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WASHINGTON-The small Dockets Management Branch office at the U.S. Food & Drug Administration's headquarters is filled with letters-many that begin: "Dear Dr. Kessler and Honorable William Jefferson Clinton," and end: "BUTT-OUT! Signed, a longtime smoker."

Since the FDA's plan to regulate tobacco advertising was unveiled last summer, the office has been flooded with form letters and public comments written on personal stationery and company letterheads. This month alone, roughly 40,000 comments have been received.

The letters range from a handwritten note by an 80-year-old Southern woman who started smoking at age 6 to a formal letter by Lisa Butler, account manager at Brown & Williamson Tobacco Corp. and Jim Rosenblum Racing Co.'s form letter signed by more than 300 people.

The more than 300 volumes of registered mail and processed comments, however, include few letters from advertising agencies, marketing associations or tobacco companies. This is due, in part, to the extension of the public comment period from Nov. 9 to Jan. 2.

"We are not even in the final stages of our first draft," said Jeff Perlman, senior VP of the American Advertising Federation. "But our message, I think, will emphasize the futility of [the regulations]-that they just won't work."

Many major industries often wait to submit comments so they can monitor incoming letters, incorporate new data or defend themselves against new studies.

The latest published study, for example, appeared in the Journal of the National Cancer Institute this month. The study stated cigarette ads influence minors more than peer pressure, family smokers or demographics.

"We are talking to advertising and marketing experts and other professionals so that we can put together a more scholarly letter," said Tom Lauria, a Tobacco Institute spokesman. "Our most prominent-named companies [Phillip Morris, R.J. Reynolds, Brown & Williamson, Lorillard and Liggett Group] are also going to submit a joint letter."

Advertising and tobacco groups also are suing to oppose the regulations. On Aug. 10, the day the FDA plan was announced, the Freedom to Advertise Coalition (including AAF, American Association of Advertising Agencies, Association of National Advertisers, Outdoor Advertising Association of America and Magazine Publishers of America), tobacco manufacturers, the agricultural community and retailers filed four separate suits against the FDA.

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