No way to ignore it - Alcohol Advertising Review Board

No way to ignore it:
The case for removing alcohol ads from public transport
09
No way to ignore it: The case for removing alcohol ads from public transport
McCusker Centre for Action on Alcohol and Youth and Cancer Council Western Australia
Published January 2016
The Alcohol Advertising Review Board operates with support from health organisations around Australia.
This work is copyright. Apart from any use as permitted under the Copyright Act 1968, no part may be
reproduced by any process without prior written permission from the McCusker Centre for Action on
Alcohol and Youth.
© McCusker Centre for Action on Alcohol and Youth, 2016
Contents
Alcohol Advertising Review Board................................................................................................................ II
Foreword..................................................................................................................................................... III
Alcohol advertising and young people.......................................................................................................... 1
Outdoor alcohol advertising.......................................................................................................................... 1
Young people and public transport............................................................................................................... 2
Alcohol advertising on public transport and transit stops in Australia........................................................... 2
Regulation of outdoor advertising placement in Australia............................................................................ 2
Complaints: alcohol ads on public transport and transit stops..................................................................... 3
Failure of the Outdoor Media Association guideline..................................................................................... 4
Action taken by governments in Australia.................................................................................................... 5
International approaches to public transport alcohol advertising regulation................................................. 5
Removal of alcohol advertising on public transport and transit stops........................................................... 6
Conclusion.................................................................................................................................................... 7
References................................................................................................................................................... 8
The Case for Removing Alcohol
Ads from Public Transport
Alcohol Advertising Review Board
The Alcohol Advertising Review Board (AARB) considers and reviews complaints from the Australian
community about alcohol advertising. The AARB was developed by the McCusker Centre for Action on
Alcohol and Youth and the Cancer Council WA, supported by other health organisations, in response to the
numerous weaknesses of the current self-regulatory alcohol advertising system.
The AARB reviews complaints on the basis of the Alcohol Advertising Review Board Code (the Code),
which sets criteria for acceptable alcohol advertising in Australia. The Code aims to ensure alcohol
advertising (i) is socially responsible, (ii) neither conflicts with nor detracts from the need for responsibility
and moderation in liquor merchandising and consumption, and (iii) does not encourage young people
to drink. The Code, which is primarily constructed using provisions from existing codes established by
alcohol industry bodies from around the world, can be found at www.alcoholadreview.com.au
Alcohol...
...is one of the
most heavily
promoted
products in
the world.1
II
The Case for Removing Alcohol
Ads from Public Transport
Foreword
This latest report from Australia’s Alcohol Advertising Review Board
is an important contribution to the debates around alcohol advertising
and youth that are occurring around the globe. With alcohol as the
leading cause of death and disability among young males ages 15-24 in
all regions of the world except the Eastern Mediterranean, and among
females in that age group in the wealthy countries and the Americas,1
and with at least 15 longitudinal studies now associating youth
exposure to alcohol marketing with youth drinking behavior,2-4 there
is ample cause for concern about the short- and long-term impact of
youth exposure to alcohol advertising.
This report highlights two forms of alcohol advertising in particular:
outdoor and public transit. My colleagues and I recently published an
account of the landmark efforts in Baltimore to remove alcohol and tobacco billboard advertising from
the city’s residential neighborhoods. Baltimore was the first city in the United States to ban this kind
of advertising legislatively. A community coalition led by local grandmothers weathered challenges up
to the level of the United States Supreme Court. As a result of their efforts, within weeks of the final
court decision the number of alcohol and tobacco billboards in Baltimore fell from more than 1300 to
approximately 70.5
In Boston, Massachusetts, a coalition of young people and adults succeeded following a six-year campaign
to convince the city’s transit system in 2012 to stop advertising alcohol, after it had been wrapping its
buses in vodka advertisements. Research showing that alcohol advertisements on public transit in Boston
were viewed an estimated 18,269 times on an average weekday by Boston Public School student transit
passengers, reaching the equivalent of 54.1% of that population, underscored the need for the ban.6
Alcohol industry self-regulation is still the primary means of limiting youth exposure to alcohol advertising
in much of the world. These stories and this report illustrate the importance of citizen voices and stronger
measures as a crucial response to the failure of industry self-regulation if we are to significantly reduce
this risk factor in the lives of young people.
