: "...90% of the prescription medications that Americans take are made in China..." and "...a recent U.S. Department of Commerce study found that 97% of all our antibiotics come from China." These statistics, if true, are troubling, of course, but I wonder where these statistics were found as no sources are provided in your email.
Upon further research, I found that:
"The Food and Drug Administration (FDA) is responsible for overseeing the safety and effectiveness of all drugs marketed in the United States. However, FDA's oversight of the nation's drug supply chain has become increasingly complicated because many drugs used in the U.S. are manufactured overseas. FDA estimates that nearly 40 percent of finished drugs and approximately 80 percent of active pharmaceutical ingredients are manufactured in registered establishments in more than 150 countries." (Source: https://oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000380.asp).
Even these estimates from the FDA are somewhat ambiguous and open to error given the highly complex nature of the global pharmaceutical supply chain. In her prepared statement for the House Energy and Commerce Committee's Subcommittee on Health from October 2019, Janet Woodcock, Director of the Center for Drug Evaluation and Research at the FDA, wrote:
"The number of Chinese facilities producing [active pharmaceutical ingredients (APIs)] for the U.S. market has increased over the past decade, as part of a massive movement of pharmaceutical production offshore. This movement is being driven by the pharmaceutical industry’s desire for cost savings and less stringent environmental regulations. Absent any intervention, FDA believes that this trend is likely to continue.
However, data available to FDA do not enable us to calculate the volume of APIs being used for U.S.-marketed drugs from China or India, and what percentage of U.S. drug consumption this represents. As mentioned above, we do not know whether Chinese facilities are actually producing APIs, how much they are producing, or where the APIs they are producing are being distributed worldwide, including in the United States." (Source: https://energycommerce.house.gov/sites/democrats.energycommerce.house.gov/files/documents/Testimony-Woodcock-API_103019.pdf)
With a statement like that coming from FDA personnel, I can't help but wonder how and who found that 90% of the prescription medications that Americans take are made in China as your newsletter asserts.
The antibiotic statistic presented in the email references a U.S. Department of Commerce study that is uncited as well. While searching for this Commerce Department report, I found that many references in the media to this statistic trackback to a blog post on the Council on Foreign Relations website (https://www.cfr.org/blog/us-dependence-pharmaceutical-products-china). This post references a Bob Woodward book without directly citing the Commerce study either. The blog post says:
"[T]he U.S.-China Economic and Security Review Commission held a hearing on the United States’ growing reliance on China's pharmaceutical products. The topic reminded me of a spirited discussion described in Bob Woodward’s book, Fear: Trump in the White House. In the discussion, Gary Cohn, then chief economic advisor to President Trump, argued against a trade war with China by invoking a Department of Commerce study that found that 97 percent of all antibiotics in the United States came from China."
With that being said, I was wondering if your office had access to or more information on the original Department of Commerce study being referenced in your newsletter.
There is most definitely an argument that can be had about over-reliance on Chinese manufacturing, but I do wonder if these are the statistics we ought to be using in that debate unless they can be supported by empirical research. At the very least, when factual claims such as those mentioned above are stated, it's vital that we're as transparent as possible about their origins, making reference to the source material with citations or links whenever possible. This is particularly important in the age of misinformation, as citizens appear to be becoming increasingly skeptical of American governmental and non-governmental institutions.
If you had the source material for the statistics referenced in your newsletter, I would appreciate you sending them my way. Global supply chains are incredibly complex, but that makes them inherently interesting in my eyes. If the positions I've taken in this correspondence are factually wrong or open to contest, I want to know so that I can improve my own understanding of the field.
Thank you for your time and attention.
Stay well,
Kyle
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This isn’t a gotcha moment or anything like that. As a scientist, I know how easy it is to lose the trust of an audience when your words are misleading or false. We see this happening with news organizations, science organizations, and institutions all across America. It’s vital that we do our best to be honest and transparent with the communities that we serve, so that we can hopefully reverse that narrative. Only time will tell though.
Stay well,
Kyle Blasinsky