Philip Morris
Public Policy Decisions Should Be Based on Sound Social Science Research, Not Speculation or Political Motivation.
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- Wolf, M.A.
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- Aitkin, P.P.
- Altman, D.G.
- Archibald, C.
- Badger, G.J.
- Bamberger, E.
- Beltramini
- Berman, E.J.
- Burns, D.M.
- Burton, D.
- Chapman, S.
- Charlton, A.
- Costanza, M.C.
- Creten, D.
- Cummings, K.M.
- Difranza, J.R.
- Dinh, K.T.
- Doxiadis, S.A.
- Ecenbarger, W.
- Feigherty, E.
- Fischer, D.A.
- Fischer, P.M.
- Fitzgerald, B.
- Fitzgerald, U.
- Flay, B.R.
- Fletcher, C.
- Flynn, B.S.
- Freedman, A.
- Geller, B.M.
- Gilpin, E.
- Glantz, S.A.
- Goldstein, A.O.
- Gruenewald, P.J.
- Howe, H.L.
- Huang, P.P.
- Jaffe, R.D.
- Johnson, M.
- Klitzner, M.
- Klonoff, E.A.
- Krugman, D.M.
- Krumske, W., J.R.
- Leathar, D.S.
- Magnus, P.
- Mankowski, E.S.
- Mintz, M.
- Murrary, D.
- Ohagan, F.J.
- Paulman, P.M.
- Pechacek, T.
- Peterson, A.V., J.R.
- Phylactou, H.D.
- Pierce, J.P.
- Popham, W.J.
- Richards, J.W., J.R.
- Rojas, T.H.
- Rosbrook, B.
- Sarason, I.G.
- Schwartz, M.P.
- Seckerwalker, R.H.
- Shaffer, G.
- Shopland, D.
- Sosin, D.M.
- Squair, S.I.
- Surgeon General
- Taioli, E.
- Trihopoulos, D.V.
- Tye, J.B.
- Warner, K.E.
- Whalen, E.
- Wolf, M.A.
- Wolfgillespie, N.
- Worden, J.K.
- Wynder, E.L.
- Altman, D.G.
- Area
- ELLIS,CATHY/OFFICE
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- Master ID
- 2057063515/3727
Related Documents:- 2057063515-3522 Before the United States Food and Drug Administration Docket No. 95n-0253 Docket No. 95n-0253j Regulations Restricting the Sale and Distribution of Cigarettes and Smokeless Tobacco Products to Protect Children and Adolescents, Proposed Rule, Analysis Regarding FDA's Jurisdiction Over Nicotine - Containing Cigarettes and Smokeless Tobacco Products, Notice Comments of Brown & Williamson Tobacco Corporation Liggett Group Inc. Lorillard Tobacco Company Philip Morris Incorporated R.J. Reynolds Tobacco Company Tobacco Institute Inc. Volume Viii
- 2057063523-3542 Professor Timothy P. Meyer University of Wisconsin, Green Bay
- 2057063561-3563 Edward V. Morse Ph.D. Clinical Professor of Psychiatry at Lsumcno
- 2057063576-3583 Lucy Henke
- 2057063589-3595 Professor J. Stephen Thomas
- 2057063633-3636 Dr. Linda D. Goff
- 2057063645-3651 Charles F. 'rick' Houlberg
- 2057063653-3660 Paul J. Traudt, Ph.D.
