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  5. 811 F.2d 1583 (1987)
 

UPJOHN CO. v. FOOD AND DRUG ADMIN.

Nos. 86-1204, 86-1245.

811 F.2d 1583 (1987)

The UPJOHN COMPANY, Petitioner, v. FOOD AND DRUG ADMINISTRATION, Respondent. HESS & CLARK, INC., Petitioner, v. FOOD AND DRUG ADMINISTRATION, Respondent.

United States Court of Appeals, District of Columbia Circuit.

Decided February 24, 1987.

As Amended March 5, 1987.

Attorney(s) appearing for the Case

Eugene I. Lambert, with whom Richard F. Kingham, Ellen J. Flannery, James R. Stirn and Bruce N. Kuhlik, Washington, D.C., were on the brief, for petitioners.

Gerald C. Kell, Atty., Dept. of Justice, with whom Richard K. Willard, Asst. Atty. Gen., Margaret A. Cotter, Asst. Director, Office of Consumer Litigation, Dept. of Justice, Washington, D.C., Thomas Scarlett, Chief Counsel, Rockville, Md., and Michael M. Landa, Associate Chief Counsel for Enforcement, Food and Drug Admin., were on the brief, for respondent.

Before RUTH BADER GINSBURG, WILLIAMS and DOUGLAS GINSBURG, Circuit Judges.

Opinion for the Court filed by Circuit Judge WILLIAMS.

WILLIAMS, Circuit Judge:

In these two cases drug manufacturers challenge the Food and Drug Administration's power to revoke certain waivers without first providing an opportunity for an adjudicatory hearing. We find these claims without merit.

Under the Federal Food, Drug, and Cosmetic Act (the "Act"), 21 U.S.C. §§ 301-378 (1982 and Supp. III 1985), the FDA subjects

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