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.
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- 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
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- FDA, Food and Drug Administration
- Federal Register
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- 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
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- 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
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- Wa Post
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- American Journal of Public Health
- Date Loaded
- 17 Apr 1999
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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
0
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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approximately equal numbers of males and females at each of six
age levels (6-7, 8-9, 10-11, 12-13, 14-15, 16-17).
Based on their findings, the researchers report that a majority of
children between the ages of 6 to-17 years have some understanding
of sponsorship by late primary/secondary years. A third of the 10-11
year-olds and over half of the secondary school children sampled
were able to name cigarette brands and sponsored sports. Of the
primary school children, 47% pointed to sponsored brands as being
liked by someone who likes excitement and fast racing cars. The
authors argue that "associations between brand names or visual cues
and exciting sports can be elicited [by simple advertisements] in
0 children who did not have a critical awareness of the- purpose of
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commercial sponsorship" (p. 209). No significant differences
between smokers and non-smokers in awareness of brand
sponsorship were found.
It should be made clear that suggesting that advertising factors might
be associated is not equivalent to demonstrating that they are
causally linked. Approval of ads is not necessarily related to the
initiation or continuation of smoking behavior. Moreover, the
authors argue that linkages/associations between brand names (or
their visual cues) and exciting sports are often unconscious. This,
however, was merely observed at the level of recognition or recall,
suggesting a low involvement model.
The researchers report that sponsorship is a form of promotion,
treating this obvious fact as if it were some sort of discovery. Of
course sponsorship is perceived to have economic benefit; if it did
not, companies presumably would not bother to engage in the
practice. The fact that children also understand this concept is an
indicator of their cognitive/perceptual capacity; it is not an indicator
of the persuasive capacity of sponsorship messages per se, nor is it
proof that such messages either target children specifically or
purposely promote consumption amongst children.
The researchers want to argue - inappropriately and without
sufficient evidence - that recognition indicates a host of other
impacts, including imitation, persuasion, consumption, and the like.
The authors cite 20 references for their research. Not one of these
is an acceptable publication, based on the criteria established earlier o
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in this statement. The sources cited include the following: Ten to
Fourteen-Year-Olds and Alcohol, British Journal of Social and
Clinical Psycholo&, Social Science and Medicine, Health Education
Journal (3 citations), British Journal of Addiction, Journal of
Epidemiology, Appendix H of the British Code of Advertising
Practice, The Young Smoker, Cigarette Advertising & Smoking: A
Rev_iew of Evidence, American Journal of Public Health, Teenag_ers
0 and Alcohol, a Department of Health and Social Services document
entitled Smoking Among Secondary School Children: A Survey of
Prevalence, Consumption, Attitudes, and Knowled~e, Community
Health Studies, Health Education and the Media, Football Targe, ting
Research: Summary Report, Smoking Attitudes and Behavior,
International Journal of Epidemiology, and Health Education
Research.
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In short, the authors found that children are aware of
advertisements and brands. Recognition and recall were assessed;
these have nothing to do with advertising impact or the decision to
initiate smoking behaviors.
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.
As part of an anti-smoking school education program, the goal of
this research (published in a relatively brief form of less than four
pages) was to study brand preference and ad recall in 1,195 seventh
and eighth grade adolescents in Australia. There were three
hypotheses: (1) outstanding patterns of brand preference would be
found in the sample, (2) smokers would be more familiar with
cigarette ads than non-smokers, and (3) the ads most familiar to
smokers would be for the brands most smoked.
The authors point out that of 30 secondary schools randomly
selected from a list of all schools in the Sydney area, only 19 agreed
to run the educational program in 1980. They write: "any
conclusions arising from the study may not warrant generalization to
school children at large, but to children in schools with teachers
interested in running such a program" (p. 491).
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Brand preference was cross tabulated with data from three questions
that discriminated between light, medium and heavy smoking.
Subjects were presented with photographs of eight print media
cigarette advertisements that had been edited to remove all
identifying writing. Advertisements for five heavily advertised brands
and three less frequently advertised brands were used to test
identification. Slogans were edited and presented in different orders
to the edited photos to form slogan completion exercises.
Four of more than 130 brands then retailed in Australia accounted
for cigarettes smoked by 78.9% of the smokers. Brand preferences
reflected those of adult smokers in Sydney found in another survey
0 taken three months later, but were different in proportion (chiefly
due to a much greater proportion of children who smoked Winfield).
Winfield smokers had a significantly greater proportion of heavy
smokers. Smokers claiming no brand preference were more likely to
be light, infrequent smokers. Smokers were nearly twice as likely to
correctly identify edited cigarette ads and slogans. Brand preference
was considered to be an important descriptor of smoking profiles.
