Process and Perils
of Rating Television

The rating system released in December by the TV Ratings Implementation Group (I.G.) is like a rebuilt aircraft with only the exterior color and shape completed. It is still an empty shell with no engine and wiring. None have been designed, and the latest from Jack Valenti is that there is no plan to do so within the I.G. The engine and wiring of a rating system are the standards and protocols which raters follow when they review shows. Rater's protocols help control personal or commercial bias and enable the use of valid public health principles that protect children from risk.

Parents need to be aware that the engines and wiring are being left to the personnel in the different TV networks who have limited expertise to design them. The latter already has been demonstrated by years of conflict within departments of broadcast standards and practices. Welcome aboard? Like the FAA, is the FCC caught in the conflict of simultaneously promoting industry and protecting the public? My experience is that the chair of the FCC, Reed Hundt, is a man with the nation's children and parents at heart. An 18 month minimum to explore options is possible.

If the I.G. system turns out to be only one of several sources of broadcast ratings codes, the public can choose their source. If the I.G proposal without considerable improvement is allowed to be the only system for our country, TV rating is not likely to function for parents as intended in the new law. There may well be ethical and legal challenges.

I believe that if a handful of specialists in this field put together what is known and already designed, a credible health-based TV classification system is close to completion. It would protect children, implement the law, meet parents' expressed needs for informed choices, respect creativity in television, and embrace the First Amendment.

I'm going to explain briefly my understanding of the goals of appraising television shows, of what the ethical issues are, and what the ingredients are of a valid and reliable health-based rating system which also respects the First Amendment.

The management and control of the television medium is not just about what parents might find personally objectionable or indecent. These are serious public health issues unique to the pervasiveness of television in the home as compared to movies. The health community knows from years of research and clinical experience that the viewing of certain television content poses specific, immediate and long term symptomatic and behavioral health risks to children and teenagers. A list of specific health risk effects has been described elsewhere and is available.

The Telecommunications Act of 1996, section 551, while embracing the First Amendment, attempts to address the need both to lower health risk and to foster free personal choice by empowering parents with advanced information. As I read it, the new law conveys parental empowerment in three ways:

1. By providing parents with advanced information about what is harmful, meaning information based on what has been demonstrated by research to raise the risk of harm.

2. By giving parents the opportunity to make informed choices about what they consider harmful and/or indecent, meaning giving them sufficient content information to make personal choices based on family values and assessments of their own children.

3. By putting viewer discretion technology ("V-chip") in the hands of parents to program their TV when they are not available to supervise their children's viewing.

As long as TV ratings are a valid public health tool and parents are given choices based on content information, we are operating ethically. Our society is morally permitted to restrict the liberties of some persons, in this case the TV industry, in order to prevent harm to others. Ethics also requires that parents receive information that does not contain hidden bias based on the moral, religious, and artistic beliefs and scientific misunderstandings of a diverse group of television raters. If parents are misled to believe by lack of clarification that a rating system is based on harm prevention when in fact it is not designed to do so, this is very problematic. Health principles and informed free choice are the main universal concepts that cross ethnic, religious and geographic boundaries.

Also, the risk of hidden bias seems high no matter who raters are, including child health experts or a group of parents. There is no room for arrogance here. To condense, for others, something as complex as a television show into a rating code of verbal descriptors, numbers, letters and icons is a task filled with risk of bias. How the mind is prepared determines what is and is not observed and what meanings are put on what is observed. For bias control and to ensure that child health remains a focus, the rating process must be structured and checked for validity and reliability. Selecting material for content codes and descriptors does not really get us around this issue either. Being ethical about TV rating, like providing health care, seems to require a lot of listening and large amounts of doubt and openness to explore different options.

There also are constitutional issues for TV writers and producers regarding TV rating. My consultation in August to the executive committee of the Caucus for Producers, Writers, and Directors confirmed this as did my participation in the PBS debate among major players in TV ratings hosted by Sonny Fox at the TV Academy of Arts and Sciences. Their biggest concerns are that naive ratings, which are out of the context of an entire show, will narrow opportunities to sell good writing, and worse, that the power to rate opens up the possibility for interest groups to narrow freedom of ideas and expression. Some creative professionals agree that risk of harm is the only ethical position for restriction of television. They want to learn more about specific child risk issues and want parents to have ample content information with which to make informed choices.

Many creative professionals hope that rating television would protect children, would be scrupulously unbiased, would heavily consider genre and context, and would allow stories to be set up by dramatic and careful use of some violence, sex, etc. which is then resolved safely for viewers.

Currently, I think experts in child health, TV research, and creative TV production need to collaborate. The I.G. was unable to do that. One choice is to advocate for a universal ratings protocol (open platform) so that a parallel system can be officially broadcast. Let Americans choose. Then everyone will be welcome aboard!

(Guest article: John Livingstone, M.D., a child and adolescent psychiatrist at Harvard Medical School, is a TV broadcast standards consultant and a founding editor, with TV producer Leonard Stern of Dialogue, published by IMHI. He is author of The Violence Framework, and Rating Your TV Rating System.)