Mon, May 14, 2001 1:46 PM
Subject: Comment on FTC reports
May 14, 2001
Office of the Secretary
I am writing to submit public comment on the Federal Trade Commission's (FTC) publication of its Tobacco Industry Marketing Reports. I strongly urge that the FTC continue the ongoing data collection, analysis and publication of this important documents.
As both a tobacco control policy specialist and a librarian, I find these reports to be invaluable reference tools that provide public health specialists, researchers, government agencies, non-governmental organizations, elected officials and the general public timely, accurate and authoritative data on tobacco industry marketing expenditures. Over the years, these reports have been a key resource in the development of public policy at the local, state and national level.
Without the FTC mandate to collect the necessary data and produce these marketing reports, the tobacco industry would have no compelling reason to release this data publicly. Thus, it is essential that the FTC continue publishing these reports. Further, the FTC should take measures to improve the data collection and reporting mechanisms so that future reports:
1. Include a state-by-state breakdown of the reported marketing expenditures;
2. Include company-specific or even brand-specific marketing expenditure data;
3. Provide subtotals for marketing expenditures for regular versus "reduced-risk" tobacco products;
4. Include a breakdown of the different types of expenditures the companies make within the existing promotional-allowance and retail-value-added expenditure categories (which account for the vast majority of all promotional spending by the companies).
Please feel free to contact me if you have any questions about my comments. Also, please confirm that you have received my comments on this matter and that they will become part of the public record on this matter. Thank you for your time and consideration.