While the researchers concluded that tobacco ads are instructively
seen as cues to smoking behavior, in fact what they tested was the
ability of their subjects to perform recall tasks. They concluded that,
since young smokers who smoke "any" brand tend more toward the
light-medium range of smoking rates than do smokers who are
brand loyal, part of the "career" of becoming a smoker is to adopt a
preferred brand. The conclusion/belief that ads are cues to behavior
is not supported by this research.
Only five sources were cited by the researchers. Again, none of the
references came from an acceptable publication, based on the
criteria established earlier in this statement. The sources cited are:
Media Council of Australia: Voluntary Advertising Code For
Cigarettes in Australia, British Medical Journal, Consumer Beliefs
and Behavior With Respect to Smoking: A Critical Analysis of the
Public Literature (a report prepared for the FTC), Journal of
Personality and Social Psychology, and International Journal of
Health Education.
This study suggests a rather obvious point: Those who consume a
product are more likely to be aware of advertising for that product.
School children appear no different from adults in this regard. i~
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However, it should be emphasized that while children who already
smoke are attentive to cigarette advertising, it cannot be argued that
cigarette advertising is a causal factor in the initiation of smoking.
(4) Klitzner, M., Gruenewald, P.J. & Bamberger, E. (1991). Cigarette
Advertising and Adolescent Experimentation With Smoking. British
Journal of Addiction, 86, 287-298.
The authors state at the onset that their goal is to clarify the
relationships between measures of the effects of advertising exposure
derived from a cognitive advertising exposure model and youthful
experimentation with cigarettes.
The authors state two assumptions: (1) Experimentation with
cigarettes would prompt subjects to attend to and retain information
from cigarette ads (a selective exposure effect), and (2) Exposure to
the ads themselves, mediated by the depth to which information
from ads was processed, would prompt subjects to experiment with
cigarettes (an effect of ad exposure).
The sample included 295 adolescent subjects from three separate
school districts in an east coast urban/suburban area. The grade
strata included 5th and 6th, 7th-9th, and 10th-12th grades. Equal
numbers males and females were sampled. The sample ethnic
distribution included 25% black, 66% white, and 9% other
(Hispanic/Asian). The subjects were from highly-educated families;
79% had a father and 60% had a mother with a college education.
A total of 41% of the subjects had smoked at some point; 47%
considered themselves to be smokers, and 27% smoked every day.
Most began smoking in the 7th grade (29%). The 4% non-smokers
believed they would begin smoking in 3-5 years.
Advertisements from 37 general U.S. magazines, 2 major
newspapers, and 5 youth readership magazines, covering a six-month
time period from March to August 1987, were used. One issue per
month of each magazine, and one issue per month of both
newspapers, were used. The sampling universe consisted of 650
unduplicated ads (217 cigarette, 230 alcohol, 203 perfume).
Individual interviews in November-December 1987 were conducted
by trained field staff. Four prompt cards listing possible choices of
product and brand were used during the presentation of ad stimuli ~
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in each interview. The first listed the three generic products for a
product recognition task. The remaining three prompt cards, one
for each product, listed a choice of brands. Each card listed 20
possible choices. The 60 ads comprising each of the stimulus sets
were presented sequentially in a manner that was counterbalanced,
for order and stimulus set effects across subjects. Due to their
considerable inattention to ads presented later in the task, 5th and
6th graders were presented with half of the 60 stimuli.
The subjects were asked to identify magazine and newspaper ads for
cigarettes, alcohol and perfumes from which product brand
identification information was removed. Alcohol and perfume ads
served as distractors. For each ad presented, subjects were asked:
(1) whether they had seen the ad before, (2) which of the three
generic products (cigarettes, alcoholic beverages, perfumes or
colognes) they thought the ad was for, and (3) which brand of the
identified product they thought the ad was for. Brand choice was
requested whether or not product choice was correct. Demographic
and smoking behavior data were also collected.
Data were also collected on total exposure to magazines and
newspapers (Exposure Opportunity measure). Total Magazine
Exposure was assessed by subjects' responses to a checklist on which
they were to indicate whether they had ever seen, looked at
occasionally, or read regularly each magazine listed. Subjects were
also asked how many other unlisted magazines they used.
In general the research as designed was thoroughly unlike the actual
experience of reading magazines and newspapers. The use of
alcohol and perfume ads to serve as distractors, in particular, is also
very different from the actual real experience of advertisement
exposure in the practice of reading magazines and newspapers.
