Black & Baldwin, LSE · 2010Two leading regulation scholars set out the built-in limits of risk-based regulation: it can miss cumulative, systemic and newly emerging risks, and depends on the regulator's ability to detect risk.
Why it matters: A theoretical lens. The paper is about regulating firms; applying it to hard-to-measure harms such as psychological harm is our interpretation, not evidence of harm.
BMJ (Greenhalgh & McKee) · Mar 2025Reviewed UK research on physician and anaesthetic associates published from 2015 to January 2025. Of 29 studies meeting its inclusion standard, none examined safety incidents and only one directly observed clinical competence.
Why it matters: In our view, a clear statement of the evidence gap: the authors warn that absence of evidence of safety incidents is not evidence that the roles are safe. Co-author Martin McKee was BMA president in 2022-23.
GOV.UK · 16 Jul 2025An independent review found the evidence on the roles weak and based on observational data. It made 18 recommendations, including renaming the roles 'physician assistant' and 'physician assistant in anaesthesia', and requiring a named supervising doctor for each physician assistant. The government accepted all of them.
Why it matters: In our view, a template for how a government re-tightens a role after scaling it ahead of the evidence.
Professional Standards Authority · 7 Oct 2025The current version of the framework. It keeps the six principles and eight elements, sets out a broad definition of harm (including psychological harm, financial loss and damage to trust), accepts that deregulation can be warranted where risk is well managed, and aligns with the UK's 'Smarter regulation' agenda.
Why it matters: The primary source. Worth quoting directly, including its own warnings about false assurance, and that regulation should only be called 'risk-based' where risks have actually been quantified and qualified.
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