Ellen Goodman did readers and parents a disservice when she sarcastically ridiculed The Tobacco Institute's major new initiatives to discourage youth smoking {op-ed, Dec. 18}.

Our proposals not only make sense, they are solid, practical steps taken by those who sell an adult product to help prevent youngsters from buying that product. The tobacco industry is working with retailers across the country to observe and enforce state laws prohibiting cigarette sales to young people. We support new state legislation setting 18 as the minimum age for cigarette sales and new laws requiring supervision of vending machines in places where youngsters are likely to frequent. We now sharply limit free distribution of product samples in public places and require billboards with our ads to be 500 feet from schools and playgrounds. We also offer parents of adolescents a free guidebook, ''Tobacco: Helping Youth Say No.''

The solutions Ellen Goodman advocates -- such as banning advertising, promotions and vending machines -- are a prescription for failure. Sixteen countries that have banned or severely restricted cigarette advertising have not experienced a drop in smoking as a result. And most of the vending machines she wants to ban (an estimated eight out of 10) are located where children are not allowed or are unlikely to be found, such as taverns, factories and offices.

There are a great many things we as a society believe should be reserved for adults. Getting married, voting, entering into a legal contract and military service are all decisions that belong in the same category as smoking -- they are choices our society reserves for adults. WALKER MERRYMAN Vice President and Director of Communications The Tobacco Institute Washington