~ The researchers found that their subjects had substantial previous
exposure to the ad stimuli. Using environmental and psychological
measures of advertising exposure, they contend that they
demonstrated that adolescents who experimented with cigarettes
were better able to recognize advertised products. Conversely, they
say, those who could better recognize advertised brands were more
likely to have experimented with cigarettes, an effect which they
concluded was due to their exposure to cigarette advertising [emphasis
is mine]. The authors contend that the size of the effect of ~
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advertisements on smoking is mediated by depth of cognitive
processing. For the ads that did affect brand recognition rates at
the mean level of observed recognition in their study, they argue
that a substantial effect may be observed.
The authors, themselves, point out: "In any cross-sectional study it is
impossible to directly test the causal relationships between any set of
variables. The temporal information necessary to establish
antecedent causes is not available." They add that they can, however,
determine the consistency of variables within their causal model, and
that in their study such consistency was achieved.
The authors conclude that their results supported "both of the
arguments put forth in the Introduction" (p. 296) While they use the
word "arguments" here, they are actually talking about the
unsupported assumptions advanced in their introduction. They
contend that experimentation does affect the extent to which
individuals recognize information presented in cigarette ads
(selective exposure effect). With increased depths of processing,
they say, it appears that exposure to smoking ads does affect the
likelihood that young people will smoke. 'That is, young people who
retain more information from cigarette ads than others, for whatever
reason, appear more likely to express an interest in smoking through
their experimentation with cigarettes. In particular, young people
who retain more brand-related information from cigarette
advertisements are most at risk for smoking experimentation"
(p. 296).
As the authors themselves point out, the results of this study must
be considered within the context of several limitations: (1) Inferring
causality from correlational data is risky; if there is causality it may
run in the opposite direction. (2) The statistical instrument used to
represent smoking in the 2SLS analyses was not optimal. (3) The
measure of ad exposure was not contemporaneous with incidents of
subjects' experimentation with smoking. Experimentation might
have occurred years before participation in the study. Any ads used
would not be those to which these subjects were exposed at the time
of the onset of any smoking behaviors.
The authors conclude that: 'The results show that the association
between exposure to advertising and consumption is complex, at
least for cigarette smoking among adolescents. Rather than
reflecting either an effect of selective exposure of smokers to
advertising, or an effect of advertising on smoking, the results show
-16-

that both processes operate simultaneously, though at different
depths of processing" (p. 296).
What the authors are claiming here is reciprocal causality, when in
fact this is merely yet another correlational study. Smoking leads
smokers to pay attention to advertisements; smokers pay attention to
advertisements because they smoke. The subjects who smoked
could correctly identify tobacco advertisements. No arguments for
causality are supported by this research.
The researchers cite the following to support their study: British
Journal of Addiction (2 citations), Journal of Advertising Research,
Journal of Communication, an unpublished doctoral dissertation,
The Lung_Goodbve: A Manual of Tactics for Counteractingthe
Tobacco Industry in the 1980's, Journal of Verbal Learning and
Behavior, New York State Journal of Medicine, Introduction to
Structural Equation Models, 'an FTC Report to Congress, a chapter
in The Behavioral Aspects of Smoking (a NIDA Research
Monograph), Journal of Pediatrics, Women and Health, Consumer
Demand in the United States, The Theory and Practice of
Econometrics, Cognitive Psychology and Information Processin~,
Journal of Marketing, Journal of Farm Economics, Cognition and
Reality Principles and Implications of Cognitive Psychology,
Marketing Models and Economic Research, Chronometric
Explorations of Mind, On the Determination of Advertising
Effectiveness: An Empirical Study of the German Cigarette Market,
New York State Journal of Medicine, Journal of Business,
Agricultural Economic Research,, The Economics of Advertisin~,
Economics and Alcohol: Consumption and Controls, Tabak Journal
International, New En~land Journal of Medicine, A Smoking Gun:
How the Tobacco IndustrX Gets Away With Murder, Journal of
Public Health Policy, Pediatric Annals, A Study of Ci agL rette
Advertising,Among Teenage Girls and Young_,Women: A Summarv
of _Findings. This is a substandard list of publications for this type of
research in advertising.
In general, the propositions advanced by the authors have not been
convincingly argued or supported. The limitations conceded by the
authors are veU significant. It should once again be emphasized
that while children who already smoke may be attentive to cigarette
advertising, it cannot be argued that cigarette advertising is a causal
factor in the initiation of smoking. Moreover, these correlational
results cannot be used to support causal inferences. Recognition of
ads is due to exposure to ads; smoking initiation is not.

Conclusion
The weaknesses regarding bias in problem statements, unwarranted
generalizations, conclusions that are not justified by research results, and
research designs that cannot answer questions that are asked are all evident
in the research examples analyzed above. As noted, these problems
permeate the research cited in the FDA proposal in support of the
proposed regulations regarding tobacco advertising. In addition, the vast
majority of this research is tainted by the value judgments of the
researchers, who will apparently stop at nothing to advance their
ideological assertions and insert them in the reports of their research
results in ways that are completely unwarranted and without justification.
