Tobacco Documents Online

0 0 • COMMENTS TO FDA I am Donald Ragsdale, Professor of Speech Communication at the Louisiana State University in Baton Rouge, Louisiana. I received a Masters and Doctorate in Speech from the University of Illinois--the latter degree in 1964. I have taught speech communication courses to undergraduate and graduate students at LSU since 1964. My professional life has been devoted to the study of communication theory and how messages affect receivers at all levels whether in face to face communications or through advertising in the media. A copy of my current curriculum vitae is attached. I have reviewed the proposal of the Food and Drug Administration regarding cigarette advertising restrictions, which has as its stated goal the reduction of underage cigarette smoking. Based on my professional training and my years of experience, it is my opinion that the advertising restrictions proposed by the FDA would have a negligible effect on underage smoking. The FDA proposal ignores the basic tenets of communication theory. FDA bases its proposals on fundamental misconceptions about advertising as a form of communication. The stated goal of reducing underage cigarette smoking is admirable, but FDA has focused on the wrong causative factor. Set out below are the bases for my opinion. One of the misconceptions about communication/advertising is the idea that the process is simple and straightforward. Many people wrongly believe there is a simple, cause and effect relationship between an advertisement for a product and the subsequent purchase of the product. In theories of mass communication, this thought is akin to the "magic bullet" or "hypodermic needle" explanation of media effects. Essentially, this explanation posits that if one crafts and places an ad carefully, then the ad will make the consumer buy the product. In this view, the media effect is to overwhelm the consumer. Despite the intuitive appeal of this concept, research in communication theory over the years has proven that this theory is without basis in science. Despite this fact, there are vestiges of this explanation remaining even among otherwise well-educated people (and, apparently, government agencies), although the view itself has been discredited since at least the late 1940's. Nearly every theory of mass media effects today acknowledges that the communication process is complex, with multiple variables operating, and with a considerable contribution being made by the thought processes of the consumer. Further adding to the complexity is the recognition of the fact that the variables change from receiver to receiver and can change for each person from minute to minute. In order to understand this complexity, one might begin by looking at a basic model of communication. One of the most general communication models is the source-message- channel-receiver (SMCR) model. 1

0 • • 1. The Source Component. The SMCR model first recognizes the importance of the source or sender of communication. The source may be an individual, a group of people, an organization or an agency. From the standpoint of the receiver of the communication, what is important about the source is its credibility. Sources are not uniformly effective or ineffective; their effectiveness depends on the receiver's judgment of their trustworthiness, their competence, their good will, and so on. For example, it is well documented that people know that sources may be biased and that their messages need to be evaluated accordingly. Sources may be self-serving. In particular, people recognize the self-serving nature of persuasive communication and of advertising. By contrast, people also recognize that family members and friends are usually the most credible sources. A prominent mass media effects theory of the 1940's and 1950's, Katz and Lazarsfeld's "two-step flow" theory emphasized that even media messages are filtered through so-called opinion leaders, to enhance their credibility. In this theory, people rely more upon the advice of respected others than upon mass communication messages. Because of the role of source credibility in considering the source, this is an appropriate place to include information from Cacioppo and Petty's "elaboration likelihood model" of information processing in persuasion. Cacioppo and Petty distinguish between two types of information processing: central and peripheral. In central processing, people give careful consideration to arguments, facts, statistics, and the like, and people are most likely to use central processing when they are ego-involved in the subject of persuasion. Ego-involvement generally comes from those subjects which are salient to the groups with which one is aligned -- e.g. peers. These are subjects a person has dealt with and considered at length and sometimes create a set of fixed habits about. An example might be an investor's consideration of investment options at the anniversary date of certificates of deposit. In peripheral processing, people tend to short-circuit careful and direct consideration of arguments, facts, and the like in favor of a reliance on source credibility, the advice of a respected other or others. An example might be a newcomer to Louisiana cooking taking the advice of a native about what to order in a Cajun restaurant. A person could research all aspects of gumbo but reliance on the expertise of a respected native of Louisiana results in a comfortable decision. The reason the elaboration likelihood model is relevant here is that the decision to begin smoking cigarettes does not come out of a set of fixed or habituated experiences personal to the decision maker. For that reason this decision is likely to be one on which a person is particularly susceptible to the influence of others, and therefore source credibility becomes key. 2. The Messa eg Component. The message component of the SMCR model refers to any verbal or nonverbal information containing the thoughts and recommendations of the source. The message may be an essay, a speech, an ad, or simply a sentence or two. It may iaclude visual components,such as colors, designs, and environments, which convey supplemental information to the receiver. In speech 2

