Television advertising: an international threat to children.

To the Editor: We would like to respond to the paper and editorial on the effect of television food advertising on children that were published in the June 2003 issue of this journal. Dr Mary Story's excellent editorial identified the need to discuss 'ethical concerns and social responsibility towards children'. We believe this can be done using the evaluation tools developed by Gostin (1) to determine if public health regulation is warranted.

Government intervention needs justification because it can intrude on the individual rights of citizens (and the corporations they control) and incur economic costs (1). At the same time, government has a legal responsibility to protect public health and safety (1). Gostin (1) suggests that three general justifications can be used by public health practitioners when deciding whether the benefit from an intervention warrants the infringement of individual (or corporate) rights. These include: where there is a risk to others (the harm principle); to protect incompetent persons; and where there is a risk to self (1). In the case of television food advertising to children, the first two of these justifications can be argued.

Addressing the harm principle, there is ample evidence that the vast majority of foods advertised to children on television do not conform to healthy eating recommendations (2,3). Advertising is an effective tool used to alter the foods requested and eaten by children, while the term 'pester power' is now commonly used to describe the established ability of children to influence parents'/carers' purchasing choices.

The second justification for government intervention, to protect incompetent persons, can also be argued because, as Mills stated in his famous paper 'On Liberty', children have diminished capacity and must be 'protected against their own actions as well as against external injury' (4). It may be argued that a parent's/carer's role is to protect their children's best interests. Regarding food choices, not all parents/caters have the knowledge, skills or capacity to exercise this responsibility, and those that do are undermined in their attempts by highly sophisticated, expensive and persuasive advertisements shown during children's television viewing. Given these considerations, the government has a responsibility to support parents in minimising poor food choices for their children by imposing restrictions on advertising.

Thus, there is a sound ethical basis for government intervention regarding food advertising on television to children. What must be decided is the regulatory framework required, its potential effectiveness, and potential cost. Gostin (1) provides a framework for the ethical assessment of particular interventions. This is presented in Figure 1.

Figure 1. Evaluation of public health regulation

Step 5. Assess Fairness of Policy

Benefits/Services Based on Need
Costs/Burdens Based on Risks Posed

Step 4. Assess Burdens on Individuals

Invasiveness of Intervention
Frequency, Scope, and Duration of Infringement

Step 3. Assess Economic Costs

Cost of Regulator, Regulates, and Opportunity
Cost-effectiveness of Strategies

Step 2. Demonstrate Intervention's Effectiveness

Means/Ends Test
Effective Risk Reduction

Step 1. Demonstrate Risk

Type of Risk: Physical, Chemical, Biological, or Behavioural
Timing of Onset and Duration of Risk: Imminent or Distant
Probability of Harm
Severity of Harm to Individuals, Entire Population, Future
Generations, or Ecosystem

Source: Gostin JAMA 2000:28:3120.

Given the importance of childhood obesity, the evidence of the effect of food messages on television on children (5), and the ethical justification that has been provided, we believe it is time to support the call by Zuppa, Morton and Mehta to make 'radical changes to the current regulatory system' (2). More research is an important priority but it should go on in tandem, not before, the introduction of effective government regulatory strategies.

References

(1.) Gostin LO. Public health law in a new century: Part III: Public health regulation: A systematic evaluation. JAMA 2000;283:3118-22.

(2.) Zuppa JA, Morton J, Mehta KP. Television food advertising: Counterproductive to children's health? A content analysis using the Ausralian Guide to Healthy Eating. Nutr Diet 2003;60:78-84.

(3.) Hill J, Radimer K. A content analysis of food advertisements in television for Australian children. Aust J Nutr Diet 1997;54:174-80.

(4.) Mills JS, On liberty. London: Longman, Roberts & Green; 1869.

(5.) The International Association of Consumer Food Organisations. Broadcasting bad health: Why food marketing to children needs to be controlled. A report for the WHO consultation on a global strategy for diet and health. London: IACFO; July 2003.

Barbara C Radcliffe

Dietitian / Nutritionist, Brisbane

Bronwyn Ashton

Member, Coalition on Food Advertising to Children

Nutrition Consultant, Brisbane