Dr David H. Jernigan
Director, Center on Alcohol Marketing and Youth
Johns Hopkins Bloomberg School of Public Health
Baltimore, USA
1. Gore FM, Bloem PJ, Patton GC, et al. Global burden of disease in young people aged 10-24 years: a systematic analysis. Lancet.
2011;377(9783):2093-2102.
2. Anderson P, De Bruijn 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 Alcohol. 2009; 44(3):229-243.
3. Grenard JL, Dent CW, Stacy AW. Exposore to alcohol advertisements and teenage alcohol-related problems. Pediatrics. 2013; 131(2):e369-e379.
4. Chang FC, Lee CM, Chen PH, et al. Using media exposure to predict the initiation and persistence of youth alcohol use in Taiwan. Int J Drug Policy.
2014; 25(3):386-392.
5. Meisel P, Sparks A, Eck R, Jernigan D. Baltimore CIty's landmark alcohol and tobacco billboard ban: An implementation case study. Inj Prev. 2014;
published Online First 22 July.
6. Nyborn JA, Wukitsch K, Siegel M. Alcohol advertising on Boston's Massuchusetts Bay Transportation Authority transit system: An assessment of
youths' and adults' exposure. Am J Public Health. 2009; 99(S3):S644-648.
III
The Case for Removing Alcohol
Ads from Public Transport
Alcohol advertising and young people
Alcohol is one of the most heavily promoted products in the world.1 Australian children and adolescents
are exposed to unacceptably high levels of alcohol advertising in many different forms, including outdoor
advertising on billboards, buses, trams, and at bus stops and train stations. It is well established that
alcohol advertising has an impact on young people. Exposure to alcohol advertising influences young
people’s beliefs and attitudes about drinking, and increases the likelihood that adolescents will start to use
alcohol and will drink more if they are already using alcohol.2-4 Exposure to alcohol advertising contributes
to the normalisation of alcohol use and works to reinforce the harmful drinking culture that exists in
Australia.5
The World Health Organization,6 the Australian Medical Association,5 the National Preventative Health
Taskforce7 and other expert groups have recommended restricting alcohol advertising during times and
in places which have high exposure to children and young people as part of a comprehensive approach
to reducing alcohol related harms. There is strong community support for effective regulation to protect
young people from alcohol promotion; 72% of Australian adults support legal controls to reduce young
people’s exposure to alcohol advertising, with only 6% opposed.8
72% of Australian adults support legal controls to reduce
young people’s exposure to alcohol advertising,
with only 6% opposed.
Outdoor alcohol advertising
Outdoor advertising continues to be a major promotional medium for advertisers. Advertising across
billboards and outdoor media is forecast to account for 9% of advertising industry revenue in 2015-16,
up from 7% in 2008-09 due to new advertising methods and an increasing number of advertisement
locations at bus and train stops, on public transport and at sporting events.9,10 The advertising industry
reports that while other traditional media continue to decline in both audience and market share, out-ofhome advertising, which covers advertising on billboards, posters, public transit stops, public transport,
in shopping centres and airports, continues to grow.11 The Outdoor Media Association reported that
Australians are likely to see an average of 26 ads across out-of-home sites each day11 and out-of-home
advertising reaches 12.2 million people daily across Australia.12
In 2014, the Outdoor Media Association listed alcoholic beverages as ninth in the top 20 advertising
categories, with a spend of $27.5 million on out-of-home advertising.13 An analysis of alcohol advertising
expenditure in Australia found outdoor advertising expenditure on billboards alone increased from 1997 to
reach a peak of $45.8 million in 2007.14
Outdoor advertising cannot be switched off, avoided or
ignored, and it is impossible to control who views outdoor
alcohol ads.
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The Case for Removing Alcohol
Ads from Public Transport
Outdoor advertising cannot be switched off, avoided or ignored, and it is impossible to control who views
outdoor alcohol ads. The advertising industry themselves describe outdoor advertising as "ubiquitous",
"effective" and "always on, deliving messages 24 hours a day, seven days a week".13 Children and young
people can be expected to be heavily exposed to outdoor advertising, including ads placed on public
transport and at transit stops. These ads are highly visible to those driving and walking past, as well as
those using public transport.
