| Comment Number: | 529477-00006 |
| Received: | 5/17/2007 4:38:48 PM |
| Organization: | Public Health Law Program |
| Commenter: | Marice Ashe |
| State: | CA |
| Agency: | Federal Trade Commission |
| Rule: | Food Industry Marketing Practices to Children and Adolescents |
| Attachments: | 529477-00006.pdf Download Adobe Reader |
Comments:
To: Federal Trade Commission Fr: Marice Ashe, JD, MPH; Director, Public Health Law Program We have read with great interest the recent Federal Register notice “Commission Information Collection Activities; Proposed Collection, Comment Request,” FR 19505 (2007). We applaud proposed collection activities of the Federal Trade Commission (“FTC”) as being responsive both to Congress and to the comments received from public health leaders – such as the California Department of Health Services (CDHS) – who have front-line responsibility for protecting the health of the nation. CDHS has been a prescient leader among state health departments in successfully addressing chronic diseases. For example: • California’s comprehensive tobacco control program has been the benchmark program against which the Centers for Disease Control and Prevention, the World Health Organization and other international health agencies measure success in tobacco control. According to CDHS, the smoking rate of adults is 25% lower in California than in the rest of the nation, and the incidence of lung cancer is decreasing four times faster in California than in the rest of the nation. • CDHS has exhibited similar leadership in obesity prevention. California originated the Five-A-Day for Better Health campaign that was adopted nationwide by the U.S. Department of Health and Human Services in 1991. While the worsening of the obesity epidemic is undeniable, recent survey data shows that children in food stamp-eligible households, who are among the populations most heavily targeted by CDHS education programs, have significantly increased their fruit and vegetable consumption. Over the same five-year period, fruit and vegetable consumption among higher income children has remained the same. We share this information to support the FTC as it repeatedly cites to the comments submitted by CDHS. It is clear from the Congressional mandate to the FTE that Congress is highly interested in the impact of various forms of marketing of foods and beverages on the health of the population. CDHS is clearly a national leader in disease prevention, and therefore the FTC and Congress should closely consider its perspectives. In our last communication on December 19, 2006, PHLP noted that the FTC collects annual marketing reports from the tobacco industry . We draw your attention to the most recent report which has been updated since our last communication: Federal Trade Commission Cigarette Report for 2004 and 2005 (see http://www.ftc.gov/reports/cigarette05/050809cigrpt.pdf). We strongly encourage the FTC also to collect annual data from the food and beverage industries. The April 18, 2007, Federal Register notice states the following: “The FTC plans to complete the current report before considering proposals for future research.” While we applaud the FTC’s long-term plans for monitoring food and beverage marketing, we want to emphasize the value and importance of annualized data so that patterns in industry marketing behavior can be tracked. Simply occasional or episodic data collection will lead to untimely delays in generating a full understanding of the contribution of food and beverage marketing to the obesity epidemic. Thank you for your consideration of these comments. cc: Senate: Hon. Boxer Hon. Cantwell Hon. DeMint Hon. Dorgan Hon. Ensign Hon. Kerry Hon. McCain Hon. Pryor Hon. Rockefeller, IV Hon. Smith Hon. Snowe Hon. Sununu House: Hon. Barrow Hon. Barton Hon. Blackburn Hon. Bono Hon. Boucher Hon. Burgess Hon. Butterfield Hon. Capps Hon. DeGette Hon. Dingell Hon. Eshoo Hon. Fossella Hon. Gonzalez Hon. Harman Hon. Hastert Hon. Hill Hon. Hooley Hon. Markey Hon. Matheson Hon. McCaskill Hon. Melancon Hon. Myrick Hon. Pickering Hon. Pitts Hon. Radanovich Hon. Ross Hon. Schakowsky Hon. Solis Hon. Stearns Hon. Terry Hon. Towns Hon. Waxman Hon. Weiner Hon. Whitfi