- 2057063669-3673 Comments to FDA
- 2057063684-3701 Comments by W. Kip Viscusi on FDA Notice of Findings, 'regulations Restricting the Sale and Distribution of Cigarettes and Smokeless Tobacco Products to Protect Children and Adolescents: Findings of the Focus Group Testing of Brief Statements for Cigarette Advertisements,' 60 Fed. Reg. 61,670-79 (95101)
- 2057063708-3727 Bibliography of W. Kip Viscusi
- Named Organization
- American Journal of Preventive Medicine
- American Journal of Public Health
- Anti Smoking Project Group
- Br J Addict
- British Journal of Addiction
- Centers for Disease Control
- Congress
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- FDA, Food and Drug Administration
- Federal Register
- Ftc, Federal Trade Commission
- Health Education Journal
- Health Education Research
- Health Promotion
- Henke Wolf
- Il Dept of Public Health
- Intl Journal of Epidemiology
- Intl Journal of Health Education
- J Consumer Res
- J Law Econ
- J Peditar
- Journal of Advertising Research
- Journal of Business Agricultural Economi
- Journal of Communication
- Journal of Epidemiology
- Journal of Farm Economics
- Journal of Marketing
- Journal of Pediatrics
- Journal of Personality + Social Psycholo
- Journal of Public Health Policy
- Journal of School Health
- Journal of the American Medical Assn
- Journal of Verbal Learning + Behavior
- Lancet
- Med J
- Media Council of Australia
- Mmwr
- Nation
- New England Journal of Medicine
- Nida
- Nonparametric Statistics for the Behavio
- Ny State Journal of Medicine
- Ny Times
- Pediatrics
- Public Health Reports
- Readers Digest
- Rev Econ Stat
- RJR Nabisco
- RJR, R.J.Reynolds
- Tabak Journal Intl
- Univ of Il
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- Wa Post
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- Women + Health
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- American Journal of Public Health
- Date Loaded
- 17 Apr 1999
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- Camel
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Document Images
PROFESSOR MICHELLE A. WOLF
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PUBLIC POLICY DECISIONS SHOULD BE BASED ON SOUND SOCIAL SCIENCE
RESEARCH, NOT SPECULATION OR POLITICAL MOTIVATION.
The research regarding tobacco advertising and youth smoking initiation and behaviors
relied on by the FDA is fraught with flaws in research design, clarity of results, and the
conclusions that are reached. The points I am advancing here can be generalized to the
vast majority of the research that is cited in the FDA Federal Register document as
support for its argument against the tobacco industry's advertising practices and the
conclusions regarding initiation and practice of smoking behaviors.
1. Many of the sources used as references in the Federal Register are not
acceptable examples of social science research. Advertising and media
effects research should be conducted by advertising and communication
scholars and should be published iii respectable, peer-reviewed journals in
those fields.
a.
One of the problems with the literature cited in the FDA document
is that a substantial number of studies were not conducted and
published by researchers with appropriate backgrounds and
qualifications. While the absence of appropriate professional
qualifications does not automatically render the studies invalid per
se, it does serve to alert the reviewer to more critically evaluate the
rigor of the methodology and the conclusions based thereon.
William Krumske Jr. addresses the investigator biases of much of
this research. He points out that these investigators begin their
research with an"abhorrence of tobacco smoking and their collective
desire to protect, at any cost and by all means, all people, especially
the young, from tobacco smoking" (p. 2). Krumske states that
another investigator bias in this research concerns specific tobacco
industry marketing objectives. He contends that the mission of such
research is "to demonstrate that unintended audiences are exposed
to advertising which, to some degree, influences them" (p. 2).
Examples of researchers without appropriate advertising/consumer
behavior qualifications follow.
(1)
Fischer, Paul M., Schwartz, Meyer P., Richards, John W. Jr.,
Goldstein, Adam O. & Rojas, Tina H. (1991). Brand Logo
Recognition by Children Aged 3 to 6 Years. Mickey Mouse
and Old Joe the Camel. Journal of the American Medical
Association, 266(22), 3145-3148.
FISCHER, SCHWARTZ, RICHARDS, AND GOLDSTEIN ALL
IDENTIFY THEMSELVES AS MEDICAL DOCTORS.
(2) Pierce, J.P., Gilpin E., Burns, D.M., Whalen, E., Rosbrook, B.
Shopland, D., & Johnson, M. (1991). Does Tobacco
Advertising Target Young People to Start Smoking? Evidence
From California. Journal of American Medical Association.
266(22), 3154-3158.
JOHN P. PIERCE IS A PH.D. DAVID M. BURNS IS A MEDICAL
DOCTOR. ELIZABETH WHALEN HAS AN MA AND BRADLEY
ROSBROOK HAS AN MS. DONALD SHOPLAND WORKS AT THE
NATIONAL CANCER INSTTTVI'E IN MARYLAND AND MICHAEL
JOHNSON IS A MEDICAL DOCTOR.
Goldstein, A.O., Fischer, P.M. Richards, J.W., Jr. & Creten,
D. (1987). Relationship Between High School Student
Smoking and Recognition of Cigarette Advertisements. The
Journal of Pediatrics, 110(3), 488-491.
