Strengthening the Canadian alcohol advertising regulatory system.
Protective measures in Canada
In Canada, despite federal and provincial guidelines that restrict alcohol advertisements from appealing to children and minors, children and youth are exposed to more than 300,000 alcohol ads each year through radio, television and the Internet. (6) Alcohol advertising countermeasures have typically taken the form of social responsibility messaging initiatives that increase the public's awareness of the potential harmful influences from alcohol advertising. In Canada, alcohol media literacy campaigns have been the primary measures for counteracting the effects of alcohol advertising. (7-9) While these initiatives have the potential of doing so, the effectiveness of such measures can be easily drowned out with increasing advertising activities from the alcohol industry, especially in the absence of effective regulation.
Critical elements of an effective alcohol advertising regulatory system
As part of the European Focus on Alcohol Safe Environment (FASE) Project, a 2010 report by the Dutch Institute for Alcohol Policy and the European Centre for Monitoring Alcohol Marketing (EUCAM) reviewed 190 papers from the literature along with alcohol marketing regulations in 23 European countries to identify components and criteria that make policy measures effective at protecting against the harmful effects of youth exposure to alcohol marketing. (10) As outlined in Table 1, the results from this report indicate that three components are necessary for an effective alcohol advertising regulation system: 1) content restrictions, 2) volume restrictions, and 3) an overall supporting system. An effective supporting infrastructure consists of a supporting legal context, a commitment of all stakeholders, transparency of the decision-making process, a mandatory pre-screening system, an effective complaint system, an independent advertising committee, effective sanctions, and a monitoring system. In addition, such supporting infrastructure should cover all forms of marketing activities and have the flexibility to adjust restrictions accordingly. Using these key elements as an evaluation framework, there are critical components in the Canadian alcohol advertising regulatory system that clearly require strengthening. (11)
Limitations in the current alcohol advertising regulatory system
A number of limitations in the current federal, provincial and industry regulations governing alcoholic beverage advertisements in Canada exist. In terms of content restrictions, the Canadian Radio-television and Telecommunications Commission Code for Broadcast Advertisement of Alcoholic Beverages (CRTC Code) has not been updated since 1996. Not all elements that appeal to youth, such as party scenes, have been addressed. In terms of volume restrictions, regulations do not mandate place restrictions, coverage of all types of advertising mediums are not standardized, and underaged viewers are not protected from the total volume of alcohol advertisements they may be exposed to. Finally, in terms of the infrastructure, pre-screening has been made voluntary as of 1996, complaints are not monitored by a third party, and there lacks an independent advertising committee independent from commercial interest. Through current regulations, it is also possible for international broadcast stations to advertise alcoholic beverages to Canadians through cable and satellite services without complying with the CRTC Code. (12) As a result, thousands of irresponsible alcohol advertisements are aired or displayed with a large proportion of them being exposed to young and impressionable children and adolescents.
The voluntary pre-screening process provided through Advertising Standards Canada (ASC) as a means of enforcing the CRTC Code represents one of the largest gaps in alcohol advertisement regulations in Canada. This process, which was made voluntary in 1996, has made it possible for alcohol advertisers, fearing little in terms of consequences, to disregard the CRTC Code. (13) Without key deterrents in place that guard against potential irresponsible alcohol advertising, young and impressionable children and youth will not be protected from exposure to alcohol advertisements. Even if contravening ads are pulled by advertisers, it is post-facto because children and under-aged audiences will have already been exposed to them.
The need to strengthen alcohol advertising regulation in Canada
Consistent with recent reviews on alcohol advertising (1,2) and the Global Alcohol Strategy, (14) there is a dire need for effective alcohol advertising control policies to address the harmful effects of alcohol advertising, especially among children and underage youth. Without a unified regulatory system governing and enforcing compliance around alcohol advertising, several limitations exist. To address such limitations, evidence gathered from literature reviews and key informant interviews were used to inform recommendations made for Canadian policy-makers, advertising standard agencies, and public health groups.
