| Comment Number: | 516960-00047 |
| Received: | 6/9/2005 6:50:04 PM |
| Organization: | The American Dietetic Association |
| Commenter: | Mary Hager |
| State: | DC |
| Agency: | Federal Trade Commission |
| Rule: | Food Marketing to Kids Workshop |
| Docket ID: | To Be Added |
| Attachment: | 516960-00047.pdf Download Adobe Reader |
Comments:
The American Dietetic Association (ADA) commends the Federal Trade Commission for its leadership to host a public workshop to explore self-regulatory marketing initiatives in food and beverage industry that respond to concerns about childhood obesity. The ADA is the nation's largest organization of food and nutrition professionals in the United States, with nearly 67,000 members serving the public through the promotion of optimal nutrition, health and well being. ADA is renowned for its grounding in sound science, particularly in the areas of human nutrition and food safety, and for its expertise in translating science on nutrition, disease states and health into information that consumers can understand and apply to self-directed goals to improve their nutritional health. ADA concurs with the IOM report titled “Preventing Childhood Obesity: Health in the Balance.” which states that: Obesity prevention requires an evidence-based public health approach to ensure that recommended strategies and actions will have their intended ffects....Because the obesity epidemic is a serious public health problem calling for immediate reductions in obesity prevalence and in its health and social consequences, the committee believed strongly that actions should be based on the best available evidence---as opposed to waiting for the best possible evidence. However, there is an obligation to accumulate appropriate evidence not only to justify a course of action, but also to assess whether it has made a difference. Therefore evaluation should be a critical component of any implemented intervention or change. ADA concurs with the Children’s Advertising Review Unit’s Self-Regulatory Guidelines for Children’s Advertising and that the FTC should monitor compliance with those guidelines as well. Such advertising must be truthful and not misleading. Nutrition messages need to be developmentally appropriate with specific behavioral messages to help children make informed food choices. However, the scientific data demonstrate that few American children achieve the Dietary Guidelines for Americans and associated food guidance systems and that multiple factors related to today’s social, cultural, and physical environments play a role in food choices made by children and parents alike. It is this complexity that warrants caution in policy development. Several groups, with the best of intentions, have offered what appear on the surface to be logical, straightforward, obvious, and simple solutions to this complex problem. Yet, implementation of these solutions as policy may result in unintended consequences. Simple solutions to complex problems are generally wrong. This month’s issue of Amber Waves published by the Economic Research Service of the Department of Agriculture articulates this quite well. Do we have the evidence that restricting the advertising of certain foods really make a difference in the foods consumed at home? Or, will programs aimed at parents that educate, support and work with them on a face-to-face level make a greater impact? A study sponsored by the NHLBI and published by Dr. Linda Van Horn, a registered dietitian and her co-authors in this month’s issue of Pediatrics reports that children can make healthier food choices with the involvement of parents and access to healthy foods. This study, part of the Dietary Intervention Study in Children did not specifically assess snacking during television viewing, but the data did document a substantial intake of empty-calorie foods. Plus, sedentary behavior was high among the study participants. Yet the role of the family was significant in changing food habits, a strategy shown to be effective in reducing smoking rates of children and teens. Therefore, ADA urges the FTC to undertake research that tests the effectiveness of proposed changes in marketing policy. Good policy should be evidence-based. See attached for additional detail. Thank you.