ADAM O. GOLDSTEIN HAS A BA, PAUL M. FISCHER AND
JOHN W. RICHARDS ARE MEDICAL DOCTORS, AND DEBORAH
CRETEN HAS ONLY A BA.
(4) Chapman, S. & Fitzgerald, U. (1982). Brand Preference and
Advertising Recall In Adolescent Smokers: Some Implications
For Health Promotion. American Journal of Public Health,
72(5), 491-494.
SIMON CHAPMAN IS THE COORDINATOR OF THE ANTI-
SMOKING PROJECT GROUP IN NEw SOUTH WALES AND A
LECTiTRER IN THE DEPARTMENT OF PREVENTATIVE AND
SOCIAL MEDICINE AT THE UNIVERSITY OF SYDNEY,
AUSTRALIA AND BILL FITZGERALD IS A STATISTICIAN AT THE
UNIVERSITY OF SYDNEY.
Huang, P.P., Burton, D., Howe, H.L. & Sosin, D.M. (1992).
Black-White Differences in Appeal of Cigarette
Advertisements Among Adolescents. Tobacco Control, 1, 249-
255.
PHILIP P. HUANG AND DANIEL M. SOSIN WORK FOR THE
DIVISION OF FIELD EPIDEMIOLOGY AT THE CENTER FOR
DISEASE CONTROL IN ATLANTA GEORGIA. DEE BURTON ~
WORKS FOR THE PREVENTION RESEARCH CENTER AT THE ~
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UNIVERSITY OF ILLINOIS, SCHOOL OF PUBLIC HEALTH,
CHICAGO, ILLINOIS. H.L, HowE IS WITH THE ILLINOIS
DEPARTMENT OF PUBLIC HEALTH IN SPRINGFIELD, ILLINOIS.
Even a casual glance raises the question of why medical
doctors and public health officials are publishing studies
about advertising. It is especially curious that almost all of
these authors onIV publish articles about a single kind of
advertising -- that for cigarettes.
b. Another problem with the literature cited in the FDA proposal is
that a substantial number of the studies are published in journals
that focus on medical -- not youth and/or tobacco advertising --
research. Moreover, a great number of these studies have nothing
to do with the relationship between tobacco advertising and the
initiation of youth smoking behaviors.
(1) Tye, J.B., Warner, K.E. & Glantz, S.A. (1987). Tobacco
Advertising and Consumption: Evidence of a Causal
Relationship. Journal of Public Health Policy, 8(4), 492-508.
(2) Aitkin, P.P., Leathar, D.S., O'Hagan, F.J. & Squair, S.I.
(1987). Children's Awareness of Cigarette Advertisements
and Brand Imagery. British Journal of Addiction, 82, 615-
622.
(3) Chapman, S. & Fitzgerald, B. (1982). Brand Preference and
Advertising Recall In Adolescent Smokers: Some Implications
for Health Promotion. American Journal of Public Health,
72(5), 491-494.
(4) Charlton, A. (1986). Children's Advertisement-Awareness
Related to Their Views On Smoking. Health Education
Journal, 45(2), 75-78.
(5)
DiFranza, J.R., Richards, J.W., Paulman, P.M., Wolf=
Gillespie, N., Fletcher, C., Jaffe, R.D., and Murrary, D.
(1991). RJR Nabisco's Cartoon Camel Promotes Camel
Cigarettes to Children, Journal of the American Medical
Association, 266(22), 3168-3173.
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(6) Fischer, D.A. & Magnus, P. (1981). "Out of the Mouths of
Babes...": The Opinions of 10 and 11 Year Old Children
Regarding the Advertising of Cigarettes. Community Health
Studies. 5(1), 22-26. [Australian study]
(7) Fischer, P.M., Richards Jr., J.W., Berman, E.J., & Krugman,
D.M. (1989). Recall and Eye Tracking Study of Adolescents
Viewing of Tobacco Advertisements. Journal of the
American Medical Association, 261(1), 8489.
(8) Fischer, P.M. Schwartz, M.P., Richards, J.W., Goldstein, A.O.
& Rojas, T.H. (1991). Brand Logo Recognition by Children
Aged 3 to 6 Years: Mickey Mouse and Old Joe Camel.