Table 2 outlines 23 activities to support 13 recommendations within three primary domains that can be made to strengthen current alcohol advertising regulations in Canada, organized according to predicted feasibility based on the authors' analysis. Implementation of all of these recommendations will require development of political will. The majority of recommendations are feasible within current regulatory structures. Some novel approaches will require creative solutions and even international cooperation to be most effective. As shown, recommendations to regulate scope of advertising including introducing volume and content restrictions, are generally feasible. Regulations to cover new media sources will be more difficult to implement and will require creative cross-jurisdictional partnerships to better ensure success. The majority of recommendations related to regulating procedures are seen as feasible within existing administrative structures. The main difficulty will be the implementation of effective enforcement sanctions. Recommendations for the provision of additional support are generally feasible. Nevertheless, implementation will need to address the lack of dedicated funds to increase public awareness around system limitations. Predicted barriers are similar across all recommendations and include weak political will, differing political priorities, and a lack of funding and staffing to establish new protocols. Also problematic are the anticipated lobbying efforts from the alcohol industry against any new controls.
In response to all of these recommendations, governing bodies and advertising standard agencies need to take active roles in controlling all alcohol advertisements, including both volume and content exposed to children and youth, so that all types of media channels are consistently and effectively regulated and enforced.
Finally, it is important to recognize that no single measure can act as a definitive solution to tackle the effects of alcohol advertising on young people's drinking, and therefore regulation should be complemented with other policy levers and interventions led by Public Health, while given adequate time to have an effect. (3) Such interventions may include educating and mobilizing a community around the limitations of the current system along with advocating for additional research-based limits through political means, such as provincial alcohol strategies.
Received: December 29, 2011
Accepted: May 5, 2012
(1.) Smith LA, Foxcroft DR. The effect of alcohol advertising, marketing and portrayal on drinking behaviour in young people: Systematic review of prospective cohort studies. BMC Public Health 2009;9(51). Available at: www.biomedcentral.com/content/pdf/1471-2458-9-51.pdf (Accessed October 1, 2010).
(2.) Anderson P, de Bruijin A, Angus K, Gordon R, Hastings G. Impact of alcohol advertising and media exposure on adolescent alcohol use: A systematic review of longitudinal studies. Alcohol and Alcoholism 2009;44(3):229-43.
(3.) Babor TF, Caetano R, Casswell S, Edwards G, Giesbrecht N, Graham K, et al. Alcohol: No Ordinary Commodity. Research and Public Policy. Oxford, UK: Oxford University Press, 2003.
(4.) Barry AD, Goodson P. Use (and misuse) of the responsible drinking message in public health and alcohol advertising: A review. Health Educ Behav 2010;37(2):288-303.
(5.) Heipel-Fortin RB, Rempel B. Effectiveness of alcohol advertising control policies and implications for public health practice. McMaster University Med J 2007;4(1):20-25.
(6.) Association to Reduce Alcohol Promotion in Ontario. ARAPO ADS UP! [Newsletter], 2004. Available at: www.apolnet.ca/arapo/newsletters/ARA-POWinter04Newsletter.pdf (Accessed October 1, 2010).
(7.) Newfoundland and Labrador's Teacher's Association. Education program for youth on alcohol advertising. The Bulletin 2005;49(2). Available at: www.nlta.nl.ca/files/documents/bulletins/bultn_nov05.pdf (Accessed November 1, 2010).
(8.) Association to Reduce Alcohol Promotion in Ontario. Under the Influence? Educator's Kit on Alcohol Advertising for Students in Grades 7-10, 3rd Edition. Toronto, ON: Ontario Public Health Association, 2006. Available at: www.tigweb.org/images/resources/tool/docs/1349.pdf (Accessed November 5, 2010).
