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### Girl Scouts of the USA

#### Comments: Addressing Obesity, Nutrition and Fitness in Girls

*Submitted to:*

Department of Health and Human Services

Food and Drug Administration

Obesity Working Group

## Docket No. 2003N-0338

Division of Dockets Management (HFA-305)

5630 Fishers Lane, Room 1061

Rockville, MD 20852

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#### [Overview: Girl Scouts of the USA]{.underline} 

The Girl Scouts of the USA is the nation's preeminent organization
dedicated solely to girls. Since our founding in 1912, the mission of
Girl Scouts has been to empower girls to grow strong in body, mind and
spirit. We boast a well-respected and highly successful program and have
a profound reach: our present membership includes nearly 3 million girls
and 1 million adult volunteers.

Encouraging health and fitness among our membership is not new to Girl
Scouts. Throughout our 91-year history we have offered girls innovative
programs in sports, nutrition and health. When Girl Scouts of the USA
began in 1912, founder Juliette Gordon Low encouraged girls to "eat well
and get their heart and blood in working order." The nation\'s first
Girl Scouts broke the rules of tradition by trading in their long skirts
for short bloomers to play basketball. Today, Girl Scouts of the USA
continues its dedication to providing girls unlimited opportunities in
sports and fitness, health and nutrition.

Given our long-standing commitment to the health and well being of
girls, our organization has a profound understanding of the complex
issue of obesity. Equipped with such expertise, we have created an
impressive array of successful initiatives and curricula in health,
nutrition and fitness some in partnership with other youth
organizations, corporations and government agencies which we believe,
are part of the solution to remedying the current childhood obesity
crisis.

We applaud the FDA for its leadership role on this important issue and
greatly appreciate the opportunity to provide comments about 1) how
obesity affects girls; 2) successful Girl Scout initiatives; and 3)
ideas for creating a national solution to this crisis. It is our hope
that these comments will inform and provide substance for the Obesity
Working Group as it creates the action plan to "confront the current
obesity epidemic in the United States and develop new and innovative
ways to help consumers lead healthier lives through better nutrition."

#### [Obesity and Girls]{.underline}

As evidenced by recent statistics, our nation is facing a critical
problem: obesity. One need only peruse the recent research, which
reveals the depth and breadth of the crisis in the United States. The
FDA posits that "obesity is a growing and urgent public health problem."
The CDC informs us that "obesity has reached epidemic proportions." And
the Surgeon General has issued a call to action to prevent and decrease
obesity. Moreover, the epidemic is not limited to adults. According to
the CDC, the percentage of young people who are overweight has more than
doubled in the last 20 years. Shockingly, of children and adolescents
ages 6 to 19 years, 15% or about 9 million, are considered overweight.

While the prevalence of obesity in girls and boys is similar, there are
some disturbing statistics specifically related to girls:

-   In all grade levels, girls get significantly less activity than boys
    do. Overall, male students are significantly more likely to
    participate in physical education class and sports teams than female
    students. (CDC, Youth Risk Behavior Surveillance, 1999)

-   Female students in grade 9 (75.6%) are significantly more likely
    than female students in grades 11 and 12 (36.8% and 29.4%),
    respectively to be enrolled in a physical education class. (CDC,
    Youth Risk Behavior Surveillance, 1999) Essentially, participation
    in school-based physical education classes declines throughout the
    high school years.

-   Nationwide, male students (36.3%) are more likely to attend physical
    education classes daily than female students (28.4%). (CDC, Youth
    Risk Behavior Surveillance, 1999)

-   Among students enrolled in physical education class nationwide,
    overall, male students (82.1%) are significantly more likely than
    female students (69.6%) to have exercised more than 20 minutes
    during an average class. (CDC, Youth Risk Behavior Surveillance,
    1999)

These statistics demonstrate that too many girls are not on the right
path to healthy living and the situation only worsens among poor, black
and other ethnic minority girls. Girl Scouts of the USA is working to
change this.

#### 

#### [Prevention of Obesity among Girls: A Holistic Approach]{.underline}

In the age of sedentary lifestyles driven by television, computers and
video games most experts state that children must have opportunities for
physical activity each day. This is true. However, our work with girls
has taught us that to be most effective in remedying obesity, our
approach must be more holistic: physical fitness must be combined with
good nutrition skills, a healthy body image and an overall healthy
lifestyle. The array of initiatives we have developed are tailored to
address these components in tandem. For example, we teach girls sports
skills through clinics and nutrition through cooking. Other projects
help girls learn to recognize unrealistic body images as portrayed in
the media. And we assist them in understanding and recognizing eating
disorders and the damaging effects of substance abuse.

Girl Scouts of the USA also has created a strong social environment that
encourages and enables physical activity. We have many sports curricula
that are used in troop settings and even in some schools. Many of our
program activities and events involve the families of girls, so
establishing positive health behaviors becomes a family affair. This
broader, holistic approach to "healthy living" has helped us yield the
greatest long-term success. And, most importantly, we have found that by
instilling these values during childhood, the positive habits formed are
very often carried well into adulthood.

Part of our success has been driven by the creation of state-of-the-art
materials and initiatives. Many of our resources are the result of
strong partnerships with key health, fitness and sports organizations,
corporations and government agencies such as, Centers for Disease
Control and Prevention, the Office of National Drug Control Policy and
the Women\'s Sports Foundation that have provided subject matter
expertise and, in some instances, have financed these projects.
Following is a sample of some of our signature initiatives:

-   ***GirlSports* Basics** -- teaches entry level skills curriculum for
    girls, ages 5 to 8, to boost self-confidence and ensure entry level
    success in sports.

