Philip Morris
Before the United States Food and Drug Administration Docket No. 95n-0253 Docket No. 95n-0253j Regulations Restricting the Sale and Distribution of Cigarettes and Smokeless Tobacco Products to Protect Children and Adolescents, Proposed Rule, Analysis Regarding FDA's Jurisdiction Over Nicotine - Containing Cigarettes and Smokeless Tobacco Products, Notice Comments of Brown & Williamson Tobacco Corporation Liggett Group Inc. Lorillard Tobacco Company Philip Morris Incorporated R.J. Reynolds Tobacco Company Tobacco Institute Inc. Volume Viii
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- Litigation
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- Tulane Univ
- Univ of Ca Chico
- Univ of Nh
- Univ of South Al
- Univ of Southern Ms
- Univ of Wi
- Ben J + Joyce Rosenberg
- Duke Univ
- FDA, Food and Drug Administration
- Focus Group
- La State Univ
- San Francisco State Univ
- Univ of Ca Chico
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- Master ID
- 2057063515/3727
Related Documents:- 2057063523-3542 Professor Timothy P. Meyer University of Wisconsin, Green Bay
- 2057063561-3563 Edward V. Morse Ph.D. Clinical Professor of Psychiatry at Lsumcno
- 2057063576-3583 Lucy Henke
- 2057063589-3595 Professor J. Stephen Thomas
- 2057063600-3621 Public Policy Decisions Should Be Based on Sound Social Science Research, Not Speculation or Political Motivation.
- 2057063633-3636 Dr. Linda D. Goff
- 2057063645-3651 Charles F. 'rick' Houlberg
- 2057063653-3660 Paul J. Traudt, Ph.D.
- 2057063669-3673 Comments to FDA
- 2057063684-3701 Comments by W. Kip Viscusi on FDA Notice of Findings, 'regulations Restricting the Sale and Distribution of Cigarettes and Smokeless Tobacco Products to Protect Children and Adolescents: Findings of the Focus Group Testing of Brief Statements for Cigarette Advertisements,' 60 Fed. Reg. 61,670-79 (95101)
- 2057063708-3727 Bibliography of W. Kip Viscusi
- Named Person
- Allen, G.G.
- Goff, L.J.
- Henke, L.L.
- Holbourg, R.
- J, B.
- Meyer, T.P.
- Morse, E.V.
- Osofsky, H.J.
- Ragsdale, D.
- Simon, P.M.
- Thomas, J.S.
- Traudt, P.R.
- Viscusi, W.K.
- Wolf, M.L.
- Goff, L.J.
- Recipient (Organization)
- FDA, Food and Drug Administration
- Author (Organization)
- Bw, Brown & Williamson
- Lig, Liggett
- Lor, Lorillard
- PM, Philip Morris
- RJR, R.J.Reynolds
- TI, Tobacco Inst
- Lig, Liggett
- Date Loaded
- 17 Apr 1999
- UCSF Legacy ID
- ugs13e00
Document Images
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BEFORE THE
UNITED STATES FOOD AND DRUG ADMINISTRATION
•
Docket No. 95N-0253
Docket No. 95N-0253J
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Regulations Restricting the Sale and Distribution of Cigarettes and
Smokeless Tobacco Products to Protect Children and Adolescents;
Proposed Rule; Analysis Regarding FDA's Jurisdiction Over Nicotine-
Containing Cigarettes and Smokeless Tobacco Products; Notice
COMMENTS OF
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•
BROWN & WILLIAMSON TOBACCO CORPORATION
LIGGETT GROUP INC.
LORILLARD TOBACCO COMPANY
PHILIP MORRIS INCORPORATED
R.J. REYNOLDS TOBACCO COMPANY
TOBACCO INSTITUTE INC.
VOLUME VIII
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Brown & Williamson
Tobacco Corporation
1500 Brown & Williamson Tower
Louisville, Kentucky 40232
Lorillard Tobacco Company
One Park Avenue
New York, New York 10016
R.J. Reynolds Tobacco Company
401 N. Main Street
Winston-Salem, North Carolina 27102
Liggett Group Inc.
700 West Main Street
Durham, North Carolina 27702
Philip Morris Incorporated
120 Park Avenue
New York, New York 10017
Tobacco Institute Inc.
