Michael R. Taylor is an American lawyer who has played leadership roles in the US Food and Drug Administration, agrochemical company Monsanto, and law firm King & Spalding. He currently co-chairs the board of STOP Foodborne Illness, a non-profit that supports victims of serious illness and their families in efforts to strengthen food safety culture and practices in government and industry.
Early career and law practice
Taylor received a B.A. degree in political science from Davidson College in 1971 and served on active duty in the US Army as an officer in the Military Police Corps from 1971 to 1973, stationed at the Presidio in San Francisco. He received a J.D. degree from the University of Virginia in 1976 and was employed as a staff attorney at the FDA from 1976 to 1980, where he worked on enforcement litigation, medical device regulations, food safety and food labeling. He served during 1980 as executive assistant to the FDA Commissioner Dr. Jere Goyan.
From 1981 to 1991 Taylor worked in private law practice at King & Spalding. He established and led the firm's food and drug practice and became the firm's first food and drug partner in 1984. During this period, Mr. Taylor wrote and spoke frequently on topics related to FDA and its regulatory programs, including risk management, the application of risk assessment to food safety decisions, federal preemption, drug approvals, color additive and medical device regulation, and the need to maintain FDA funding for consumer protection. In some of his early writings, Mr. Taylor addressed the Delaney Clause, a part of a 1958 federal law that prohibits any carcinogenic chemical from being added to food that is processed. In the 1970's and 80's, FDA scientists had developed scientific risk assessments on the basis of which they could conclude that, under certain circumstances, very low human exposure to chemicals found to cause cancer in animals nevertheless could be found safe under the "reasonable certainty of no harm" safety standard for food additives. Some commentators argued that FDA should interpret the Delaney Clause as allowing FDA to approve food additives based on a de minimis risk legal interpretation.
In 1981, Taylor argued in Legal Times of Washington that it was the role of Congress, not FDA, to decide if there should be a de minimis interpretation of the Delaney Clause. In 1986, after FDA had established a de minimis risk interpretation for color additives he made a presentation at the Brookings Institution, subsequently published, explaining the legal and policy rationale for FDA's interpretation and urging that FDA take a cautious, science-based approach to its implementation with protection of public health as its overriding concern. From 1986 to 1987, Taylor served on a National Academy of Sciences Committee that studied the application of the Delaney Clause in pesticide regulation and participated in a Keystone Center dialogue on pesticide regulation, which contributed to legislation that strengthened safety standards for residues of carcinogenic pesticides in food.
Government Service at FDA and USDA, 1991 - 1996
US Food and Drug Administration, 1991-1994
On July 17, 1991, Michael Taylor left King & Spalding to return to the FDA in the newly created post of Deputy Commissioner for Policy established by FDA Commissioner David A. Kessler. In this position, Taylor led FDA's new Office of Policy and, on behalf of the commissioner, oversaw development of policy and regulations in all FDA program areas, including food, drugs, and medical devices.