Tobacco Documents Online

CHARLES F. "RICK" HOULBERG • • • My name is Rick Houlberg, and I am a professor of electronic media at San Francisco State University. I hold a 1982 doctorate in mass communication from The Ohio State University, a 1972 masters degree in broadcasting from Brooklyn College, and a 1969 undergraduate degree in radio-television from Southern Illinois University. I have been teaching at the university level since 1972, including five years at the University of Idaho, two years at Xavier University of Louisiana, and 13 years at San Francisco State University (where I have been a tenured professor since 1989). I have taught extensively in research, the survey of electronic media, radio, performance, and production. Also, since 1972, I have been an active researcher focused on the audience effects of mass mediated messages. My research has been published in the Journal of Broadcasting and Electronic Media, Journalism Quarterly, and books. I have been competitively selected to present my research at meetings of the International Communication Association, and the Speech Communication Association, the Western States Communication Association, and the Association of Educators in Journalism and Mass Communication. I have been a text reviewer for professional research organizations and commercial publishers. Comment Useful social science research demands an unbiased approach, clear and consistent definitions, reliable methods, and conclusions which follow from careful data analysis (Babbie, 1979 and 1990; Emmert and Barker,, 1989; Lowery and Defleur, 1995; Rubin and Rubin, 1990; Singletary, 1994; Wimmer and Dominick, 1983). At issue in_this discussion is the clarity and consistency of the social science research which has been used to support the conclusions stated in United States Food and Drug Administration, Department of Health and Human Services Report, 21 CFR Part 801, et al., dated August 11, 1995. A review of the FDA proposal and many of the studies upon which its conclusions are based, clearly shows a lack of clarity in the use of key terms and concepts. This failure to meet the demands of social science research makes the conclusions reached by the FDA proposal unreliable and unable to support the proposed changes in public policy. In order to compare results from social science studies, to clearly communicate those results, and to base policy decisions on the results, research studies must develop a consistent set of definitions for the pivotal terms such as, in this case, "smoking," "adolescents," "appeals," "advertising effects," and "causation." These and other definitions should be the definitions accepted by researchers with expertise and experience in this area of research. In research, without rigor in the definition process,

• the subsequent conclusions are, at best, questionable. The FDA proposal is so filled with inconsistent definitions and other methodological problems that its conclusions are not • valid. Definition Problems Page 41322 of the FDA report contains section "3. Section 9\897-3--Definitions" ~ but this section makes no attempt to define the key terms discussed below (which come from both the FDA report and supporting materials). • • • • • Since the stated goal of the FDA's proposed advertising restrictions is to reduce underage smoking, careful attention must be paid to insure that both the FDA and the many studies of young people it relied on would use the same terms for those youth below the legal age to purchase tobacco products. However, it is clear that multiple definitions are used, some which include youth of the legal age to smoke and others that do not. For example, "Adolescent" is a term used throughout the FDA report and its supporting studies. The term means young people 17-years-old and younger in some studies, and in other instances includes 18 and 19-year-olds when referring to high school seniors and 12th graders (e.g. FDA report page 41317). On page 41315, the FDA report includes 12th graders in the discussion of smoking prevalence among "young people". High school seniors and "teenagers" are included in the discussion on page 41317 without age clarification. On the same page, in the discussion of smokeless tobacco products, the age is placed at "under the age of 21 in 1986," and "among high school seniors". High school seniors are included in the discussion of buying cigarettes on page 41322 of the FDA report. On page 41322 of the FDA report, the term "minors" is not defined. The serious problems brought by use of incomplete definitions concerning age and grade level was recognized by Aaro, Wold, Kanna, and Rimpela (1986, p. 32). Conclusions by the FDA about underage use of tobacco products can not be fairly based on studies that include data on 18 and older teens. Perhaps the most important term requiring consistency in the FDA proposal is the concept of "causation." The proposal and the studies it relies on make important conclusions about a "causal" relationship between tobacco advertising/promotion and underage use of tobacco. Unfortunately, these "causal" conclusions are, in fact, based on much weaker concepts (e.g. correlation, suggestion, recognition, awareness, etc.) thereby severely undermining the conclusions and the recommendations based thereon. • As noted above, "causation" is a term used loosely and improperly in the FDA report and in many of the supporting studies. In some cases, the term is used to mean only "predictive" (e.g. FDA report page 41332). Although "causal" and "predict" are ~ obviously very different in their meanings, according to the FDA the two terms are the p CTC ® va 2- Cf~ ~ O~