Journal of the American Medical Association, 266(22), 3145-
3148.
(9)
Goldstein, A.O., Fischer, P.M., Richards, J.W., Jr. & Creten,
D. (1986). Relationship Between High School Student
Smoking and Recognition of Cigarette Advertisements. The
Journal of Pediatrics, 110(3), 488-491.
(10) Huang, P.P. Burton, D., Howe, H.L. & Sosin, D.M. (1992).
Black-White Differences in Appeal of Cigarette
Advertisements Among Adolescents. Tobacco Control, 1, 249-
255.
(11) Klitzner, M., Gruenewald, P.J. & Bamberger, E. (1991).
Cigarette Advertising and Adolescent Experimentation With
Smoking. British Journal of Addiction, 86, 287-298.
(12) Pierce, J.P., Gilpin, E., Burns, D.M., Whalen, E., Rosbrook,
B., Shopland, D., Johnson M. (1991). Does Tobacco
Advertising Target Young People to Start Smoking?
Evidence From California, Journal of the American Medical
Association, 266(22), 3154-3158.
(13) Tye, J.B., Warner, K.E. & Glantz, S.A. (1987). Tobacco
Advertising and Consumption: Evidence of a Causal
Relationship. Journal of Public Health Policy, 8(4), 492-508.
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(14) Sarason, I.G., Mankowski, E.S., Peterson, Jr., A.V. & Dinh,
K. T. (1992). Adolescents' Reasons for Smoldng. Journal of
School Health, 62(5), 185-190.
(15) DiFranza, J.R. & Tye, J.B. (1990). Who Profits From
Tobacco Sales to Children? Journal of the American Medical
Association, 263(20), 2784-2787.
(16)
Taioli, E. & Wynder, E.L. (1991). Effect of the Age at Which
Smoking Begins on Frequency of Smoking in Adulthood. The
New England Journal of Medicine, 325(13), 968-969.
Cummings, K.M., Pechacek, T. & Shopland, D. (1994). The
Illegal Sale of Cigarettes to U.S. Minors: Estimates by State.
American Journal of Public Health, 84(2), 300-302.
(18) Feigherty, E., Altman, D.G. & Shaffer, G. (1991). The Effects
of Combining Education and Enforcement to Reduce
Tobacco Sales to Minors. Journal of the American Medical
Association, 266(22), 3168-3171.
(19) Klonoff, E.A., et al. (1994). The Problem and Sociocultural
Context of Single-Cigarette Sales. Journal of the American
Medical Association, 271(8), 618-620.
(20) Popham, W.J., et al. (1993). Do Anti-Smoking Media
Campaigns Help Smokers to Quit? Public Health Reports,
108, 510-513.
(21) Popham, W.J., et al. (1994). Effectiveness of the California
1990-1991 Tobacco Education Media Campaign. American
~ Journal of Preventative Medicine. [in press]
(22) Flay, B.R. (1987). Mass Media and Smoking Cessation: A
Critical Review. American Journal of Public Health, 77, 153-
160.
(23) Flynn, B.S., et al. (1994). Mass Media and School
Interventions for Cigarette Smoking Prevention: Effects Two
Years After Completion, American Journal of Public Health,
84 1148-1150.
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(24) Flynn, B.S., Worden, J.K., Seeker-Walker, R.H., Badger, G.J.,
Geller, B.M., Costanza, M.C. (1992). Prevention of Cigarette
Smoking Through Mass Media Intervention and School
Programs. American Journal of Public Health, 82, 827-834.
Although the mere act of publishing advertising research in
medical/health related journals does not, in and of itself, completely
discredit the research, it is a signal to the reader to be alert to
evaluate the methodology, conclusions and, perhaps, the motivation
for the research.
c. A third problem with the literature cited in the FDA proposal is that
some of this literature merely consists of critical essays and reviews
-- not reports of social science research.
0
(1) Washin on Post (1995, January 9). p. A5, col. 3.
(2) Freedman, A. (1994, October 26). How a Tobacco Giant
Doctors Snuff Brands to Boost Their 'Kick.' [sic] Wall Street
Journal, p. A14, col. 5.
(3) Wall Street Journal (1990, May 3). p. Bl, col. 3.
.(4) Wall Street Journal (1989, October 19). p. B i.