-   ***GirlSports* Fit & Fun** -- teaches teambuilding and progressive
    fitness skills for girls, ages 8 to 11, through sports activities.

-   **In the Zone: Living Drug Free** \-- teaches girls, 5-17 facts
    about drugs and includes activities to encourage sound
    decision-making and healthy behaviors.

-   **Strong Bones, Strong Girls** -- Encourages bone health for girls
    9-12 through education about the importance of increased calcium
    consumption and physical activity.

-   **Game Face: What Does a Female Athlete Look Like?** --Encourages
    all girls, regardless of ability, to participate in sports.

-   **Uniquely ME! The Girl Scout/Unilever Self Esteem Program** --
    covers topics from body image to healthy eating for girls 8-14.

##### What the Future Holds

While our programming is strong, we recognize there is more to be done.
With increased funding and strategic partnerships, Girl Scouts can
target increased numbers of girls, especially those in underrepresented
populations or geographic areas where we see significantly higher
obesity rates. As we look to the future and define our role in
addressing obesity, we hope to:

-   Increase information to girls on topics like nutrition, exercise,
    goal setting and emotional health. Information could be disseminated
    via the Girl Scouts of the USA website, an interactive CD-ROM and
    print resources.

-   Expand research efforts through the Girl Scout Research Institute on
    topics from motivation to body image to peer pressure.

-   Increase collaborative efforts with organizations and agencies like
    the FDA that work to promote healthy behaviors for youth and
    encourage sports and fitness opportunities and programs.

-   Include a print/web component on the Girl Scouts of the USA website
    for family members, parents, Girl Scout leaders and advisors that
    address health, nutrition and other relevant topics.

-   Create a Girl Advisory Board to advise on needed resources, issues,
    and messages.

-   Create a series of national events to promote health and fitness
    among our members, increase public awareness of the obesity epidemic
    and kick-start a national campaign.

-   Organize a national health summit for young girls with diverse
    representation to share cultural issues around the topics of health,
    fitness and diet.

-   Create a career component to educate girls on the various job
    opportunities in the field of health and fitness, including
    leadership institutes, job fairs, print/web resources and
    internships.

## What the FDA Can Do to Address Obesity

The role of the FDA in addressing obesity is powerful and your
involvement can lead to a marked decrease in this staggering epidemic.
The challenge, however, is not to reinvent programs, but to build on the
success of proven initiatives. In fact, we believe the answer to solving
the obesity problem exists; the necessary mechanisms now need to be
established to systematically address the issue. We recommend the FDA:

-   Partner with groups such as the Girl Scouts and provide support
    through financial resources and by working collaboratively to
    develop progressive new projects, such as those outlined in the
    previous section. Organizations such as the Girl Scouts of the USA
    have already built successful curricula and activities. The FDA can
    assess the availability of proven programs, interweave them and
    replicate comprehensive initiatives nationwide.

-   Work in partnership with other government agencies with jurisdiction
    over this issue or relevant programming to develop a comprehensive
    action plan with a strong youth component to prevent obesity in the
    United States. This will ensure that work is not being duplicated
    within the governmental system. In addition, broader questions
    remain unanswered that specific government organizations would be
    best suited to examine. For example, has the omission of physical
    education classes from the school day significantly contributed to
    obesity among children, and if so, how do we reestablish physical
    education as part of core curriculums? Further, while there is a
    great push to make after-school programs academic in nature, is it
    worth exploring a focus on health and fitness as well?

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-   Broaden the existing or spearhead the development of a new national
    working group on the prevention of obesity, to include youth
    organizations, health and medical associations, the media and
    government agencies such as the FDA, CDC, NIH, the Department of
    Education, and others. The charge for this group would be the
    creation of a national campaign to prevent obesity, (similar to the
    one so successfully used to encourage use of seatbelts).

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-   Design and implement a repository for the collection of existing
    information on obesity. The importance of capitalizing on existing
    research, tools and programs cannot be overstated. This centralized
    information source would help all stakeholders understand the
    current state of the issue, what resources are presently available
    and where information is lacking.

##### 

##### Conclusion

Girl Scouts of the USA is an organization with a broad reach (4 million
members) and a very personal connection to its membership, which makes
the task at hand that much easier. We have a longstanding commitment to
reaching every girl, everywhere, whether they live in the suburbs, in
rural areas or in public housing. Because obesity has reached epidemic
proportions in the U.S., now is time to work together to define and
implement the solution to preventing this condition before it worsens.
Girl Scouts of the USA has the program, tools, resources and capacity to
play a key role in concert with the FDA and others. We look forward to
partnering with the Obesity Working Group and hope to be a part of your
action plan towards a building a nation of healthy living.

If you have any questions, please contact Laurie A. Westley, Vice
President, Government Relations and Advocacy, 202-659-3780. Thank you
for the opportunity to share our perspective and ideas.

Respectfully submitted,

Kathy Cloninger

Chief Executive Officer

Girl Scouts of the USA

Girl Scouts of the USA

1025 Connecticut Avenue, NW, Suite 309

Washington, DC 20036

202-659-3780

November 20, 2003