🔴 Policy Without Science. Discipline Without Proof. On October 16, 2025, Harmed Americans for Reform in Medical-Device Safety Corp. (HARMS) — led by Dr. Hooman Noorchashm, Dr. Michael K. Paasche-Orlow, and Dr. David A. Simon — filed a Citizens Petition with the U.S. Food and Drug Administration (FDA). This petition was filed in response and opposition to the use of Enzyme Immunoassay (EIA) hair testing by the New York City Police Department (NYPD), using the case of former Police Officer Frankie F. Palaguachi as a real-world example of harm. Palaguachi was terminated on October 17, 2025, one day after the filing, based on results from the Psychemedics Corporation cannabinoid hair testing device (510(k) No. K111929) — a device that the FDA never classified for hair testing and which cannot scientifically distinguish marijuana use from passive exposure. 📌 Why It Matters: ⚠️ Regulatory Misclassification: The device was cleared for serum, plasma, saliva, and urine testing — not hair. 🧪 Scientific Unreliability: EIA hair testing cannot prove marijuana use, only the presence of metabolites. Passive exposure can trigger a positive result. 📜 Misleading Labeling: Psychemedics’ language implies the test can “identify use,” creating a false evidentiary narrative in employment and disciplinary cases. 🧑🏽⚖️ Harm in Practice: Palaguachi’s termination exemplifies how this flawed science can end careers and violate due process. The HARMS Petition calls on the FDA to: Mandate labeling changes clarifying the device’s true limitations. Issue public guidance to employers and law enforcement warning against misuse of hair testing. Disclose investigation data to ensure accountability and transparency. ⚖️ When unreliable science becomes the basis for discipline, due process is not protected — it’s erased. Read the Citizens Petition buff.ly/zRy42VE #NYPD #FrankiePalaguachi #Psychemedics #FDA #CivilRights #DueProcess #EmploymentLaw #ScienceAndLaw #UGESP #TitleVII #HairTesting #PolicyWithoutProof #Accountability #LawEnforcement #RegulatoryFailure #EricSandersEsq #TheSandersFirmPC