0 • • • • • same in the statement "...and the amount of information retained by each subject from cigarette advertisements predicted the subjects' experimentation with cigarettes (causality)." As noted by Simon and Burstein (1985) in their third edition of Basic Research Methods in Social Science, "cause-and-effect relationships are a subclass of associations ... relationships that yield predictions are another subclass of associations... Not all predictions are causal; empirical generalizations that do not explain a phenomenon can often be used for successful predictions of the phenomenon. And not all causal relationships yield predictions, because the situation to which the relationship applies may change." (p. 437). Simon and Burstein go on to explain the misuse of the terms and the confusion that often accompanies that misuse. More examples of the conflicting use of the concept of "causation" can be found on page 41334 of the FDA proposal. The "Summary of Evidence" section starts by stating that the "causal relationship between advertising and youth smoking behavior" and a"positive effect of stringent advertising measures on smoking rates and on youth smoking," are only "suggest[ed]" by the evidence. The authors however ignore the limitations underlying their evidence and go on to claim a "causal" relationship. The limitations of the underlying evidence are clear. On page 41341, the FDA report states "many different factors may affect a young person's decision to start smoking or use smokeless tobacco products". Even Fischer, Schwartz, Richards, Goldstein, and Rojas (1991) disclaim, "It is obviously impossible to predict how the exposure of children to environmental tobacco advertising might influence their later smoking behavior" (p. 3148). Dr. M. Joycelyn Elders, the former U.S. Surgeon General, in a 1994 report, noted, "[a] misguided debate has arisen about whether tobacco promotion 'causes' young people to smoke -- misguided because single-source causation is probably too simple an explanation for any social phenomenon" (p. iii). McDonald (1993) explains, "It is clear that none of the research evidence proves that advertising causes children to smoke. The circumstantial evidence quoted from the studies themselves show that it is not a particularly likely hypothesis. If advertising does 'cause' smoking it clearly fails to work in most cases, since most children, even when they enjoy advertising, seem to be unaffected by it" (p. 285). • Another term often improperly used in the FDA proposal and supporting studies ~ as interchangeable with "cause" is "correlation" (e.g. FDA report page 41332). Correlation is defined by Singletary (1994) as "An estimate of the extent that variables vary together, or as an estimate of the extent to which one variable is related positively or negatively to another." (p. 454). Causation does not have the same meaning. The 0 problem is that with "causation" hidden or unknown variables may be "causing" the correlation between the examined variables. If unknown variables do exist, then both of the examined variables may be changed (or "caused" to change) by those variables and not by each other. Hastings, Aitken, and MacKintosh (1994) state, "We, along with most ~ other researchers, would of course agree with McDonald that correlations can never o CTt • ~ ~ -3- w ~ ~ . ~

0 • • • • • 0 • • prove a causal link (between tobacco advertising and smoking)" (p. 196). Klitzner, Gruenewald, and Bamberger (1991) write, 'These biases will operate in research studies relying on simple correlations as well as studies using more sophisticated recursive structural equation models" (P. 296). Two more terms used in the FDA proposal and supporting studies as being the same as "cause" are "recognition" (e.g. FDA report page 41333) and "awareness" (e.g. FDA report page 41337 and 41338). Even an untrained person understands that these terms do not equate with "cause." The substitution for "cause" by "recognition" is used throughout the discussion of "Joe Camel" and how many children have recognized the symbol. According to the FDA, "recognition" is assumed to "cause" the start of smoking by those children some time later in their lives. From a social science standpoint, such an assumption is absolutely unsupportable. The term "awareness" is also used throughout the discussion of the "effects" of cigarette advertising to mean "cause". Henke (1994) notes, 'To the contrary, it is possible that characters such as Old Joe, by attracting the attention of young children, make the product category and the surrounding controversy more salient and thereby facilitate the acquisition of perspective-taking skills and increase understanding of the health risks associated with smoking" (p. 22). Aitken and Eadie (1990) state, 'This does not necessarily mean that advertising plays an important part in inducing children to start smoking. Cause-and-effect relationships are always difficult to disentangle. For example, children may become more aware and appreciative of cigarette advertising after they start smoking" (p. 410). Wilcox and Vacker (1992) conclude, that "aggregate cigarette consumption is primarily related to price and income and not to advertising expenditures... It is important to note that the relationships observed in this study are correlation, not causal" (p. 276). The improper substitution by the FDA of misleading terms for causation injects major confusion into a report already filled with confusion. "Smoking" is another term which has many meanings in both the FDA report and the supporting documentation it relies on. "Regular Smoker" is undefined twice on page 41314 of the FDA report. In the Reimers, Pomrehn, Becker, and Lauer (1990) study, the term "regular smoker" means everything from weekly to daily smoking, while "experimenter" is someone who smokes occasionally but less than once a month (p. 1266). "Current smoker" is defined as daily, some day, occasional infrequent smoking, and "smoked within the last 30 days" (FDA report p. 41317), and is used on page 41322 without definition. "Heavy smoker" is noted on page 41318 of the FDA report without definition. "Adolescent smoking rates" are discussed on page 41327 of the FDA report without clarification. The absence of a consistent definition of "smoker" nullifies the conclusions of the FDA proposal. 0 ~ 0 ~ -4- w ~ • GO

