From: Lin Kaatz Chary [lchary@uic.edu]
Sent: Monday, September 09, 2002 4:48 PM
To: FDA Chief Counsel Daniel Troy
Subject: RE: FDA Docket # 02N-0209

Lin Kaatz Chary
7726 Locust Avenue
Gary, IN 46403


September 9, 2002

FDA Chief Counsel Daniel Troy

,   


Dear FDA Chief Counsel Troy:

On behalf of US children, including in my own family, I urge you to 
implement stronger regulation of commercial advertising aimed at children.

Arguments that stronger regulation would represent a limitation on free 
speech miss the point. Many parents already significantly censor what 
their children are exposed to on TV, in the movies, and in other media.  
Making choices on behalf of our children's well-being is our 
responsibility, and our obligation, and is in no way an abridgement of any 
corporate efforts to sell their product.

This responsibility and obligation MUST extend to the FDA in its role as 
the collective representative of the interests of the public in the 
marketplace, particularly and ESPECIALLY with regard to those most 
vulnerable members of the public, our children.  Children have no choice 
but to rely on the judgement and guidance of adults in positions of power. 
 Surely it is the highest calling and purpose of an agency such as the FDA 
to exercise its judgement and public powers on behalf of the children with 
whose safety it is charged.

I am repeatedly dismayed and disgusted by the pathetic level to which 
current advertising efforts have degenerated, but as an adult I am able to 
distinguish between advertising and reality, and to take responsibility 
for my own choices.  Children, especially very young children, on the 
other hand, are not able to distinguish clearly between the program they 
are watching and the advertisements, which are very purposefully designed 
to further blur the difference.  Children take everything at face value, 
are taught to believe adults, and are very influenced by images of other 
children having fun in the context of advertising.  This places a heavy 
responsiblity on all of us to carefully consider and monitor the content 
and form of those messages, and this is by definition the role of the FDA 
in the public arena.

Yes, parents could and should monitor their childrens' TV viewing. But 
there are some fine children's programs on commercial TV, and it is hardly 
realistic to expect parents to be there throughout every program with 
remote control in hand to edit the commercials! And to prevent children 
from watching TV at all is an example of the old adage of "throwing the 
baby out with the bath water."  

Moreover, the content of children's TV viewing is already regulated to 
some extent.  No one would even consider airing programs which glorify 
heroin use or alcoholism, or child abuse or rape.  But advertisers have no 
compunction in raping our childrens' minds by quite cynically exploiting 
their inability to make reasoned judgements and choices about what they 
are seeing.
 
The average US child sees more than 40,000 advertisements a year on TV 
alone, and food commercials account for most TV advertising during 
children's peak viewing hours. (On Saturday mornings, children see one 
food commercial about every five minutes.)  It is no wonder that childhood 
obesity, diabetes, and eating disorders (all serious public health issues 
for our kids) are linked to children's reaction to food advertising. From 
1992 to 1999 the amount spent marketing to children shot from $6.2 billion 
to $12 billion. As a public health professional, there is no question in 
my mind that it is time for FDA to be much more assertive in regulating 
marketing aimed at children. 

Such regulation poses no real threat to freedom to do business. We are 
still the biggest capitalist economy in the world. Nonetheless, we have 
numerous laws relating to environmental protection, product safety, 
highway safety, and so forth because we  expect those corporate interests 
involved to operate without blatantly threatening our health and 
well-being,and we expect our federal agencies to enforce that regulatory 
agenda.

It's time to adopt the same attitude with the marketers who dump toxic 
messages and products into the stream of US childhood. It is past time 
that we hold advertisers accountable for their commercial exploitation of 
children. 

Please advise me what the FDA will do.



Sincerely,


Dr. Lin Kaatz Chary