Submission Number: 00014
Received: 3/25/2011 1:15:35 PM
Commenter: Dawn Kepler
Agency: Federal Trade Commission
Initiative: Alcohol Reports: Project No. P114503
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A 2010 study published in the American Journal of Public Health found that "Ad placements for beer, spirits, and alcopops increased as adolescent viewership rose from 0% to 30%, especially for female viewers. Alcohol advertising practices should be modified to limit exposure of underage viewers" (http://ajph.aphapublications.org/cgi/content/abstract/100/3/555). These findings are particularly troubling when the impact of alcohol advertising on adolescent alcohol use is examined. A 2009 systematic review published in Alcohol & Alcoholism revealed the following findings: "Based on the strength of this association, the consistency of findings across numerous observational studies, temporality of exposure and drinking behaviours observed, dose-response relationships, as well as the theoretical plausibility regarding the impact of media exposure and commercial communications, we conclude that alcohol advertising and promotion increases the likelihood that adolescents will start to use alcohol, and to drink more if they are already using alcohol" (http://alcalc.oxfordjournals.org/content/44/3/229.full.pdf). These findings have been substantiated in other studies, as well (please see attachments).
Based on the research showing the negative impact alcohol advertising is having on our youth under the current system of self-regulation, I ask that you please heed the health and wellness of our nation’s adolescents when making a decision in regard to alcohol advertising regulation. The most recent analysis of the cost of underage drinking to the US is $60.8 billion/year (http://www.udetc.org/UnderageDrinkingCosts.asp). With all of this in mind, I beseech you to implement the following recommendations (based on the Marin Institute’s Review of Advertising Self-Regulation):
1. A truly independent, third-party review body that includes public interest representatives.
2. Objective standards for judging the content of advertisements.
3. Lowering of the current 30 percent placement standard to 15 percent, so that ads may only be placed in media where no more than 15 percent of the audience is under the legal drinking age.
4. Enforcement power and significant penalties beyond requests to pull ads, enforceable by federal law or binding industry agreement.