(9.) Association to Reduce Alcohol Promotion in Ontario. The Booze Buzz Peer Education Project. Toronto: Ontario Public Health Association, 2006. Available at: www.apolnet.ca/resources/pubs/briefingnotes/BN-BoozeBuzz.pdf (Accessed November 1, 2010).
(10.) van den Broeck A, de Bruijn A. Effective alcohol marketing regulations: Policy report. The Netherlands: Dutch Institute for Alcohol Policy & European Centre for Monitoring Alcohol Marketing, 2010. Available at: www.eucam.info/content/bestanden/policy-report-alcohol-marketing.pdf (Accessed November 1, 2010).
(11.) de Bruijn A, Johansen I, van den Broeck A. Effective alcohol marketing regulations: A proposed framework to evaluate existing alcohol marketing strategies. The Netherlands: Dutch Institute for Alcohol Policy and European Centre for Monitoring Alcohol Marketing, 2010. Available at: www.faseproject.eu/content/bestanden/effective-alcohol-marketing-regulations- a-proposed-framework-to-evaluate-existing-alcohol-marketing-regulations.pdf (Accessed November 1, 2010).
(12.) Fortin R, Rempel B. The Effectiveness of Regulating Alcohol Advertising: Policies and Public Health. Prepared for the Association to Reduce Alcohol Promotion, 2005.
(13.) Novak J. Alcohol Promotion and the Marketing Industry: Trends, Tactics, and Public Health. Association to Reduce Alcohol Promotion in Ontario. Toronto: OPHA, 2004. Available at: http://www.apolnet.ca/resources/pubs/rpt_Effectiveness-Dec05.pdf (Accessed August 18, 2010).
(14.) World Health Organization. Draft Global Strategy to Reduce the Harmful Use of Alcohol, 2010. Available at: www.eucam.info/content/bestanden/who-2010-global-strategy.pdf (Accessed November 1, 2010).
Carly M. Heung, MPH,  Benjamin Rempel, MPH,  Marvin Krank, PhD 
[1.] Ontario Public Health Association, Toronto, ON
[2.] University of British Columbia, Kelowna, BC
Correspondence: Ms. Carly Heung, Research Coordinator, Health Promotion, Chronic Disease, and Injury Prevention, Public Health Ontario, 480 University Avenue, Suite 300, Toronto, ON M5V 1V6, Tel: 647-260-7341, Fax: 647-260-7600, E-mail: email@example.com
Acknowledgements: The authors acknowledge and thank all of the key informants who provided valuable insights to inform this paper. Funding for the work discussed in this paper was supported by a research grant secured by the Ontario Public Health Association.
Disclaimer: Ms. Heung and Mr. Rempel are now at Public Health Ontario, Toronto, ON. The opinions, results and conclusions reported in this paper are those of the authors. No endorsement by Public Health Ontario or by the Ontario Public Health Association is intended or should be inferred.
Conflict of Interest: None to declare.
