From: S. Dixon at OSPIRG [dixonospirg@yahoo.com]
Sent: Tuesday, September 10, 2002 8:49 PM
To: fdadockets@oc.fda.gov
Subject: Docket number 02-0209


September 10, 2002

Dockets Management Branch
United States Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville MD, 20852

RE: Docket 02N-0209

I am writing on behalf of the Oregon State Public
Interest Research Group (OSPIRG) and our 27,000
members throughout the state of Oregon to offer
comments on the US Food and Drug Administration’s
authority over "commercial speech". I am especially
concerned about the commercial speech issue as it
relates to pharmaceutical companies' advertisement of
prescription drugs. 

OSPIRG opposes any weakening of advertising laws
relating to the pharmaceutical industry.  The
pharmaceutical industry spent over $2.5 billion in
direct-to-consumer marketing in 2000, in addition to
$4 billion spent on marketing in doctors’ offices (not
including an additional $8 billion in free
prescription samples). As a result of these
promotions, the pharmaceutical industry was the best
performing sector of the US economy the last several
years, according to Fortune Magazine. Their profits
were driven largely by enormous returns on
aggressively marketed pharmaceuticals - with 34 of
these high profile drugs making up more than 50% of
the industry's skyrocketing profits. In addition to
selling to more and more consumers, drug companies are
raising their prices at well over the rate of
inflation.  One example is the prescription drug
Accutane.  The cost of Accutane skyrocketed nearly 23%
in one year largely due to the marketing efforts of
the pharmaceutical industry.  

The pharmaceutical industry is targeting our most
vulnerable citizens: the sick, infirm, and aging, in
order to expand their profit margins. The Food and
Drug Administration should maintain and improve its
role as the watchdog for what Americans consume in the
name of health, rather than facilitate drug company
profiteering. The FDA should not give in to
pharmaceutical industry pressure as was done in 1997,
when relaxed rules on drug advertising initiated this
steady rise in drug costs. Instead, the FDA should
concern itself with the needs of its citizens and
assisting federal officials in finding ways to keep
costs down.  

Please accept these as official public comments.  If
you have any questions feel free to contact me at the
number provided below.  

Sincerely,







=====
Steve Dixon
Consumer Advocate
OSPIRG
1536 SE 11th St
Portland, OR 97214
Phone-(503) 231-4181 ext. 314 
Cell-(503) 735-7499 Fax-(503) 231-4007

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