Michelle A. Wolf %
Date
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References
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.
Archibald, C. (1993). Sale of Individual Cigarettes: A New Development.
Letters to the Editor, Pediatrics, 91(4), 851.
Beltramini, R. (1988). Perceived Believability of Warning Label Information
Presented in Cigarette Advertising. Journal of Advertising, 32, 26-32
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), 491-493.
Charlton, A. (1986). Children's Advertisement-Awareness Related to Their
Views On Smoking. Health Education Journal, 45(2),75-78.
Crawford, C.T., Gramm, W.L., Weininger, B., Allen, R., Snyder, W.S., Rubin,
P., Higgins, R S., Levine, B. C., Damato, D. G., Keenan, D. & Popper, E. T,
(1985). Omnibus Petition for Regulation of Unfair and Deceptive Alcoholic
Bevera e Advertising and Marketing Practices: Docket No. 209-46
(Memorandum). Recommendation of the Staff of the Federal Trade
Commission. Washington, DC: U.S. Federal Trade Commission. Unpublished
Paper. ,
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.
DiFranza, J.R., & Tye, J.B. (1990). Who Profits From Tobacco Sales to
Children? Journal of the American Medical Association. 263(20), 2784-2787.
DiFranza, J.R., Richards, J.W., Paulman, P.M., Wolf-Gillespie, N., Fletcher, C.,
Jaffe, RD., and Murray, D. (1991). RJR Nabisco's Cartoon Camel Promotes
Camel Cigarettes to Children, Journal of the American Medical Association.
266(22), 3149-3153.
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Doxiadis, S.A., Trihopoulos, D.V. & Phylactou, H.D. (1985). Impact of a
Nationwide Anti-Smoking Campaign. The Lancet pp. 712-713.
Ecenbarger, W. (1993). America's New Merchants of Death. Reader's Digest,
142(852), 50-57.
Feigherty, E., Altman, D.G. & Shaffer, G. (1991). The Effects of Combing
Education and Enforcement to Reduce Tobacco Sales to Minors. Journal of the
American Medical Association, 266(22), 3168-3171.
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]
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), 84-89.
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.
Flay, B.R. (1987). Mass Media and Smoking Cessation: A Critical Review.
American Journal of Public Health, 77, 153-160.
Flynn, B.S., Worden, J.K., Secker-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.
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, 1148-115 0.
Freedman, A. (1994, October 26). How A Tobacco Giant Doctors Snuff Brands
to Boost Their 'Kick.' [sic] Wall Street Journal, p. A14, col. 5.
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 Pediatric Medicine, 110(3), 488-491.
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Henke, L.L, & Wolf, M.A. (1995). Parent Intervention to Prevent Smoking:
Using Joe Camel to Teach Children About Smoking. Paper to be presented at
the 1996 American Academy of Advertising Conference, Vancouver, B.C.,
March/April.
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.
Klitzner, M, Gruenewald, P.J. & Bamberger, E. (1991). Cigarette Advertising
And Adolescent Experimentation With Smoking. British Journal of Addiction.
86 287-298.
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.
Krumske, Jr., W. When Medical Doctors Conduct Marketing, Research: JAMA
and Old Joe, the Camel. (Unpublished paper).
Mintz, M. (1991). Marketing Tobacco to Children, The Nation, 252(17), 577.
Pierce, J.P. (PhD), Gilpen D., Burns, D.M. (MD), Whalen, E., Rosebrook, B.
(MS), 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.
Popham, W.J., et al. (1993). Do Anti-Smoking Media Campaigns Help
Smokers to Quit? Public Health Reports, 108, 510-513.
Popham, W.J., et al. (1994). Effectiveness of the California 1990-1991 Tobacco
Education Media Campaign. American Journal of Preventative Medicine. [in
press]
Sarason, I.G., Mankowski, E.S., Peterson, Jr., A.V. & Dinh K.T. (1992).
Adolescents' Reasons for Smoking. Journal of School_ Health, 62(5), 185-190.
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.
The New York Times (1984, January 13). p.D4, col.5.
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Tobacco Advertising and Promotional Activities. (1994). Preventing Use
Among Youna People: A Report of the SurQeon General. U.S. Department of
Health and Human Services, Centers for Disease Control and Prevention, Office
on Smoking and Health (Chapter 5).
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.
Wall Street Journal (1989, October 19). p. Bl.
Wall Street Journal (1990, May 3). p. Bl, col. 3.
Wall Street Journal (1994, December 27). p. B5.
Washington Post (1995, January 9). p. A5, col. 3.
Washington Post (1995, January 9). p. A5, col. 3.
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