Friday, December 6, 2019

FDA’s So-Called Laser Targeted Advertising is Hypocritical, and Deadly

The U.S. Food and Drug Administration for the last year has been investigating JUUL for targeting teens in their advertisements.  Then-FDA Commissioner Scott Gottlieb blamed JUUL in September 2018 for what he called an epidemic of high school vaping. 

JUUL denies it targeted teens.  Writing in TheCut on August 27, 2018,, Katie Heany noted that “Juul’s initial ad campaigns from 2015 included only models age 21 or over,” but she suggested that the company was guilty of attracting teens through the use of “splashy design, minimalist lettering, and youthful styling.” 

On the flip side of the coin, the FDA runs its own marketing program, called the “Real Cost Campaign,” with this justification: “80% of teens [don’t perceive] great risk of harm from regular e-cigarette use.  Teens understand risky behaviors, but don’t see using e-cigarettes as risky.  They have limited knowledge about e-cigarettes and need more information.  They compare e-cigarettes to other substances, with vaping seen as being among the lowest risk [here].”

The FDA introduced the term “epidemic” on September 17, 2018, to characterize teen vaping.  The word was placed in quotes by Kathy Crosby, the director of the Office of Health Communication & Education in the FDA Center for Tobacco Products, in a manner suggesting that the term was being used for effect, and wasn’t to be taken literally.  I have noted in several blog posts that no such epidemic exists. 

The FDA tested the “epidemic” language on 300 youth, finding that it “had a Perceived Effectiveness score of 4.17 out of 5.  Youth clearly understood the main message of the ad.”

The agency also tested the language on “900 young adult and adult smokers open to using e-cigarettes.”  What it found was tragic: “potential unintended consequences…perception of risk shifted to think that e-cigarettes were equally or more harmful than cigarettes…adults were less interested in using e-cigarettes to help them quit smoking.”

Let me be clear: The FDA found that its campaign would convince adult smokers that e-cigarettes were equally or more harmful than cigarettes and suppress quitting, and still the agency proceeded with its dangerous misinformation program.

The FDA argued that it could advance its campaign without harming adult smokers: “The campaign is being laser targeted to only reach youth…‘The Real Cost’ Youth E-Cigarette Prevention Campaign will be limited to age-verified digital media, limiting adult ‘spill’ by hyper-targeting the media to exclusively reach 12-to 17-year-olds on digital and social channels.” 

The irony of the FDA’s position is striking.  The agency challenges JUUL’s assertion that it is marketing only to adults, while the FDA claims its own propaganda is “laser-” or “hyper-” targeting only 12-to-17-year-olds.

How did the FDA campaign, which has been supported by other government and medical organizations, work out?  As the chart shows, pre-campaign, nearly 40% of Americans believed that e-cigarettes were safer than cigarettes in 2012.  By 2018, that number had cratered to a mere 17%.  The FDA’s laser targeting was a joke, but hundreds of thousands of smokers didn’t die laughing.

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