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Campaign to Achieve FDA Regulation of Tobacco
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This 2001 strategy memo, Campaign to Achieve FDA Regulation of Tobacco, reveals Philip Morris' plans to institute U.S. Food and Drug Administration (FDA) oversight of the tobacco industry. The memo was written by John Brady of Direct Impact, a public relations company PM has retained for campaigns such as organzing the company's "Options" program (which promoted ventilation as a solution to secondhand smoke), defeating the 1998 McCain bill to regulate the industry, and lobbying against excise taxes in Vermont in 1995. The memo reveals that FDA oversight is a PM corporate goal being pursued at least in part to enhance the company's image. In the section entitled "A Public Relations Opportunity," the memo states,
"Though the nature of the FDA regulation issue does present some challenges for Philip Morris, we believe that is also opens an important opportunity for the company to enhance the Philip Morris corporate image..."
The memo also points out how the pursuit of FDA regulation will help PM by complicating tobacco issues for the public (thus graying PM's traditionally black coporate hat), and giving PM a strategic public relations advantage over other tobacco companies by making the company appear to be a "good corporate citizen". The memo says,
"Unfortunately for the industry, the tobacco debate in recent years suffered from oversimplification, perpetuated by media coverage that depicts tobacco-related issues as 'black and white,' with tobacco companies playing the predictable role as evil corporate giant..." It continues, "The debate over FDA reform has the potential to complicate this portrayal in a manner that will specifically benefit Philip Morris. The simple fact that other tobacco companies will likely come out on the opposite side of the issue--against FDA regulation--provides Philip Morris a chance to distinguish itself from its competitors as a good corporate citizen. Positioned appropriately, the campaign can actually serve two purposes: achieving PHilip Morris's goal of instituting regulation of the tobacco industry while also realizing significant public affairs benefits."
The memo says that the key to success in achieving FDA regulation lies in recruiting non-traditional allies, "...including anti-smoking activists, the health care community and other non-traditional ally groups that may be difficult for Philip Morris to access." Direct Impact proposes hiring field staff who already have relationships with health groups and having them make "highly personalized, individual contacts with these prospective allies" to help gain advocates' support.
Direct Impact proposes to help PM "develop better relationships with communities that have often opposed Philip Morris" and thus "improve perception of Philip Morris, as compared to other tobacco companies...[to] help promote to the broader public the image of Philip Morris as a company that is 'doing what's right' as it relates to tobacco regulation."
A different 2001 PM document entitled "FDA Regulation: Non-Traditional Allies, MA and RI" lists potential "non-traditional" allies in these states. The list includes Greg Conolly of the Massachusetts Department of Public Health, Boys and Girls Clubs of America, Boston Police Patrolmen's Association, City of Worcester (MA) Department of Public Health, Rhode Island Department of Health, Rhode Island Medical Society, the Massachusetts Hospital Association, and Blue Cross/Blue Shield of Massachusetts. (Title: FDA REGULATION NON-TRADITIONAL ALLIES Document Date: 20010105 Bates Number: 2085249861/9862 URL: http://www.legacy.library.ucsf.edu/cgi/getdoc'tid=mwb22c00&fmt=pdf&ref=results )
Yet another document (an internal PM email) shows that PM carried out focus group testing to determine if pursing FDA regulation would improve PM in the eyes of the public. The email states,
"Impact on PM Image--knowing PM supports FDA and after hearing reasons moves overall views of the company in the positive direction. Total 'unfavorable' drops 15%, total 'favorable' goes up 5% and 'neutral' increases 16%." Title: FDA RESEARCH RESULTS - COMMUNICATIONS TESTING Organization Authors: PMMC, PHILIP MORRIS MANAGEMENT CORP Document Date: 20010409 Document Type: EMAI, E-MAIL, REPT, REPORT, OTHER Bates Number: 2082654123A/4124 URL: http://www.legacy.library.ucsf.edu/cgi/getdoc'tid=dxk84a00&fmt=pdf&ref=results
Yet another document analyzes which messages prove most convincing in selling FDA regulation to the general public: http://www.legacy.library.ucsf.edu/cgi/getdoc'tid=bnc75c00&fmt=pdf&ref=results
These documents taken together demonstrate several important points that are made apaprentl by observing how the industry has operated in the past:
1) Philip Morris, not public health authorities, is driving the current push towards FDA regulation,
2) PM is pursuing FDA regulation according to a well-strategized plan,
3) PM is pursing regulation at least in part for the positive public relations benefits that will accrue from such action,
4) Doing so gives PM an image advantage (particularly among legislators) by distinguishing itself in a positive way from its competitors, who oppose the regulation,
5) To achieve the goal of FDA regulation, PM is using similar strategies to those they have used in the past on other issues:
A) broadening and complicating the issue (as they did with secondhand smoke) to deflect regulator's and the public's focus,
B) selling the issue to the public and legislators by tailoring messages to certain audiences (as they have done when working to defeat tax increases),
c) Repeating a "white hat" strategy used in Oregon in 1996, namely blurring the lines between tobacco and public health:
"Make our hat whiter, make their hat blacker...blur tobacco's relationship to the health care community." [Title: Proposed Advertising Strategy to Defeat Measure 70, Type of Document: Report, Author: Fairness Matters to Oregonians, Date: 19960613 Site: Tobacco Institute http://www.tobaccoinstitute.com/ Page Count: 16 Bates No. TIOR0020292/0307 URL: http://www.tobaccoinstitute.com/getallimg.asp'DOCID=TIOR0020292/0307
Date: March 22, 2001 To: John Scruggs From: John Brady Re: Campaign to Achieve FDA Regulation of tobacco
We appreciate the opportunity to provide you with our thoughts on the Philip Morris campaign to institute Food and Drug Administration (FDA) oversight of the tobacco industry. This memorandum outlines a campaign strategy that will both increase the likelihood of legislative success for Philip morris, as well as enhance the company's image as a supporter of reasonable tobacco regulation.
