Thank you for the opportunity to testify today on the topic of media ratings. I have conducted numerous studies over the past 15 years on the issues of media violence and sexual content, and served as a senior researcher from 1994-1998 on the National Television Violence Study, one of the largest media research projects to date. I have also followed the topic of media ratings closely since the introduction of the V-chip which Congress triggered with an amendment to the Telecommunications Act of 1996.

In my testimony today, I wish to cover three primary points: (1) why do we have media ratings; (2) how well are media ratings working to assist parents; and (3) how can media ratings be improved to better accomplish their purpose of informing parents about the nature of sensitive media content.

Concern on the part of the public and Congress about the harmful influence of media violence and other sensitive material on children dates back to the 1950s and 1960s. The legitimacy of that concern is corroborated by extensive scientific research that has accumulated since that time. Indeed, in reviewing the totality of empirical evidence regarding the impact of media violence, the conclusion that exposure to violent portrayals poses a risk of harmful effects on children has been reached by the U.S. Surgeon General, the National Institutes of Mental Health, the National Academy of Sciences, the American Medical Association, the American Psychological Association, the American Academy of Pediatrics, and a host of other scientific and public health agencies and organizations.

Lest I seem pedantic in reviewing this overwhelming consensus about the harmful effects of media violence, I must note a troubling development that has surfaced recently. Echoing patterns from the distant past, industry officials are once again contesting the premise that media violence poses a risk of harm for children. Indeed, in a letter written just weeks ago by Jack Valenti, Chairman of the Motion Picture Association, to Dr. David Walsh, President of the National Institute on Media and the Family, Mr. Valenti claims that the scientific community does not agree on the conclusions of research in this area. Mr. Valenti cites a recent research review funded by the Motion Picture Association that calls the evidence in this realm "inconsistent and weak." This stance sharply diverges from the position of industry leaders during the period in 1995-96 when the Congress was considering more stringent measures to address the problem of media violence. At that time, industry officials including Mr. Valenti were uniform in their recognition that media violence is a legitimate cause for concern, and they were quick to accept the V-chip rating system as an appropriate mechanism to address that concern in lieu of other policy options under consideration at the time that the industry found less palatable.

Notwithstanding Mr. Valenti’s recent comments, it is well established by a compelling body of scientific evidence that television violence poses a risk of harmful effects for child-viewers. While exposure to media violence is not necessarily the most potent factor contributing to real world violence and aggression in the United States today, it is certainly the most pervasive. Millions of children spend an average of approximately 20 hours per week watching television, and this cumulative exposure to violent images can shape young minds in unhealthy ways.

Using media ratings as a means to address the problem of violence and other sensitive material in the media has both advantages and disadvantages. By merely labeling rather than limiting the presentation of material likely to be harmful to children, the rights of adults to watch whatever they choose are protected. But there are two important issues involving the use of media ratings to reduce children’s exposure to violence and other types of potentially harmful content. One is the concern that parents may not understand and use the rating systems to help guide their children’s media use; and the other is that media content may not be accurately labeled, resulting in inappropriate content "slipping through the cracks" in the filtering system of the V-chip and other rating formats even though parents actively employ them. These are the two key issues to consider in evaluating how well the current rating systems are working.

Studies that examine parents’ knowledge about and use of the V-chip television rating system have produced mixed results to date. Research conducted by both the Kaiser Family Foundation and the Annenberg Public Policy Center indicate that although a substantial proportion of parents know about the ratings, there is a lot of confusion about the meaning of the various categories and labels. This may account for why only a modest proportion of parents report using the ratings to make decisions about what their children may watch.

In May of 1999, the Kaiser Foundation reported that 77% of parents said they would use the V-chip if they had one. But the same study also found that only 44% of parents "often" or "sometimes" used the TV ratings to help guide their children’s viewing. More recent research by the Annenberg Public Policy Center indicated that only about 50% of parents were aware of the V-chip ratings in 2000, compared to 70% in 1997 when the press coverage for the roll-out of the new system was at its peak. This reduction in the awareness of ratings almost certainly stems from the lack of any systematic effort by the television industry to publicize their ratings framework.

Even among those parents who know about the rating system, nine out of ten could not accurately identify the age ratings for a sample of programs their children watched, according to the Annenberg Center data. Confusion abounds about the meaning of many categories. For example, most parents mistakenly believe that the "FV" designation, which indicates "fantasy violence" in children’s shows, is meant to identify programs appropriate for "family viewing." Given this confusion within the V-chip rating system itself, it is hardly surprising that the lack of consistency across the rating systems used for differing media -- including films, television, music, and video games -- leads to even more consternation on the part of parents trying to figure it all out.