0 "Appeal" is another undefined term. The FDA report on page 41315 discusses the "appeal of advertising" twice without a meaningful definition of the term. At least • one of the studies upon which the FDA report is based did define "appeal" simply as "likeability" (Huang, Burton, Howe, and Sosin, 1992, p. 253), but the FDA report makes no such attempt. A related problem is unclear definitions of advertising exposure in the support studies. For example, Klitzner, Gruenewald, and Bamberger (1991) state, "An additional problem with past studies of the relationship between advertising and the use • of cigarettes has been the divergence of definitions used to operationalize advertising exposure" (p. 288). FDA and the studies it relies on fail to use any consistent concepts or definitions when making number comparisons. This failure results in high discrepancies that make • interstudy comparisons and conclusions virtually impossible. For example, on page 41328 of FDA report, $75 million in later 1970's money is "translated" to $290 million in 1994 dollars; while on page 41329, $361 million in 1970 dollars is compared to $6 billion in 1993 dollars without any comment about using a comparable standard. In question is the FDA conclusions that the "cigarette advertising and promotional expenditures" have • increased 1,562 percent between 1970 and 1993. If the same "translation" is used on page 41329 as is used on page 41328, the increase in expenditure becomes closer to 500 percent. Further down the same page, the FDA report indicates the advertising for "moist stuff' tobacco changes by 485 percent between 1972 and 1984 without an indication of a standard dollars base for the comparison. It is worthwhile to note that 0 the 6 billion dollar figure is used throughout the FDA report to include BOTH • • • advertising and promotional expenditures, although the two activities are mvestigated m separate parts of the report. On page 41334 of the FDA report, in a discussion of the recent bans on advertising in Canada, the report claims the ban reduced "consumption" by "2.8 percent more than would have been expected had there been no advertising restrictions." Given the complexity of the interactions discussed, making a claim about how a ban effected what "should" have happened is questionable. On page 41337, the FDA report notes that total sponsorship (by the cigarette companies) has grown considerably between 1985 and 1994. This comparison would also be clearer if a dollar standard had been included so that money expended a decade apart could be carefully compared. The FDA cited study by Tye, Warner and Glantz (1987) compares 1975 and 1983 monies and concludes this "288 percent increase was more than triple the growth rate of the consumer price index over the same period" (p. 492). However, no where in their discussion do they establish a real dollar base for the cited figures. The problem was dealt with by the ~ 0 C3-t O ~ W -5- o~ ~ c,c

• • • • • Institute of Medicine in their 1990's report, "Preventing Nicotine Addiction in Children and Youths" with the footnote about the use of dollar amounts and comparisons in their introduction by stating, "All figures have been converted from nominal to real dollars with a base of 1991, the year for which the most recent date are available from the Federal Trade Commission" (p. 105). Conclusion The evidence presented in this discussion indicates a dramatic lack of clarity and consistency in the defini tions of important terms used in the supporting social science research studies and the reliance thereon by the 1995 FDA Proposal. In many instances, both the FDA and the supporting studies reach conclusions which are based on unclear definitions, less than acceptable and invalid cause-and-effect links, and merely emotive language which is passed off as carefully considered social science. These failings in the FDA proposal render its conclusions and recommended policies not valid. q.~ 13 We 11 Date • • • • ~ 0 CTt 0 cr~ 6- C~ ~ ~ O

0 ! • ! ! ! ! ! ! REFERENCES Babbie, E.R. (1979). The practice of social research. Belmont, CA: Wadsworth. Babbie, E. (1990). Survey research methods. (2nd ed). Belmont, CA: Wadsworth. Emmert, P. and Barker, L.R. (1989). Measurement of communication behavior. New York, NY: Longman. Katzner, J.; Cook, K.H.; and Crouch, W.W. (1982). Evaluating information: A guide for users of social science research (2nd ed.). New York, NY: Random House. Lowery, S.A. and DeFleur, M.L. (1995). Milestones in mass communication research (3rd ed.). New York, NY: Longman. Rubin, R.B.; Rubin, A.M. ; and Piele, L.J. (1990). Communication research: Strategies and sources (2nd ed.). Belmont, CA: Wadsworth. Simon, J.L. and-Burstein, P. (1985). Basic research methods in social science (3rd ed.). New York, NY: Random House. Singletary, M. (1994). Mass communication research: Contemporary methods and applications. New York, NY: Longman. Smith, M.J. (1988). Contemporary communication research methods. Belmont, CA: Wadsworth. Wimmer, R.D. and Dominick, J.R. (1983). Mass media research: An introduction (3rd ed.). Belmont, CA: Wadsworth. O ! ~ O -7- ~ ~ tst • ~."'`