A Challenging Legislative Campaign
The challenge[s] for Philip Morris in conducting this campaign are numerous.
--Legislative success must be achieved in the face of strong objections by Philip Morris' competitors in the industry;
--The issue is likely to fragment traditional tobacco support -- including pro-tobacco legislators, farmers, smokers and other constituents--dividing alliances between Philip Morris and its competitors.
Despite the fact that Philip Morris will through this campaign share the short-term goals of traditional "tobacco regulation crusaders," gigvfen the nature of disputes over tobacco in recent years, these groups are unlikely to cooperate with the company. Though their support for FDA regulation will better Philip Morris' chances of legislative success, some tobacco-regulation advocates may also support unfavorable amendments to the bill or take other measures that would further divide legislators on the issue.
A Public Relations Opportunity
Though the natures of the FDA regulation issue does present some challenges for Philip Morris, we believe that is also opens an important opportunity for the company to enhance the Philip Morris corporate image through support of reasonable tobacco regulation. Unfortunately for the industry, the tobacco debate in recent years has suffered from oversimplification, perpetuated by media coverage that depicts tobacco-related issues as "black and white," with tobacco companies playing the predictable role as evil corporate giant. The debate over FDA reform has the potential to complicate this portrayal in a manner that will specifically benefit Philip Morris. The simple fact is that other tobacco companies will likely come out on the opposite side of the issue --against FDA regulation--provides Philip Morris a chance to distinguish itself from its competitors as a good corporate citizen. Positioned appropriately, the campaign can actually serve two purposes: achieving Philip Morris' goal of instituting FDA regulation of the tobacco industry while also realizing significant public affairs benefits.
Non-Traditional Allies -- The Keys to Success
The messaging for such a campaign will be critical, enabling Philip Morris to support FDA regulation without at the same time supporting negative perceptions of the industry as one "in need of" aggressive regulation. As important will be the allies that Philip Morris leverages to communicate the campaign messages to legislators. Because many of Philip Morris' traditional allies--stakeholders in the tobacco industry, smokers, etc. -- will be largely out of play in this debate, the company will need to develop relationships with a range of new advocates who can speak convincingly about the benefits of FDA regulation of tobacco.
While we understand that Philip Morris already has in place an extensive field network, a list of non-smoker and smoker advocates, and a range of other grassroots resources, the unique nature of this campaign may make mobilization of these allies less effective than it has been in other efforts. Some of Philip Morris' traditional allies may not agree with the idea of including tobacco under the list of FDA-regulated products, while some may simply not be as convincing as pro-regulation advocates...
We believe that Direct Impact can supplement Philip Morris' ally development capabilities for this particular issue, bringing to the campaing individuals and groups that have previously been soft opponents of Philip Morris, who may for this reason be less receptive to recruitment efforts conducted directly by the company. Direct Impact mmaintains an extensive network of more than 1,000 field operatives across the country, and we hire field staff specifically for the task at hand. We would retain field recruiters for this project who have relationships with relevant audiences, including the health care community, anti-smoking activists, and other non-traditional ally groups that may be difficult for Philip MOrris to access. The use of highly personalized, individual contacts with these prospective allies would help introduce th eissue, the campaign, and Philip Morris' role ina manner most likely to gain advocates' support.
Once recruited, these non-traditional allies can then participate in a number of activities, including writing letters to legislators, meeting formally or informally with members of Congress, submitting opinion editorials and letter to the editor of local papers, and so on. In addition, by educating these individuals about Philip Morris' commitment to supporting sensible tobacco regulation, the company will help develop better relationships within the communities that have often opposed Philip Morris or taken a middle-of-the-road stand on tobacco-related issues. Though these groups cannot be expected to support the company's efforts on all topics, the improved perception of Philip Morris, as compared to other tobacco companies, could be advantageous and could help promote to the broader public the image of Philip Morris as a company that is "doing what's right" as it relates to tobacco reguation...
Passing legislation that will institute FDA oversight of tobacco will be a difficult battle, one that divides the industry and fragments traditional Philip Morris supporters. however, a strategic program that will recruit non-traditional allies to join Philip Morris in supporting legislation to include tobacco in the lsit of products regulated by FDA would not only help the company increase the likelihood of legislative success, but would also have ancillary public relations benefits that could be leveraged through a range of earned media and other efforts...
- Philip Morris
- Brady, John (Founder, Direct Impact Marketing/PR firm)Direct Impact specializes in "grassroots" mobilizing for corporations
- Scruggs, John F. (PM Mgmt Corp. Federal Government Affairs Office)VP Federal Government Affairs (Tobacco) PM Management Corp.cc. 2/2000, Alexandria, Virginia (2085318084-Fax letterhead 2001)
- United States
- FDA Regulation (Philip Morris campaign to institute FDA regulation of the to)Philip Morris campaign to institute regulation of the tobacco industry around 2000-2001
- Named Organization
- Direct Impact Company (Public relations corporate "grass roots" organizing firm.)Assists PM in recruiting "non-traditional allies" to help with FDA regulation campaign
- United States Food and Drug Administration
- Philip Morris
- MEMO, MEMORANDUM
- REPT, REPORT, OTHER
- FDA regulation
- Corporate image
- Corporate strategy