(5) Wall Street Journal (1994, December 27). p. B5.
(6) The New York Times (1984, January 13). p. D4, col. 5.
(7) Ecenbarger, W. (1993). America's New Merchants of Death.
Reader's Digest,142(852), 50-57.
~
(8) Mintz, M. (1991). Marketing Tobacco to Children, The
Nation, 252 (17), 577.
(9) Archibald, C. (1993). Sale of Individual Cigarettes: A New
Development. Letters to the Editor, Pediatrics, 91(4), 851.
(10) Doxiadis, S.A., Trihopoulos, D.V. & Phylactou, H.D. (1985).
Impact of a Nationwide Anti-Smoking Campaign. The Lancet,
pp. 712-713.
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d. A fourth problem with the literature cited in the document concerns
the apparent reliance on a number of government documents.
These documents do not constitute primary social science research.
Moreover, many of these documents do not even focus on areas of
consideration and analysis that are relevant to issues surrounding
relationships between tobacco advertising and youth consumption of
tobacco products. In general, government documents are not
regarded as original contributions to research. Rather than examine
the original research scientifically, these reports often make mere
conclusory references, many of which are based on third-party
accounts of the original studies. Often, the findings of original
research are camouflaged. For example, frequent research
references are made to the 1994 Surgeon General's Report. In this
document, research findings are mischaracterized and important
points are omitted from research results and conclusions drawn
because they do not support the points that are being advanced.
In fact, of the 108 studies cited in Subpart D of the Federal Register
document, only a single study -- the research of Beltramini (1988) --
meets the necessary criteria established above in that it: (1)
addresses the appropriate subject matter (specific cigarette
advertising related issues and youth smoking behaviors), (2) is
published by an advertising or communication scholar in (3) a
respectable, peer-reviewed journal in the field of advertising or
communication.
2. Several additional problems emerge from a careful study of the research
relied on by the FDA in the Federal Register.
a. Problem statements are biased.
b. Unwarranted generalizations are advanced.
c. Conclusions drawn are not justified by results or findings.
d. Researchers do not - and cannot - answer the questions that
they ask.
The weaknesses noted above can be found throughout the research cited in
the FDA Register in support of the proposed regulations regarding tobacco
advertising. To illustrate these problems, I have selected four examples of
cited studies which illustrate these problems. In the following pages, the
7
research objectives, methods, results, and conclusions (which are often,
quite different from the results) are summarized and evaluated.
(1) Fischer, P.M., Schwartz, M.P., Richards, J.W., Goldstein,
A.O., & Rojas, T.H. (1991). Brand Logo Recognition by
Children Aged 3 to 6 Years: Mickey Mouse and Old Joe the
Camel. Journal of the American Medical Association,
266(22), 3145-3148.
The objective here was to measure product logo recognition by
subjects aged 3 to 6 years. It is important to recognize at the onset
that logo recognition has nothing to do with intent to smoke or
smoking behaviors. The authors used a convenience sample of 229
children attending 10 preschools in Augusta and Atlanta, Georgia; it
was balanced for race and Socio Economic Status (SES), and
included ages 3 to 6 years. Notably, this sample is not generalizable.
Subjects matched 22 logo cards to one of 12 products pictured on a
game board. Each of 12 products was named, and there was a
demonstration of matching with a sample logo card. Subject
responses were graded as correct or incorrect. The authors found a
high recognition rate ranging from 91.7% for The Disney Channel to
25.3% for Cheerios. Joe Camel had the highest (over 50%)
recognition rate among cigarette logos. Other cigarette logos were
correctly recognized at a rate of 18.0% to 32.8%. Logos for adult
products were recognized by 16.2% to 54.1% of the sample, with
automobile brand logos having the highest rate. Three-year-olds
recognized Camel at a rate of 11.1% and Joe Camel at 30.4%. Six-
year-olds recognized Camel at a rate of 43.5% and Joe Camel at
91.3%. Logo recognition was found to be highly associated with age.
Race and gender were not associated with the scores.
It is not at all surprising that logo recognition is highly associated
with age. Children recognize brand logos for many different
products. However, recognition and recall are not the causes of
consumer behavior; consumer decision factors are. The influence of
peers and family, along with such factors as past experience, lifestyle,
social class, and culture, have been shown to be very important
influences.
