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The primary focus of my topic is three fold first if a high ranking official from a firm were to become the Director of an agency and his former company is asking for approval of a drug how should the Director act in regard to this rulemaking The second question is not a difficult if a former Director were to assume a position at a firm asking for approval of a drug how should the former directors position influence the decisions of the agency Finally how could government regulation limit the potential conflicts of interest from the Revolving Door The first scenario answer is both ethics and law based It would be unethical for the Director to have any influence what so ever in this circumstance Realistically the Director would have probably at least an influence to the degree that those who work for him would at least try and guess his desire for the outcome at worst he would directly or indirectly tell them Probably at this point no procedural rules have been breached This is of course only if the director has not tried to influence the Administrative Law Judge in which case many legal issues could be raised more on that in question three Back to the ethics involved it would be very important if the Director were to try and be ethical about the issue heshe should give the appearance of ethical procedure One way this could be done is that a recommendation could be made rulemaking be in a formal format In addition shehe should be very careful to limit ex parte contacts between himself and his former business associates Under no circumstance should the Director have conversation of any nature involving this case Under the circumstance that the drug was or was not approved the case could go before Judicial review there any appearance of unethical behavior could not only be be evidence to support a
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