Young people and public transport
Public transport accounts for approximately 10% of total urban passenger travel in Australia.15 Various
data sources provide evidence that children and young people represent a substantial proportion of public
transport users:
»» A community survey of parents of school-aged children found one in five children use public transport
to get to school.16
»» Around half of secondary school students use public transport to travel to and from school at least once
a week.17
»» Young people aged 18 to 24 years are more likely than older people to use public transport.18
»» In Western Australia (WA) in 2014-15, students up to Year 12 accounted for 13% of cash and paid
SmartRider* boardings. The Public Transport Authority in WA noted that the start of the new school
arrangement in 2015 where Year Seven students were transitioned from primary school to high school
saw a greater demand for Transperth to get students to and from school.19
»» In New South Wales (NSW) in 2013-14, subsidised travel was provided to half a million school students
on rail, bus, ferry and long-distance coach services under the School Student Transport Scheme.20 On
an average week day in Sydney in 2012-13, 9.1% of public transport fares on trains and 27.4% on buses
were for free school passes.21
*
A SmartRider is a reusable smart card used to pay for travel on Transperth services.
Alcohol advertising on public transport and transit stops in Australia
Alcohol advertising on public transport and transit stops is widespread. An audit of bus stop ads in Perth,
WA, found almost a quarter (172 of 744) of ads identified were for alcohol products, and alcohol was
the dominant category.22 An audit of ads at train stations in Sydney, NSW, found that 21 locations had
billboards advertising food or beverages, and of the 81 unique ads identified, the greatest proportion was
for alcohol (27%).23 The extent of alcohol advertising on public transport and transit stops means children
and young people are highly likely to be exposed to alcohol advertising placed on the sides of buses and
trams, on bus stops and at train stations.
Regulation of outdoor advertising placement in Australia
The Outdoor Media Association (OMA) is the industry body that represents most of Australia’s outdoor
media display companies.24 The OMA is part of the self-regulatory system in Australia, and has a Code
of Ethics that outlines voluntary principles for its members.25­The OMA’s Alcohol Advertising Guidelines
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The Case for Removing Alcohol
Ads from Public Transport
set only one restriction upon the placement of outdoor alcohol advertising; that it not be displayed
within a 150 metre sight line of a school gate. This guideline does not apply where there is a club, pub or
bottleshop in the vicinity of the school, and does not apply to advertising on buses, trams and taxis.26
There have been many instances where this restriction has been breached, demonstrating the failure of
OMA’s monitoring and enforcement of the Alcohol Advertising Guidelines. In addition, 150 metres is a
very small distance, and buses, trams and taxis drive past schools every day, further demonstrating that
the guidelines are inadequate in protecting children and young people from exposure to outdoor alcohol
ads.
Complaints: alcohol ads on public transport and transit stops
Since its launch in March 2012, the AARB has received 130 complaints regarding alcohol ads placed on
public transport and transit stops that would be expected to have high exposure to young people (18% of
all complaints). Section (7) of the AARB Placement Code states:
7. Transport advertising
No Alcohol Advertisements shall be placed on any means of public transport.
No Alcohol Advertisements shall be placed at any train, tram, bus or ferry stops.
The title of this report, "No way to ignore it", was taken directly from a complaint received by the Alcohol
Advertising Review Board regarding an alcohol ad on public transport: "Buses drive all through our streets,
past schools and playgrounds, and children would undoubtedly see the ads as there is no way to ignore it".
Table 1 summarises the type of public transport and transit stops the complaints related to from 16 March
2012 to 31 December 2015.
Number of public transport and transit stop complaints received
by the AARB
Bus ad
40
Bus stop ad
75
Train station ad
11
Tram ad
4
Total130
Examples of complaints received by the AARB relating to public transport and transit stop advertising
include:
»» An Eristoff Vodka bus stop ad next to a children’s playground in Adelaide, SA in March 2012 (ref 1/12).
»» Bulleit Bourbon ads at Camberwell train station in Camberwell, VIC in December 2013 (ref 246/14).
»» A Jack Daniel’s ad at Town Hall train station in Sydney, NSW in October 2013 (ref 227/13).
»» A Johnnie Walker Red Label bus stop ad outside a supermarket in Canberra, ACT in January 2014 (ref
268/14).
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The Case for Removing Alcohol
Ads from Public Transport
»» A Brown Brothers ad seen on a tram in Melbourne, VIC in February 2014 (ref 274/14).
»» A XXXX Summer Bright Lager bus stop ad near a university in Perth, WA in February 2015 (ref 381/15).