Table 1. Evidence-based Framework for an Effective Alcohol Advertising Regulatory System (10) Component Elements Content Restrictions--Content Content restrictions are said to be restrictions can protect all effective at protecting young people consumers against misleading against attractive advertisements or deceptive alcohol only if: advertisements and in 1. Content restrictions address all particular, young people elements that have shown to be against attractive appealing to young people and do advertisements. not just state that alcohol advertising cannot be specifically aimed at minors. Such elements might include lifestyle images, use of humour, celebrities, cartoons, and sexual content; 2. Content restrictions limit advertisements that young people find appealing even if these are not specifically targeting minors, or that are specifically appealing to minors (but to adults as well); and 3. Alcohol advertisements are evaluated according to young people's interpretation and not according to the intention of the advertiser. Volume Restrictions--Volume Volume restriction measures are said restrictions are a necessary to be effective only if they meet the tool in protecting young following criteria: people against the cumulative 1. Volume restriction measures are effects of exposure from large not merely symbolic policies but volumes (both in quantity or contribute substantially to the specific locations) of alcohol total volume of alcohol advertisements on drinking advertising to which adolescents behaviour. In practice, there are exposed; and have been three types of 2. No significant substitution volume restriction measures, effects arise (e.g., shift to including a) restrictions on other media or price decrease). certain times or places, b) restrictions on certain types of media, and c) restrictions on certain types of alcoholic beverages. Supporting Infrastructure-- Elements to an effective alcohol While both content advertising regulatory system restrictions and volume include: restrictions should be 1. A supporting legal context--No employed, the effectiveness of conflicting regulations on the alcohol advertising national or international level regulations depends not solely and a legal backstop is needed to on these content and/or volume support the enforcement of the restrictions, but also on the restrictions; system that supports them. 2. Commitment of all stakeholders (including policy-makers, public health advocates/consumer representatives, and industry-related stakeholders) to increase the support of and adherence to the restrictions; 3. Transparency, which includes the availability of information to the public at every stage of the regulation process--including what and how decisions are made during the pre-screening and complaints process; 4. A mandatory pre-screening system with a public health interest to prevent both public exposure to advertisements that are non-compliant with restrictions and breaches of the 5. Effective complaint system with easy access to and support from the public--Complaints should be monitored by a third party; 6. An independent advertising committee--Evaluation by parties independent from commercial interests (not by advertising industry-related or alcohol industry-related, but by judges, public health advocates or consumer representatives); 7. Effective sanctions--Sanctions that are expected to be most effective are: withdrawing broadcasting rights and substantial financial penalties. Sanctions that are expected to be less effective are: bad publicity or voluntary action; 8. Monitoring to assess the effectiveness of the system and record the potential effects of new marketing techniques; monitoring should 1) be performed by parties independent from commercial interests, 2) be conducted routinely and systematically, 3) include content, volume, as well as "unmeasured" types of alcohol marketing practices, and 4) include public disclosure of alcohol marketing expenditures to third parties (government, academic institutes, or civil society); 9. Coverage and flexibility-- Restrictions should cover the entire range of forms of marketing activities and should be updated regularly to respond to potential shifts in unregulated types of alcohol marketing practices. Table 2. Strengthening the Regulation of Alcohol Advertisements in Canada Recommendations Activities Regulating Scope 1. Strengthen content Mandate content restrictions to restrictions (governing address all elements appealing to bodies) youth; Consolidate all content restrictions into one document; Outline what is allowed in content restrictions, rather than what is not allowed. 2. Develop and implement Employ statutory watersheds to codes for volume restrictions limit the time of day alcohol (governing bodies) advertisements would be allowed to be shown on television; Develop and implement volume restrictions based on the viewing habits of underaged viewers. 3. Increase coverage of alcohol Regulate both measured and advertising regulations unmeasured media outlets, (governing bodies) particularly new media and the Internet; Prohibit marketing practices that are difficult to monitor and are being used to reach children and underage youth. Regulating Procedures 4. Reinstate federal mandatory Revert back to enforcing mandatory pre-screening process pre-clearance of alcohol ads by (governing bodies) federal and provincial bodies with a strong public interest mandate. 5. Improve current complaints Adjust the current complaints system (governing bodies) systems to ensure both a simpler and quicker process; Remove biases from reviews being made on complaints. 6. Create an independent Include representatives free from panel of representatives any alcohol industry ties to (governing bodies) review the appropriateness of alcohol advertisements during the pre-screening process as well to review complaints; Include representatives from public health, children and youth organizations, objective media, and marketing experts. 