When the Food and Drug Administration published a new set of proposed regulations in the Federal Register recently, it included the usual notice that interested parties could inspect the files at the FDA's headquarters.
But the Federal Register notice didn't mention the catch.
Even Joseph Heller, who wrote Catch 22, would be proud of this one, for the catch is that to use FDA's public document room you need a reservation.
Not a reservation to get into the room, but a reservation for the parking lot - the visitors parking lot at FDA headquarters in Rockville.
"Parking by Reservation Only," the sign says, and there are no exceptions. Don't ask the guard at the gate, he'll tell you there might be a place only five or six blocks away.
And don't ask FDA officials to explain how the public interest, convenience and necessity is served by requiring reservations at the visitor's parking lot. They'll tell you they don't run the lot, GSA does.
FDA officials are irate enough at GSA for sticking their offices in the Parklawn Building in Rockville that they aren't about to take the blame for the parking lot boondoggle.
But the FDA has made its own contribution to regulatory wretched excess. At the FDA, three copies of a form are required to get one copy of a document.
For even a single page from the copying machine, clerks in the office of FDA's public hearing clerk dutifully fill out, in triplicate, an official Department of Health, Education and Welfare document, in white, yellow and green carbonless paper.
If the mechanics of the FDA's public particippation program are mind boggling, consider the regulations the public is supposed to help write - like the federal standards for the condoms, tampons and what are politely called "genital vibrators."
The public outcry for protection in this sensative area is so great that the comment file on condoms contains but one letter, and it's not suitable for publication in a family newspaper.
The only people concerned about DA's proposal to set federal standards for menstrual products are the folks who make Kotex and Tampax. If nobody cares, why is the federal government setting standards?
"Because Congress ordered us to," answers the FDA. "But it's not a high priority," insists an agency spokesman, who estimated it may be 10 years before the agency gets around to writing federal "performance standards" for vibrators.
Maybe by that time you'll be able to get into the FDA's visitor parking lot without a reservation.
When Rep. John Dingell (D. Mich.) waved around a preliminary General Accounting Office report on automobile airbags at a recent rules committee meeting to support his call for easing planned regulations in that area, several congressional eyebrows were raised.
Despite the fact that GAO drafts are generally circulated to appropriate committees for comment before public release, Hill sources say they were "shocked" by the fact that the GAO would hand out a preliminary copy of a report to a congressman so he could use it as a lobbying tool in a rules committee session.
The chief criticism was that the report was released before the Department of Transportation comments on it were even returned to the GAO. Those comments obtained by the Washington Post raise serious questions about the findings of the study, and lend even more credence to the possibility that there were political motivations in the preliminary release of the report draft.
The GAO, for its part, said it released the draft to Dingell because he said he wanted to use it "internally," and because it frequently releases preliminary reports for criticism from the interested members of Congress.
But this report, which was instigated not by Congress but by the GAO itself, was used for political purpose, Hill government operations officals said.
"Just by releasing the preliminary report, the GAO gives weight to its preliminary findings," said one source, "even if they are wrong. No one has had the chance to refute them."