»» Five complaints for a Lemon Ed Hard Lemonade bus ad seen in Melbourne, VIC and Perth, WA
between July and September 2015.
In each example listed above, the AARB Panel found the ad contravened section (7) of the Placement
Code, as the ads were located in popular public places where children and young people were highly likely
to be exposed to them.
There is substantial concern around young people’s exposure to alcohol advertising on public transport
and transit stops, especially those in close proximity to schools. A survey of Western Australian adults
shows 72% support removing alcohol advertising from buses and bus stops to reduce young people’s
exposure, with only 10% opposed.27
72% support removing alcohol advertising from buses and bus
stops to reduce young people’s exposure, with only
10% opposed.
Failure of the Outdoor Media Association guideline
The AARB is aware of several instances where the OMA’s guideline restricting alcohol ads from being
placed within 150m of a school gate has been breached, with seemingly no consequences. For example,
the AARB has received five complaints about alcohol ads on bus stops located outside schools:
»» January 2014: Corona ad placed near a primary school
in WA (ref 253/14).
»» April 2014: Dan Murphy’s ad placed directly outside a
primary school in WA (ref 291/14). The placement of
the ad received media attention, pictured right.28
»» July 2014: complaint regarding a Coopers Brewery ad
placed near two schools in Canberra, ACT (ref 302/15).
»» September 2014: a restaurant/hotel ad featuring two
people drinking wine placed directly outside a primary
school in WA (330/14).
»» November 2014: Smirnoff Vodka ad placed across the
road from a primary school in Melbourne, VIC (ref 350/15).
All five complaints were upheld. These are only examples of which the AARB has been made aware. It
is likely that there are many more alcohol ads that have been placed outside schools where children and
young people would have been exposed.
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The Case for Removing Alcohol
Ads from Public Transport
These examples demonstrate the failure of the Outdoor Media Association’s Alcohol Advertising
Guidelines. Not only are the guidelines narrow and inadequate to prevent young people’s exposure to
outdoor alcohol ads, the Outdoor Media Association’s ineffective monitoring and enforcement processes
have consistently failed to prevent inappropriate placement of outdoor alcohol ads. It is evident that there
is an urgent need for much stronger regulation to reduce young people’s exposure to alcohol advertising,
including ads on public transport and transit stops.
Action taken by governments in Australia
In September 2015, the ACT government announced that alcohol advertising will no longer be allowed
on public buses. In announcing the restriction, Minister for Territory and Municipal Services, Shane
Rattenbury MLA, said:
“ACTION buses travel right across our city and most people travelling about Canberra will
encounter a bus most days of the week. Advertising on our buses is clearly a good way to reach
a large cross-section of the community. In particular, a significant number of ACTION passengers
who are school-aged children. I think it is really important that we don’t have alcohol, junk food
and gambling advertised on our buses…
While the Federal Government retains regulatory control of substantial advertising policy, it is
important that the ACT Government does what it can to ensure that the advertising on our public
assets is suitable and appropriate and in line with the values of the Canberra community.”29
To our knowledge, the ACT is the only Australian jurisdiction to restrict alcohol advertising on their public
transport services.
International approaches to public transport alcohol advertising
regulation
Several other countries have policies and legislation around alcohol advertising on public transport and
transit stops. These include Finland, Ireland and numerous jurisdictions within the USA.
In February 2014, the President of Finland signed off on proposed amendments to Finland’s alcohol
advertising legislation, which would see outdoor alcohol advertising prohibited, including on billboards, bus
stops and public transport vehicles (excluding sporting and cultural events).30,31 These restrictions aim to
reduce the number of situations in which children and young people are exposed to alcohol advertising30
and came in to effect on 1 January 2015.32,33
In the USA, numerous state capital cities have policies restricting alcohol advertising on public transport
vehicles. A 2013 review of alcohol advertising policies of 32 major metropolitan transit agencies and
city departments that control transit advertising in the USA found 18 agencies have alcohol advertising
explicitly banned in agency policy (formally adopted by the administering body of the transit authority),
contract requirements (stated in the contract between the transit agency and the advertiser), government
policy (codified by the government body that controls the transit agency), or a combination of these.34
San Francisco (California), Philadelphia (Pennsylvania) and Honolulu (Hawaii) public transit agencies
operate under city ordinances that prohibit alcohol advertising on city property, in addition to contract
requirements and agency policy. Maryland Transit Administration, a state-managed transit system that
covers the city of Baltimore, is subject to an executive order banning alcohol advertisements on all
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The Case for Removing Alcohol
Ads from Public Transport
property owned by the agency, requiring all contracts to reflect this order.
