APA Comments on Proposed Tobacco Regulation
Several divisions contributed material to the comments, which were drafted by Ellen Greenberg Garrison, PhD. Dr. Garrison, working as a consultant to PPO, sought a range of views and expertise from the APA scientific membership and circulated the comments widely for review. The result, according to William C. Howell, PhD, APA Executive Director for Science, is 'a very solid, data-based paper that illustrates the depth and breadth of psychological knowledge about why young people start using tobacco products, the roles of tobacco advertising and promotion, and the types of interventions that might be successful. These comments will be very useful to the FDA.'
The FDA published its proposed regulation on August 11, 1995, and asked for public comments. The proposed regulation would establish FDA's authority to regulate tobacco products, which the agency has not previously asserted. Advertising and promotion of tobacco products to minors would be restricted, and vending machine sales of cigarettes would also be outlawed. The proposed regulation also calls for tobacco companies to fund a public education campaign encouraging young people not to use tobacco and asks for suggestions about what such a campaign should include. The goal of the regulation is to reduce, by 50% over 7 years, the number of minors who use tobacco products.
The APA comments stress the importance of enforcement to reducing the purchase of tobacco products by minors. All states have laws prohibiting the sale of tobacco to minors, but the laws are enforced erratically at best. Several studies have shown that reductions in youth access to tobacco are associated with a reduction in tobacco use by minors. In addition, a number of studies evaluate the effectiveness of various interventions to end sales of tobacco products to minors. According to the APA comments, it is only when educational approaches are combined with routine enforcement of laws prohibiting the sale of tobacco products to minors that sustained reductions in minors' access to tobacco are achieved.
The APA comments cite studies showing that children and youth are indeed exposed to a considerable amount of tobacco promotion and advertising and that reducing their exposure to advertising and promotions impedes persuasion. The APA comments also cite psychological studies on desirable and undesirable aspects of public education campaigns.
'Ellen Garrison did a tremendous job incorporating all the division comments and seeking out experts for their opinions,' said Dr. Howell. Among the contributors and reviewers were Robert Cialdini, PhD, Anthony Biglan, PhD, Leonard Jason, PhD, Connie Pechmann, PhD, Ron Wood, PhD, Saul Shiffman, PhD, Robert Balster, PhD, Lloyd Johnston, PhD, Brian Gibson, PhD, Paula Skedsvold, PhD, Robert Kaplan, PhD, and Ken Perkins, PhD.
Pat Kobor, Director of Science Policy in APA's Public Policy Office, said, 'The divisions should be credited for insisting that APA take a leadership role on this issue and ensuring that APA's comments are strong, to the point, and scientifically sound. This effort demonstrates how effectively psychological research can inform the policy process. From psychopharmacology, to consumer studies, to basic social psychology, to applied prevention research, psychologists have tremendous expertise that the FDA needs in order to promulgate a sound public policy.'
The APA comments to the FDA will be posted on the PPO Web page. Follow the menu to the PPO's Science Advocacy page.