Docket Management
Docket: 02N-0209 - Request for Comment on First Amendment Issues
Comment Number: EC -412

Accepted - Volume 6

Comment Record
Commentor Ms. Robin Moore Date/Time 2002-09-12 13:22:03
Organization Ms. Robin Moore
Category Individual

Comments for FDA General
Questions
8. Do FDA's speech-related regulations advance the public health concerns they are designed to address? Are there other alternative approaches that FDA could pursue to accomplish those objectives with fewer restrictions on speech? The FDA's position should be that public health takes priority over commercial speech considerations, and the agency should do everything it can to defend its authority to restrict commercial speech in the effort to protect public health.
9. Are there any regulations, guidance, policies, and practices FDA should change, in light of governing First Amendment authority? Overly broad commercial speech protections will inappropriately transform legislative or regulatory decisions about public health issues into constitutional issues.




EC -412