Alice, Humpty Dumpty, and the New Administration


As children, we are taught that “sticks and stones will break my bones, but words will never hurt me.” That may have helped children develop resilience against verbal bullying, but it totally discounted the power of words. As adults, we know better. Words matter! 

Notably, words have the ability to control as well as inform. 

“When I use a word,’ Humpty Dumpty said in rather a scornful tone, ‘it means just what I choose it to mean — neither more nor less.’

’The question is,’ said Alice, ‘whether you can make words mean so many different things.’

’The question is,’ said Humpty Dumpty, ‘which is to be master — that’s all.”

― Lewis Carroll, Through the Looking Glass

Each political party uses terms and slogans to advance their causes. In doing so, they often use words that imply a clearer definition and greater certainty than the situation, facts, and proof points justify

The new administration is fond of: radical transparency, gold standard science, and ultra-processed foods. But what is meant by these catchphrases may not always be clear.

Radical Transparency. The conclusions and the reasoning behind government decisions should be readily available and easy to understand. They should provide tangible evidence that public opinion was sought, received, and considered. 

At least four federal laws are involved: the Administrative Procedures Act,[1] the Federal Advisory Committee Act[2], the Freedom of Information Act[3], and the National Archives and Records Administration statutes[4]. In the face of these four laws, it is fair to wonder what differentiates “radical transparency” from “transparency?” 

Despite the catchy phrase, the new Administration has shown little interest in transparency as traditionally defined and manifested in existing laws. 

As Dr. Jeremy Faust has observed: visibility—widely-distributed fiat announcement of government policy—is different from transparency about and public inclusion in the government decisionmaking process.[5]

Perhaps “radical visibility” should replace “radical transparency?”

Gold standard science. In my nearly 20 years as an advocate for FDA resources, I made hundreds of references to FDA being “the global gold standard for regulation of food and medical products” because of its reliance on science-based decisionmaking. Recently, FDA Commissioner Marty Makary and CBER Director Vincent Prasad made this their center-piece, describing “the two guiding principles of our philosophy—gold-standard science and common sense.”[6]

In a recent executive order[7], gold standard science was defined, enumerating nine characteristics. 

What seems missing from the administration’s definition of “gold standard science” is an appreciation of the complexity and ambiguity of scientific results. Often, science is (or needs to be) actionable, even if it is not absolute or immutable.

There is, necessarily, a strong situational relativity when you factor in the difficulty, cost, and timeliness of achieving complete certainty. As a result, sometimes gold standard science has to be “what we knew at the time, exercising best judgment, and having surveyed all relevant evidence.”  

Over time, new data may refine or refute previously held interpretations of previous studies. Mis-directions from the past are not necessarily blameworthy. They may simply reflect how scientific knowledge evolves. 

Ultra-Processed Food. A key plank of the MAHA (Make America Healthy Again) initiative is to build federal and state policies that result in the elimination of ultra-processed foods (UPF) from the American diet. This term was already in use and gaining momentum before the new administration made it a central tenet of government food policy. 

Before UPF becomes a legal standard by which foods are judged to be good/healthy or bad/unhealthy, there needs to be some honesty about how ill-defined the term is.

Is UPF defined by the number of ingredients? By the presence or absence of certain ingredients? By certain processing steps (and which ones)? What, if any, is the level of proof needed to establish a food as “good” or “bad?” 

Something more specific and scientifically-sound is needed...if Congress is to pass a law, FDA and USDA are to promulgate regulations, or government officials are to threaten industry with withdrawal of foods, ingredients, additives, and processes in common usage today. Consumers, too, ought to have the benefit of clarity when government eliminates and/or demonizes certain foods, ingredients, or processes. 

I am not alone in such concerns. Marion Nestle, the doyenne of nutritional food policy, recently offered the following comment about proposed California legislation that would ban UPF’s from the state’s school lunch program:  “I hope it passes, not least because I can’t wait to find out how its authors think the state will go about identifying the specific foods blocked from schools.”[8]

English is enriched every day by new words and new meanings. As the exchange between Humpty Dumpty and Alice illustrates, we are often the initiators of those changes. When that occurs, we should endeavor to be crystal clear about what we mean. 


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