• • • communication, for example, we know that a speaker may prepare a quite effective persuasive presentation on paper but be wholly ineffective in delivery. In the media, for example in advertising, we know that "packaging" makes a considerable difference in effectiveness. No detergent manufacturer uses a purple package; consumers will buy detergent, but not in a purple package. Now M & M's have come under fire because, as the comedian George Carlin used to say, 'There is no blue food!" It is probably fair to say that when a person has decided to buy a particular category of product, the choice of brand is more a function of these visual elements than of the verbal elements. This is because the decision to consume has already been made and now an actual behavior is about to take place. In actual behavior, a somewhat different set of variables is in play than in the decision to consume. In particular, what a person believes to be his or her reference groups' opinion of the behavior will come to the fore. One does not want to display a behavior which isn't part of the group's image of itself or of him/her. If nobody in one's civic club drives a Ford Taurus (indeed, if driving a Taurus is looked down upon) then one would be very resistant to any advertising appeals for a Taurus -- regardless of the car's merits. Such image aspects of messages are predominantly nonverbal and are obviously extremely salient in affecting one's brand choice in consumption. 3. The Channel Component. The channel component of the SMCR model refers to the medium by which communication is conveyed. In human communication, there are many channels, another fact often overlooked by the average person and which is virtually ignored by the FDA in drafting its proposal regarding restrictions on cigarette advertising. The channel component of the SMCR model includes media: written messages, newspapers, billboards, radio, and television. Since the media consumer often does not know the writer or broadcaster personally, the consumer or receiver may attribute source credibility to the media themselves. However, regardless of the channel, consumers are well aware of the inherent bias of advertising and t)pically assign low or even negative credibility ratings to ads. It is well established that people rank channels in terms of credibility and give the highest ranking to interpersonal, face to face channels, and the lowest to commercial advertising. 4. The Receiver Component. The final component of the SMCR model, the receiver, is often the most disregarded element. In early, primitive models of communication, the receiver was viewed as simply the destination of information. However, it has been increasingly and overwhelmingly obvious in all the social sciences in this century that the receiver is complex and must be accounted for - a fact also ignored by the FDA proposal. The receiver does not merely record messages passively but interacts with received_messages. No receiver is a blank state. Receivers already have values, beliefs, and attitudes, along with information pertaining to these. Beliefs and values appear to be extremely fundamental and highly resistant to change in the short term. Enduring behavior change, 3

• • • • • • for example, requires altering a deep-seated set of beliefs. All messages will be processed in terms of what is already in the receiver. According to Fishbein and Ajzen's theory and research, the process includes at least three considerations. The first is the receiver's attitude toward the action suggested in the message, not the object which is the subject of the message. The second component in predicting the receiver's behavior is one's normative social beliefs or what one believes his or her reference groups think one's behavior should be. Particularly with teenagers, the act of smoking may have several positive supports, such as peer acceptance and even approval, rebellion against parents and "the Establishment," and the like. Indeed the endorsement of smoking in one's peer group may virtually drive one to smoke. By contrast, for one's peer group to frown on smoking would be a far greater influence on behavior than any particular message in the media. Perhaps it is this factor more than any other which explains the current general decline in smoking in the adult population in the United States and which offers the most promise in achieving the FDA's stated goals. Fishbein and Ajzen's third and final factor in predicting behavior is motivation to comply with the normative social beliefs. This factor suggests that, for example, peer pressure might vary in its influence depending upon the amount of peer contact. For example, were a teenager to be isolated from peers for several weeks, such as one might be on a family vacation, there would be much less incentive to behave in peer-valued ways, especially when those ways are not family-valued. What emerges about receivers from this assessment of Fishbein and Ajzen's theory is that the processing of communication is done in a highly complex cognitive system which is much more highly formed than any individual incoming message. The theory suggests that enduring behavior changes, such as taking up smoking or giving up smoking, are really only incidentally related to particular pieces of communication. They are always the product of a long-term effort to dislodge fundamental beliefs, and the sources of these beliefs are reference groups rather than media messages. Having examined the SMCR model and made reference to several of the general theories related to it, it is possible to comment on some of the specific issues emerging out of the FDA proposal to restrict cigarette advertising further. First, it is highly • unlikely that cigarette advertising plays a role in a teenager's beginning to smoke. In addition to the factors mentioned above, teenagers, like adults, are exposed to multiple messages regarding the health consequences of smoking from family, friends, the government through the media, and the media themselves, all of which are inherently more credible than advertising. There is absolutely no basis in either theory, research or i common sense to believe that somehow advertising insidiously advances to the fore and overwhelms these other influences. Certainly people, including teenagers, may be aware of such advertising, just as they are aware of advertising for such other products as jeans, 0 beer, and cars. But simply because one recognizes the Levis, or the Budweiser, or the ~ BMW logo does not mean that one will buy the product. The "gang" may be wearing .~ ~ 4 ~ ~ ZZ

• • 0 r • f Girbauds and drinking Coors; and buying a BMW is financially challenging to say the least. Second, it is unreasonable to reduce cigarette advertising to a text-only form. The nonverbal components of messages provide the subjective bases for attracting attention to the advertisement and differentiating competing brands. For example, almost everyone uses toothpaste. Despite manufacturers' claims for the superiority of their own brands, there is little "objective" difference between the top brands. For the consumer, it is a question of how one feels using one brand as opposed to another. With a related product, mouthwash, it just may be that one feels better with a"green" brand (Scope) in an attractively shaped bottle than a"brown" brand (Listerine) with a text-oriented label. To remove the advertisers' nonverbal tools would be to keep significant, albeit subjective information from the consumer and disable one manufacturer from competing with another. For all of the above reasons, I believe the FDA's proposed tobacco advertising restrictions are misconceived and would be ineffective if implemented. ~C,C.L~PDtirc~~ Date • • 0 O Cn -.i ~ W 5 ~ ~ w