From: xxxxxxxxxxxxxxxx
Sent: Tuesday, October 22, 2002 11:05 AM
To: fdadockets@oc.fda.gov
Subject: FDA Seeking Public Comment on RX advertising

 I am writing to offer my 
> comments to the US Food and Drug Administration with
> regard to the FDA's authority over "commercial speech"
> especially with regard to pharmaceutical companies'
> advertisement of prescription drugs.
>
Consumers and patients need facts and information about the efficacy of drug performance.  As a former HMO and managed care executive I have found consumers are swayed by direct to consumer marketing rather than the facts about drug effectiveness for specific health conditions. 
>
> I do not believe the pharmaceutical industry needs any
> weakening of advertising laws, as they already found
> ways to spend over $2.5 billion in direct-to-consumer
> marketing in 2000, in addition to $4 billion they spent
> on marketing to doctors (not including an additional $8
> billion in prescription freebies). If anything, the FDA should strengthen the requirements that pharmacy companies present information about clinical trial findings and  about adverse reactions to drugs in advertising, particularly TV ads. 

The pharmaceutical industry was the
> best performing sector of the US economy the last
> several years, according to Fortune Magazine, including
> a lead in every measurable growth area in 2001. 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 jacking
> up their prices at well over the rate of inflation –
> Allegra's gone up 11%, OxyContin up 15%, and Accutane up
> nearly 23%.
>
> The pharmaceutical industry is preying on its most
> vulnerable citizens: the sick, infirm, and aging, in its
> quest for profits. 

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 assist in drug company profiteering. The FDA should
> not cave into the pharmaceutical industry as was done in
> 1997, when relaxed rules on drug advertising initiated
> this steady rise in drug costs. Instead, the FDA should
> concentrate on looking out for the needs of its citizens
> and assisting federal officials in finding ways to keep
> costs down, not helping them rise further out of
> control.
> 
Sara Mason 
Lake Oswego, Oregon