The second key issue to consider in assessing the efficacy of media ratings is whether or not the content that poses the greatest risk of harm to children is labeled accurately. If it is not, even those parents who understand and use the rating systems will not reap any benefits in reducing their children’s exposure to potentially harmful material. In this realm, there are a number of concerns. Research I have conducted in the first and second years following adoption of the V-chip rating system indicated that the age-based rating judgments (TV-G, TV-PG, TV-14, etc.) were being applied accurately, but that the content-based descriptors (V for violence, S for sex, etc.) were not. Indeed, the majority of programs that contained violence did not receive a "V" rating and thus any parent using the V-chip to screen out programs rated with a "V" would accomplish little in reducing their children’s exposure to television violence. If this pattern persists today, parents could not effectively screen out violent portrayals by relying upon the content-based aspect of the V-chip rating system.

A recent study by researchers at the National Institute on Media and the Family published in the June issue of Pediatrics found that parents tend to rate programs in more restrictive fashion than the judgments that are applied to the same shows by the television industry. Given the obvious economic incentive for television networks to rate programs leniently so as to avoid diminishing their audience and hence reducing their revenue stream, this is a worrisome finding.

Finally, one additional concern involves limitations in the design of the rating categories rather than their application to specific shows. Children’s programs may receive only one of two basic rating labels -- either TV-Y, appropriate for all youth; or TV-Y7, appropriate for children age 7 and over. In many children’s programs, there are significant amounts of violence that are presented in a manner that makes them particularly likely to encourage aggression and other harmful effects in child-viewers. For example, an episode of the futuristic cartoon "Beast Wars" showed hunters hovering in a helicopter, shooting wildlife below on the ground while exclaiming cheerfully "I love it when prey cannot shoot back!" The fact that such programs are rated as "fit" for those over age 7 strikes me as a fundamental design flaw in the current rating system, when clearly there are many children’s shows on television that are inappropriate for those in the 7-10 year old range due to their violent content. This structural limitation of the current V-chip system is an independent issue from the question of how accurately the ratings are applied to most programs primarily intended for adult audiences.

The assignment of media ratings are determined by those in the industry who are responsible for the content’s production and/or distribution. Practically speaking, there is probably no alternative to that course given the amount of material that must be categorized and the turn-around time constraints inherent in the rating process. Nonetheless, there is a rich body of scientific research that helps to identify the types of media content that pose the greatest risk of harmful effects on children. More training, education, or sensitivity on the part of raters to the relevant research about media effects on children is needed. This goal could be accomplished in a number of ways involving the cooperation of experts in the areas of child development, media effects, and the public health community. Unless media ratings can consistently and accurately label the content that poses the greatest risk of harm to children, such systems cannot accomplish much help for parents.

More active monitoring and oversight of the ratings process is also needed. While several of the media rating systems maintain advisory boards charged with supervisory responsibility, none have played a vigorous role in discharging their responsibilities to date, and all are dominated by media industry officials with only token participation at best by a parent or child advocate representative. There is a precedent for the television industry funding truly independent research from neutral parties to evaluate its performance in the realm of presenting violence responsibly, as was done with the National Television Violence Study and the UCLA Violence Report in the 1990s. Such an effort should be considered to evaluate the accuracy and consistency of rating judgments for the V-chip system as well as for other media rating systems.

Finally, it is time to seriously consider the prospects for a universal rating system that could be applied across all media. The lack of consistency across media in their rating formats makes it incredibly difficult for parents to master all of the subtleties that vary across television ratings, film ratings, video games, and so on. As Dr. David Walsh has noted in a letter to this committee, a media product that included extreme violence would be rated R if it were a movie, TV-MA if it were a TV show, M if it were a home video game, display a red sticker if it were an arcade video game, or have a "Parental Advisory" sticker if it were a music CD. This causes needless confusion for parents, and undercuts the utility of all rating systems.

An apt comparison in this regard involves the uniform system of food labeling that is employed in the U.S. A consistent framework that indicates calories, grams of fat, and so on is included on all food packaging, and the uniformity of the system facilitates easy comparison across all types of food products. Imagine that food labeling was not accomplished uniformly, but rather in idiosyncratic fashion that made comparisons across different products impractical. Such a labeling system would be of little value to consumers -- and that is the current situation we face with the alphabet soup of differing media rating systems.

I have already read the comments of media officials who claim "it can’t be done" when the prospect of a uniform rating system is raised, but this appears to be little more than a knee-jerk reaction. The "can’t be done" chorus was also heard when the V-chip idea first surfaced, but we have obviously proven that reaction wrong already. The potential value to parents of a uniform rating system is too great to pass up without serious consideration by all of the media industries. That consideration will not come without strong prompting from the public, and hearings such as this are an important catalyst to help focus the attention of already busy and overwhelmed parents on the importance of media in their children’s lives. I commend this committee for its pursuit of this issue and its contribution to the ongoing public dialogue about the efficacy of media ratings. Thank you for your time and for your attention to this important issue.