1875 I Street, N. W.
Washington, D.C. 20814
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VOLUME VIII
EXPERT COMq=S ON ADVERTISING AND RELATED ISSUES
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VOLUME VIII
EXPERT COMMENTS ON ADVERTISING AND RELATED ISSUES
TABLE OF CONTENTS
Introductory Statement
1. Professor Timothy P. Meyer
Marketing, Advertising, Mass Media and Consumer Behavior,
Ben J. and Joyce Rosenberg Professor, University of
Wisconsin
(CV attached)
A Ban On Color And Imagery In Cigarette Advertising
Is Tantamount To A Ban On Cigarette Advertising
FDA's Proposal To Ban Imagery and Color In Outdoor
Advertising For Cigarettes Is Unsupported By The
Record And Is Tantamount To A Ban On Outdoor
Advertising
FDA Cites No Evidence Of Any Causal Connection
Between Exposure To Cigarette Advertising And The
Decision To Smoke
2. Professor Edward V. Morse
Clinical Professor of Psychiatry, Louisiana State
University Medical Center, New Orleans; Associate
Professor, Department of Sociology, Tulane University;
Adjunct Professor, Department of Pediatrics,
Tulane University
(CV attached)
FDA's Proposal To Reduce Underage Smoking Is Based On
A Flawed And Simplistic Model of Behavior And Will Be
Ineffective In Reducing Underage Smoking
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3. Professor Lucy L. Henke
Mass Media and Impact On Children
University of New Hampshire
(CV attached)
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FDA's Proposal To Restrict Cigarette Advertising To
Reduce Underage Smoking Is Unsupported By The Record
And Completely Ignores The Substantial Body Of
Relevant Research Regarding Advertising Messages And
Their Impact On Children
4. Professor J. Stephen Thomas
Anthropology
University of South Alabama
(CV attached)
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People Smoke Cigarettes For Numerous Reasons That Are
Entirely Unrelated To Any Pharmacological Effects of
Nicotine
~ 5. Professor Michelle L. Wolf
Mass Media and Impact On Children
San Francisco State University
(CV attached)
FDA's Record Does Not Support Its Proposal To
Restrict Cigarette Advertising To Reduce Underage
Smoking and FDA Completely Ignores Entire Body Of
Relevant Literature And Decades Of Research In Social
Science Regarding Media Effects On Consumers
6. Professor Linda J. Goff
Mass Media and Impact On Children
University of Southern Mississippi
(CV attached)
FDA's Proposed Regulation Is Not Supported By
Communication Theory And Its Specific Proposals Are
Naive And Will Fail To Achieve The Desired Outcome
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7. Professor Richard Holbourg
Mass Media and Consumer Behavior
San Francisco State University
(CV attached)
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FDA's Record Is Filled With Inconsistent And Variable
Definitions Regarding Key Research Concepts And
Issues; The Record Does Not Therefore Support The
Proposed Action
8. Professor Paul R. Traudt
Marketing, Advertising and Consumer Behavior
University of California, Chico
(CV attached)
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FDA's Proposed Action And Rationale Are Based On
Outmoded And Erroneous Models Of Consumer Behavior
And The Proposed Action Will Not Be Effective In
Reducing Underage Smoking
9. Professor Donald Ragsdale
Speech and Communication
Louisiana State University
(CV attached)
FDA's Proposal Regarding:Advertising Restrictions
Will Be Ineffective Because The Agency Ignores Basic
Tenets Of Communication Theory And Relies On
Misconceptions About Advertising As A Form Of
Communication
10. Professor W. Kip Viscusi
George G. Allen Professor of Economics
Department of Economics
Duke University --
FDA's Proposal To Require Additional Warnings On
Cigarette Advertising Is Methodologically Unsound,
Unlikely To Prove Effective And May Produce
Unintended Adverse Consequences
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11. Edward V. Morse, Ph.D.
Howard J. Osofsky, M.D., Ph.D.
Patricia M. Simon, MSW, Ph.D.
The Focus Group Research Contracted For By FDA Is
Methodologically Flawed And Biased -- Yet,
Nevertheless, Even This Research Underscores The
Power And Effect Of Family, Friends And Peers, Rather
Than Cigarette Advertising -- On Youth Choices About
Smoking
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VOLUME VIII
EXPERT COMMENTS ON ADVERTISING AND REtATED ISSUES
INTRODUCTORY STATEMENT
FDA acknowledges that the issues surrounding underage smoking
require special expertise,'and that, in carrying out its proposed
regulations, FDA intends to consult "with other federal agencies
with expertise in consumer behavior and marketing . . . and with
consultants and contractors who are expert in communications theory
and practice." 60 Fed. Reg. 41,328.
What follows in this volume are the comments of experts in
consumer behavior, marketing, communications theory and related
fields with whom the tobacco industry has consulted in responding to
FDA's proposed regulation of tobacco products. Each of these
experts has been paid a consulting fee for their time. The comments
and views expressed are their own. Materials referred to in these
comments are included in the Appendix to Volume VIII.
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