The study has several limitations. First, the authors used a
convenience sample. It is unknown how the sampling method might ~
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have influenced results. Other problems include the reliance on the
ability of children to match the logo cards and the arbitrariness of
the selection of specific logos.
In fact, the authors themselves conclude: "It is obviously impossible
to predict how the exposure of children to environmental tobacco
advertising might influence their later smoking behavior. .."
Nevertheless, the authors go on to conclude "cigarette advertising
may be an important health risk for children" (p. 3148). Despite
acknowledging that this research does not establish any connection
between logo recognition and smoking, the authors wrongly conclude
cigarette advertising "may" be a risk. In fact, my own very recent
research provides evidence that Joe Camel, while well recognized,
symbolizes a product that children say is for adults and is bad for
you (see Henke & Wolf, 1995).
Beyond this, the researchers 'fail to consider other factors that affect
"recognition." The Disney logo looks like a mouse, and matching it
to a picture of Mickey Mouse might not demonstrate product
recognition any more than matching any similar shapes, colors or
objects would. The recognizability of Joe Camel might well be a
routine outcome of any high visibility campaign. Most important is
the fact that brand (character) recognizability has not been shown to
determine smoking behavior. The researchers apparently assume,
without benefit of supporting data, that brand awareness in
childhood not only influences adult brand preferences but, indeed,
causes consumption. That proposition is hardly tested here.
The conclusion on p. 3148 that "RJ Reynolds ... is as effective as The
Disney Channel in reaching 6-year-old children" is misleading. The
conclusion is severely limited by, among other things, the
researcher's narrow operationalization of "effectiveness," which is
measured as the ability to match product logos with generic graphics
(i.e., "effective" simply equals "recognition"). Measuring that ability
is a far cry from measuring more complex cognitive and behavioral
impacts.
Finally, a total of 22 references are cited to support the foundation
for this research. T'ne publications listed (in the exact citation form
used by the authors) include: J Law Econ, Rev Econ Stat, J Peditar
Am J Public Health, Br J Addict (2 citations), Health Promotion,
Med J, N Eng J Med (2 citations), MMWR, Surgeon General,
9
Reducin
the Health Consequences of Smokina: 25 Years of
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Progress: A Report of The Surgeon General, J Public Health Policy,
J Advertising Res, Curr Issues Res Advertisin~, Nonparametric
Statistics for the Behavioral Sciences, Children as Consumers
J Consumer Res (2 citations), Health Educ J, and World Smoking
Health. Given the fact that the research concerns brand logo
recognition and advertising, the overwhelming citation of research
from medical sources is irresponsible.
In short, the researchers' conclusion that cigarette advertising is a
pediatric health risk is not substantively or rigorously supported by
their data.
(2) Aitkin, P.P., Leathar, D.S. & Squair, S.I. (1986). Children's
Awareness of Cigarette Brand Sponsorship of Sports and Games in
the UK. Health Education Research, 1(3), 203-211.
The stated objective here was to explore children's awareness of
cigarette brand sponsorship of sporting events in the UK. The
authors begin by assuming, as stated in the introduction, that "under-
age smokers are deriving some benefit from cigarette
advertisements" (p. 203). This is based on findings (here the authors
refer to research that is also problematic) that "under-age smokers
tend to have more positive attitudes towards cigarette advertising
than do non-smokers of the same age" (p. 203) and that "under-age
smokers tend to rate cigarette advertisements more highly on rating
scales describing attractive qualities (e.g., exciting eye-catching) than
do non-smokers of the same age"(p. 203). It is important to point
out that neither the notion that youth can identify brand imagery nor
the assumption that they (presumably) have more positive attitudes
towards cigarette ads is indicative of any "benefit" in the sense of
showing that ads contribute to decisions to initiate smoking behaviors.
In fact, on page 204 the authors themselves write: 'This of course
does not necessarily mean that cigarette advertising plays a part in
inducing children to start smoking." Nevertheless, they go on to
contend that it "suggests that attitudes towards cigarette advertising .
may play a part in the transition from non-smoker to smoker." This
contention is not supported by the research.
The sample included 726 primary and secondary school children
between the ages of 6-17 years in Glasgow, Scotland. There were
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