Philip Morris
Dr. Linda D. Goff
Fields
- Author
- Goff, L.D.
- Type
- REPT, REPORT, OTHER
- Site
- R461
- Named Person
- Doubleday
- Droege
- Goff, L.D.
- Liebert
- Macneil
- Palmer
- Sprafkin
- Area
- ELLIS,CATHY/OFFICE
- Litigation
- Iwoh/Produced
- Master ID
- 2057063515/3727
- 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
- 2057063600-3621 Public Policy Decisions Should Be Based on Sound Social Science Research, Not Speculation or Political Motivation.
- 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
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Dr. Linda D. Goff
My name is Unda Dysart Goff and I am a tenured member of the faculty of the
School of Communication at the University of Southern Mississippi in Hattiesburg,
Mississippi. I hold a Ph.D. in mass communication from the University of
Massachusetts at Amherst, awarded in 1975. My dissertation research was
conducted in the area of children and television advertising and for the past 20 years
my teaching and research has involved work on the effects of mass communication
and the impact of the medium of television on children.
My knowledge of media effects in general and children and advertising in
particular leads me to conclude that the tobacco advertising restrictions posed by the
FDA will fail to achieve the desired outcomes.
Children's understanding of television advertising has been studied extensively
due to a long-standing concern over young children's susceptibility to advertising's
influence. There exists a large and consistent body of research that links the
development of an understanding of advertising to a child's progress through stages
of comprehension ability that are roughly related to age ranges (Palmer & MacNeil,
1991). It is generally agreed that children understand the persuasive intent of
television advertising (easily generalized to other forms of advertising) by ages 7 to 9.
By the time they reach adolescence, children are recognized as being able to
distinguish commercials from program content, understand commercial messages,
and resist persuasive messages (Doubleday & Droege, 1993). By this time, children
have developed not only the cognitive ability necessary to put advertising in its proper
perspective, they have also gained a great deal of experience as consumers. Children
develop a wary attitude toward advertising in early childhood. Skepticism toward
advertising that approaches cynicism is common by the early teenage years (Liebert &
Sprafkin, 1988, p. 169).
My own dissertation research included an examination of one seemingly
manipulative technique of children's television advertising, the use of a premium offer -
- providing a toy or other item along with the product. The product in this case was a
breakfast cereal that was not well liked by the second and third grade children in my
sample. The study found that the dislike of the product offering a premium greatly
affected recall of the product and the desire for the product (Goff, 1975). The offer of
the premium item did not change their attitude toward or dislike of the breakfast
cereal. Consumer experiences and teachings of parents, siblings, and peers add to
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considerable logic in applying some of the theoretical understanding gained from the -.~
aforementioned research to children's understanding of print media advertising. Quite ©
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medium dominates children's use of commercial media. The percentage of all
magazines directed at children is very small, and even older children of the current
multi-channel "television generation" pay very little attention to print media sources.
Therefore, the very logic that motivates the FDA to propose certain required anti-
smoking television messages for older children (television messages are likely to
reach the audience-of-concern) questions the logic of requiring black and white "text
only" advertising in certain magazines (which few members of the audience-of-concern
will ever see).
The proposed FDA regulations include a plan to require text-only black and
white tobacco advertising formats in any magazine with a youth readership of 15% or
numbering more than 2 million youth (defined as under 18 years of age). The FDA
believes that the use of color and imagery in print advertising presents a favorable
image of smoking and tobacco products that lures youths, tempting them to try
tobacco products. The FDA cites research in which substantial numbers of children
can identify "Joe Camel" with Camel cigarettes. Unfortunately, such research never
establishes a link between logo recognition by children with positive affect for the
product, let alone product purchase or use. By the teen years, if not before, children
can identify hundreds of product logos and the products they represent. They
certainly do not seek to buy or use every product they see advertised. In the case of
cigarettes and cigarette advertising, the product class is immersed in an overall
information environment that is extremely negative.