7. Increase transparency Ensure that all alcohol (governing bodies) advertising decisions are made in consultation with both federal and their respective provincial health agencies. 8. Develop and implement a Develop a self-regulatory code public health-informed that specifically addresses advertising standards code for advertising of alcoholic alcoholic beverages beverages; (advertising standards agencies) Ensure that development of a self- regulatory code is made by people with a public health background rather than with a legal or exclusively business background. 9. Implement an effective Implement regular and systematic monitoring system monitoring of alcohol advertising (governing bodies) activities, including public disclosure of alcohol marketing expenditures, use of various mediums for alcohol advertisements, and compliance of advertisements with codes for responsible advertising. 10. Enforce effective sanctions Develop and implement an effective (governing bodies) administrative and deterrence system for infringements on marketing restrictions; Include real consequences, such as bans on marketing products for a specified time period or financial penalties, on advertisers who breach rules. Provision of Additional Supports 11. Advocate; cultivate Advocate for additional limits on collaborations and alcohol advertising to prevent partnerships (Public Health irresponsible messages from being and community interest targeted to underage drinkers; groups) Ensure Public Health's role in cultivating collaborations and partnerships. 12. Conduct additional research Review the literature for specific (Public Health and community elements of initiatives that have interest groups) been evaluated for effectiveness at counteracting the influences from alcohol advertising. 13. Increase public awareness Inform future provincial alcohol (Public Health and community strategies by specifying the interest groups) specific elements of the alcohol advertising regulatory system that require updating; Increase public awareness around the limitations of the current alcohol advertising regulatory system. Recommendations Implementation Considerations Regulating Scope 1. Strengthen content Feasible to implement: restrictions (governing Recommendation is administrative bodies) in nature as existing codes could be altered to accommodate. 2. Develop and implement Concerns with implementation: codes for volume restrictions A monitoring and compliance system (governing bodies) would need to be established to ensure restrictions are adhered to by advertisers. 3. Increase coverage of alcohol Difficult to implement: advertising regulations (governing bodies) Internet and new media are currently difficult to monitor and measure. Creative cross- jurisdictional strategies would need to be employed to effectively address this recommendation. Regulating Procedures 4. Reinstate federal mandatory Feasible to implement: pre-screening process (governing bodies) Before 1996, pre-clearance of alcohol advertisements were mandatory. Reverting back to past processes is predicted to be feasible for recommendation implementation. 5. Improve current complaints Feasible to implement: system (governing bodies) Recommendation is administrative in nature as existing codes could be altered to accommodate. 6. Create an independent Feasible to implement: panel of representatives (governing bodies) Before 1996, pre-clearance of alcohol advertisements were mandatory. Reverting back to past processes while ensuring representatives from health organizations are included is predicted to be feasible. 7. Increase transparency Feasible to implement: (governing bodies) Consultation processes can likely be established and maintained under current administrative structures. 8. Develop and implement a Feasible to implement: public health-informed advertising standards code for Working closely with government alcoholic beverages and national public health (advertising standards agencies, Advertising Standards agencies) Canada could be tasked with developing and introducing new codes. 9. Implement an effective Concerns with implementation: monitoring system (governing bodies) A monitoring system would need to be established to ensure public disclosure of alcohol marketing expenditures, medium tracking, and compliance rates. 10. Enforce effective sanctions Difficult to implement: (governing bodies) An administrative and deterrence system would need to be established to process infringements on marketing restrictions. Complete advertising bans and financial penalties within other jurisdictions have been seen to be effective, but also difficult to accomplish. Provision of Additional Supports 11. Advocate; cultivate Feasible to implement: collaborations and partnerships (Public Health Public health units or regional and community interest health authorities could work in groups) collaboration to advocate and pressure governing bodies for additional advertising limits. 12. Conduct additional research Feasible to implement: (Public Health and community interest groups) Research grants could be secured by national public health groups to collate and report on evaluated and effective initiatives. 13. Increase public awareness Concerns with implementation: (Public Health and community interest groups) Future provincial alcohol strategies could specify specific elements of the regulatory system that require attention. Increasing public awareness may require significant funding to accomplish.
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|Author:||Heung, Carly M.; Rempel, Benjamin; Krank, Marvin|
|Publication:||Canadian Journal of Public Health|
|Date:||Jul 1, 2012|
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