especially so, as here, in the context of matters involving complex scientific issues. See Marsh v. Or. Natural Res. Council, 490 U.S. 360, 378, 109 S.Ct. 1851, 104 L.Ed.2d 377 (1989). Dr. Shuren’s Memorandum to the File contains argument that cannot reasonably be called arbitrary or capricious, which is the standard at issue here. He based his decision on a review of the relevant material, including an examination of both panels, meetings with the review team, and the overall record. (See AR 5461). He properly based his conclusion on the CS device’s proposed labeling. (See AR 5466-67, 5470-76). And while Ivy is correct that not every single person in the entire agency agreed with him, that is not the standard of review. See Serono Labs., Inc. v. Shalala, 158 F.3d 1313 (D.C.Cir.1998) (<HOLDING>). 2. The FDA Identified Technological
holding deference is owed to the decisionmaker authorized to speak on behalf of the agency not to each individual agency employee holding that deference to an agency interpretation is not appropriate where a statute is administered by more than one agency holding that agency interpretation which is reasonable is entitled to deference recognizing that courts accord significant deference to an agency decision where agency expertise is involved holding deference to agency methodology appropriate unless agency failed to address an essential factor