Media in all forms convey consistent and detailed messages about the health
consequences of smoking and other tobacco use. This information environment is
reinforced in the majority of family settings. While some parents/adults smoke, most
would nonetheless discourage smoking by children/youth. The health consequences
of tobacco use are topics common to the health curricula for most grades in virtually
all states. The same message is conveyed through a variety of youth organizations.
For example, the 10th edition of The Boy Scout Handbook (1990) states the following
about tobacco:
You may have friends who think smoking makes them look grown up.
Ads in magazines and newspapers pretend that smoking is very exciting. Many
of those ads are aimed at young adults not much older than you.
Don't let advertisements fool you. Smoking shortens your breath and
makes it hard for you to be good at sports. Smoke coats your lungs with
sticky tars that can cause cancer, a disease that kills hundreds of thousands of
people every year (pp. 388-389).
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tobacco, and effects of nicotine (described as a drug). A similar warning about
alcohol use describes the positive product context usually created by advertising.
And what about advertising and its influence? In the first place, all advertising
seeks to present products in a favorable light. Cigarette ads, then, are hardly unique
in their style or layout. The same attractive settings and people found in cigarette
advertisements are found in the ads for hundreds of other products. The only thing
unique about cigarette ads is the required health warning that is present in every one.
This warning echoes the health information that is already familiar to children and
adults.
The FDA rule would require modifications to tobacco advertising carried in
magazines read by a threshold number of youth. Even passive television viewers can
avoid or fail to pay attention to television commercials. Print (and outdoor) ads are
the easiest to miss of all forms of advertising. Magazine circulation or readership
figures are among the crudest estimates used in commercial media practice.
Considering the way such figures are derived, estimates of "youth" readership of
magazines directed at adults will be terribly imprecise. Even if readership estimates
place 'youth" readership of a magazine at or above 15%, there is no known
relationship between this figure and the actual percentage of youth who will actually
see an ad in that magazine. Few people read or even scan magazines from cover to
cover. Indeed, today's youth spend very little time reading anything. Use of print
media has always been positively related to the attainment of education. This would
indicate that among young persons, the brighter children will be more likely to be
readers of print media. These same youth would be the least likely of their age group
to be influenced by advertising.
The image appeal of cigarette advertising is no different than that of other
products. Cigarette advertisements have no uniqu`e ability to influence children. Their
images are similar to those of other products and their ads are disseminated in a
cluttered environment of similar messages. The FDA document contends here that
some cigarette advertising is, in fact, directed at children. I have read with great
interest some of the pertinent "Joe Camel" and related research in JAMA and other
sources and find it to be unimpressive. To contend that Camel ads with "Joe Camel"
are directed at children because children can recognize the "Joe Camel" logo is
ridiculous. I am certain that most children in the U.S. can recognize "Snoopy" from the
"Peanuts" comic strip. Does this mean that the Metropolitan Life Insurance Company
is advertising to children?
The critics of "Joe Camel" would be quick to respond by observing that few
children buy life insurance, but that cigarettes are illegally consumed by kids under the
age of 18. I would respond that children try cigarettes initially because of the influence
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of peers. The kids who begin to smoke do so because they associate with other kids
who smoke. For these kids, smoking is perceived a"cooP' or an "in" thing to do.
Advertising did not cause this behavior and health warnings did not prevent it. It is
highly unlikely that a new barrage of health messages will have any more effect. The
social desirability of smoking is conveyed by real people in the young person's
environment.
In conclusion, however laudable the goals of the FDA may be in promoting the
public health, its ideas about advertising are naive and its view of tobacco advertising
are founded on subjectively designed and seriously flawed research. FDA plans for
changes in print media advertising of cigarettes and tobacco products will accomplish
little and may even lead to negative consequences. The public information campaign
envisioned by the FDA will, for the most part, convey information that. is already known
by young people. This type of information can do little to overcome the powerful peer
and social influences that are known to be associated with smoking initiation.
Linda D. Goff
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