San Francisco (California) provides an interesting example of community opposition to alcohol advertising
on public transport. In 2006, a policy allowing alcohol advertising on the San Francisco Bay Area Rapid
Transit (BART) system was introduced, with alcohol advertisements expected to generate $400,000
in revenue for the transit agency facing a budget deficit.35 A California-based not-for-profit organisation
formed a coalition of local prevention and youth groups to lobby city officials and board members to
reverse the decision.36 At a hearing regarding the policy, the Board heard testimonies from coalition
members on the research associating alcohol advertising with alcohol use among young people, and
young people spoke about the BART’s responsibility to keep alcohol advertisements off trains and train
stations. As a result, several BART Board members changed their position on the issue and the policy was
abandoned. As the BART director stated: “There are plenty of places that advertise alcohol. I just don’t
think that public transit, funded by the public, should be one of them.”36
“There are plenty of places that advertise alcohol. I just don’t
think that public transit, funded by the public, should be one
of them.”
In January 2015, following a campaign by public health groups, the Los Angeles City council voted to ban
alcohol-related advertising on city property in Los Angeles, including bus benches and bus shelters.37
In December 2015, the Minister for Health in Ireland published the Public Health (Alcohol) Bill which
includes restrictions on alcohol advertising and promotion in Ireland.38 The proposed legislation states that
alcohol products cannot be advertised in or on public service vehicles, trains, light rail vehicles, and in or at
train or bus stations.39 The Bill is yet to be fully implemented.
Removal of alcohol advertising on public transport and transit stops
There is international precedent for effective government
regulation of alcohol advertising on public transport and
transit stops.
There is international precedent for effective government regulation of alcohol advertising on public
transport and transit stops. Phasing out the placement of alcohol advertising on public transport and
transit stops is an important step to ensure young people’s exposure to alcohol advertising is minimised.
The AARB calls on each State and Territory Government to amend advertising agency contracts or existing
legislation to prohibit the display of alcohol advertising on public transport and transit stops, including on
buses, trains and trams, and at train stations and bus stops.
There is also important scope for Local Governments to take early action by introducing policies to prohibit
alcohol advertising on transit stops in their communities.
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The Case for Removing Alcohol
Ads from Public Transport
Conclusion
There is a need for strong, independent, legislated controls on all forms of alcohol advertising and
promotion in Australia. Leaving regulation of advertising to the alcohol and advertising industries does
not work; the industries have demonstrated again and again that they are unable to prevent the exposure
of children and young people to alcohol promotion, and are unable to ensure that all forms of alcohol
advertising and promotion are socially responsible.
Constraints on alcohol advertising and promotion are an essential part of a comprehensive approach
to preventing harm from alcohol. The AARB continues to advocate for effective regulation of alcohol
advertising and promotion at a federal level. However, with high levels of concern about alcohol and young
people, it is appropriate and necessary for State and Local Governments to take action to reduce young
people’s exposure to alcohol advertising. This has been demonstrated by the ACT Government as well as
internationally. Public transport and transit stops are locations where children and young people are clearly
and substantially exposed to alcohol promotion. Removing alcohol promotion from these locations is an
important step that can and should be taken now by State and Local Governments.
7
The Case for Removing Alcohol
Ads from Public Transport
References
8
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Jernigan D. The extent of global alcohol marketing and its impact on youth. Contemp Drug Probl. 2010;
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Anderson P, de Bruijn A, Angus K et al. Impact of Alcohol Advertising and Media Exposure on Adolescent
Alcohol Use: A Systematic Review of Longitudinal Studies. Alcohol Alcohol. 2009; 44(3):229–243.
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Outdoor Media Association. 3.6% Audience Growth for Outdoor [media release]. 2014 May 19. Available from:
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Ads from Public Transport
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alcoholireland.ie/wp-content/uploads/2015/12/Public-Health-Alcohol-Bill.pdf
Alcohol Advertising Review Board
c/o McCusker Centre for Action on Alcohol and Youth
Curtin University Health Research Campus
GPO Box U1987
Perth WA 6845
[email protected]
www.alcoholadreview.com.au
Twitter: @AlcoholAdReview