Rep. John D. Dingell (D-Mich.) likes to write letters. In his role as chairman of the House Energy and Commerce subcom- mittee on oversight and investigations and dean of political belles-lettres, he writes what his staff estimates as hundreds or even thousands of them every year. He has written to Bernadine P. Healy at the National Institutes of Health dozens of times since she was appointed director, chastising, rebuking, requesting mounds of documents and rounding up staff members for hearings. He writes to William K. Reilly at the Environmental Protection Agency, and to colonels and generals up and down the Pentagon. David A. Kessler is his favorite correspondent. Since the beginning of 1991, he has written Kessler 175 times. At the agency, they call them Dingellgrams.

1. IN RE: If Kessler is one of Dingell's favorite pen pals, then the agency's Center for Devices and Radiological Health is one of his favorite topics. He wrote to Kessler complaining about the way the division operates on Feb. 3, then again on Feb. 12, March 11, April 1, April 7, twice on April 15, April 21, twice on April 22, five times in May and on and on through this summer. In all, Dingell has written 44 letters to Kessler on the subject of medical devices since the year began.

2. CASUS BELLI: This is not a letter like the others, however. In fact, in the week since it was first sent from Capitol Hill to FDA headquarters in Rockville, it has become something of a sensation. The Health Industry Manufacturers Association (HIMA) has faxed it around town with barely disguised glee. FDA officials are up in arms over the letter, calling it the most outrageous, the most egregious, the biggest example of Dingell chutzpah ever.

Why the fuss? In virtually every other letter sent to Kessler, Dingell has complained about the incompetence of the FDA's device center staff -- how, for instance, they were too chummy with industry types and too easy and unscientific in their application reviews. Now, FDA officials complain that Dingell's complaints are of the opposite vein: approvals are "nonexistent," the process is "paralyzed," industry is angry and frustrated.

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"We thought we were on the same wave-length with Dingell and then all of a sudden this comes along," said one senior agency official.

3. IN LOCO INDUSTRIS: Dingell's staff, it seems, spent four days meeting with medical device manufacturers in August and came back shocked by the "confusion, fear and frustration" they found there. The agency, he reports, has stopped approving new products and become hostile to the companies whose products "offer the only real hope for people in need of lifesaving devices."

This Dingell appears to be a different Dingell from the one who scolded senior FDA officials at a hearing of the oversight subcommittee in June. There, Dingell aide Thomas Dorney complained about the "high approval rate" for new device applications at the FDA and about how the Office of Device Evaluation at FDA was referred to inside the agency as the "Office of Device Approval."

The FDA, he said, "lacked scientific independence," and was too close to the industry. FDA staff members, he said, felt that the devices division had a "basic philosophy of facilitating approvals; taking a non-adversarial stance on virtually any question, or worse . . . constantly supporting the manufacturers."

"If you sat through that hearing, you'd think you were dealing with a completely corrupt, nonscientific process that ought to come to a halt," said one FDA staff member. So in response, they said, they went back and started to dismantle the system that Dingell told them wasn't any good. And now this.

"We're trying to improve the quality of the science and we are trying to improve the quality of our reviews," said Kessler, in an unusually tart response to Dingell's letter. "We can't do that and speed up at the same time."

4. SPINNIBUS DINGELLIS: All of this is not, Dingell hastens to point out here, simply a brief for the industry. According to his spin, he has the public's and the government's best interests in mind. And to even suggest that the latest Dingellgram is anything but a high-minded attempt to right the wrongs at FDA draws outrage from the subcommittee.

"For them to be whining, ticks me off," said a Dingell staff member. Speeding up and reforming at the same time is possible, he contended. The two things are "two {sides} of the same coin. It's all a matter of being properly organized."

The letter, he said, has to be understood in its full context and appreciated for all of its nuance.

"It's not like pro-industry or pro-FDA," the subcommittee staff member said. "It's more subtle than that."

5. ERGO PARALYSIS: The unkindest cut. At the end of the letter, Dingell complains about the "anarchy" at the medical devices branch, caused by the presence of two reorganization teams and at least three internal investigative groups.

"Reviewers and others likened the situation to working under a microscope without knowing what is expected," he wrote.

He does not mention that one of the other investigative groups putting the devices center under a microscope has been his own oversight and investigations subcommittee, whose staff has been out at FDA all summer conducting interviews. Not to mention the Dingellgrams.

Is this another example of government paralysis? At the beginning of the summer, FDA officials estimated that just to respond to Dingell letters took up 1,500 hours of work and required the gathering and copying of 120,000 pages of documents. That was on June 18. Since then, there have been another 13 letters, requesting thousands more documents.

"You call over there, and they're always busy supervising the copying of documents to Dingell or responding to Dingell," said one FDA official. "They're exhausted. They're frustrated. They don't want to talk because they're tired of responding to requests."

Pressed on the point, Dingell staff members conceded that they are not entirely blameless. They are problem finders, they said, and problem finders naturally cause disruption. But again, theirs is a complex and nuanced position.

"We have been the catalyst for the paralysis," said a staff member, "but not the cause."