Submission Number: 00227
Received: 11/2/2011 11:36:09 AM
Commenter: J. Randy Koch
Organization: Virginia Commonwealth University Institute for Drug and Alcohol Studies
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of Phusion Projects, LLC; Jaisen Freeman; Christopher Hunter; and Jeffrey Wright; FTC File No. 112 3084
Attachments: No Attachments
To Whom it May Concern: While the goals of the consent agreement (to decrease underage binge drinking)are laudable, I'm afraid that the proposed strategies will be insufficient at best and possibly counterproductive. First, there is no evidence that I am aware of that labelling the containers with the amount of standard drinks will limit consumption. In fact, given the target audience for this product, it seems just as likely that such labelling may actually make the product more appealing. Before any such serving size labelling is required, the impact must be subjected to scientific study. Secondly, while requiring that the containers be resealable seems logical and does communicate that the beverage is not intended to be consumed in one sitting, again there is no scientific evidence that this will be effective. Given the lack of scientific support for the effectiveness of the proposed strategies, it appears quite possible that the consent agreement will have no positive impact on reducing consumption but will provide the appearance of having addressed the problem. However, the real problem is large containers with highly alcohol content packaged and priced to appeal to youth. These are what must be addressed. Therefore, a more effective strategy would be to limit the size and alcohol content to such beverages to 6% and 12 ounces. An alternative would be to apply a Federal excise tax to significantly increase the price such that they are not perceived as a "good value" by young people. We do have excellent scientific data to demonstrat that pricing effects consumption of alcohol, particularly among young people. Thank you for the opportunity to comment. J. Randy Koch, Ph.D.