Submission Number: 00020
Received: 4/2/2011 4:18:26 PM
Commenter: Ronald Bogle
Organization: North Carolina Superior Court Judge (Retired)
State: North Carolina
Agency: Federal Trade Commission
Initiative: Alcohol Reports: Project No. P114503
Attachments: No Attachments
In 1999, FTC concluded there is reason to believe alcohol advertising plays a role in influencing underage persons to drink.
Since then, respected research has definitively found that alcohol advertising has contributed to the increase in underage drinking. Among other things, these studies conclude that adverting influences teens to have positive expectancies about alcohol use and to intend to drink or to drink. In other words, teens are positively influenced to drink alcohol by industry advertising.
In addition, not only are teens influenced by industry efforts, a collaborative study by UCLA, Johns Hopkins, Northwestern and the RAND Corporation concludes the industry actually targets teens with their messaging.
Without rejecting all existing national research and data, it seems implausible, given the frequency and breadth of research confirming the critical impact alcohol advertising has upon teens, along with the enhanced exposure of teens to industry advertising, to conclude that the currently approved industry "self-regulation" has protected or minimized risk to this vulnerable population. To the contrary, industry "self-regulation" has increased the risk and harm to this population, while protecting only the industry at youth expense.
On March 6, 2007, the U.S. Surgeon General announced a National "Call to Action," a science driven declaration, mobilizing all sectors to society to combat an identified public health crisis, namely, underage drinking.
Like tobacco products before it, the science has rapidly identified the health damage caused by alcohol to young and old alike. However, this harm is particularly acute to the still-developing body of teen drinkers.
However, though tobacco has one of the most highly regulated forms of marketing in the world for health harm reasons, the alcohol industry has successfully evaded similar regulation despite its many known health harms. Associated with more than 60 known medical conditions, it is a component cause in 200 others.
But unlike tobacco, alcohol is multi-dimensional in its harm. A frequent catalyst for destructive, even criminal behaviors, courtrooms in America are saturated with alcohol-related cases.
The U.S. Department of Justice reports that alcohol is a factor in 50 percent of violent crime and 40 percent of traffic fatalities.
With many experts contending that alcohol, an addictive drug, is the nation's worst drug problem, the British Independent Scientific Committee on Drugs recently concluded that, when considering alcohol's harm to the individual user and to the environment around the user, alcohol is the most harmful societal drug.
NIAAA reports that 12 percent of Americans ages 18 to 20 are addicted to alcohol, the highest rate of addiction of any age group. Confirming the fruits of our neglect of underage drinking, it also finds that 53 percent of the nation's alcoholics are youths, pre-teen to age 26.
As a judge for many years, I can confirm by experience the societal harm from alcohol. No courtroom or community is left untouched by that harm.
While I readily acknowledge that underage drinking is a complex issue, the alcohol industry, which profits enormously from the use and abuse of its products by teens and adults, is a primary factor is this grave societal problem.
It is long past time for appropriate governmental intervention to rein in the harm to teens and society. This industry, which targets teens with its advertising and its products (alcopops, alcohol energy drinks, and others), must, as a matter of responsible public policy, be subject to the same scrutiny and regulation as any other harmful or unhealthy product.
As a start, I urge the FTC to ban radio and television advertising of alcohol products. With our youths at continued risk from an industry unwilling or unable to regulate itself, nothing less is appropriate.
Ronald E. Bogle
Superior Court Judge (Retired)