Submission on the Film, Magazine and Computer Games Classification Guidelines 2012

The following Christian Action Network Submission has been sent to the Film and Publications Board (FPB). 

Introduction
The FPB is elected as a proxy for parents as they are unable to view all the movies released, and so the FPB should represent the interest of the parents. Parents should be able to "trust" that the classifications are suitable.

In a recent press statement, Ms. Makhasi, CEO of the FPB, said: “The guidelines are there to ensure that our classifiers in executing their duties do so with due consideration of tolerance levels in our society and in line with the rights enshrined in the constitution.”

It seems, however, that the FPB has under-estimated the tolerance levels of the largely conservative South African populace.

Considering that almost 80% of South Africa’s population is of the Christian faith (South African Christian Handbook 2007), the values upheld should be representative of these statistics. The remaining people are largely Jewish, Hindu or Muslim, and adhere to similar moral standards.

The recent gang rape of a girl, brazenly filmed by one of the rapists, depicts yet again how youth in South Africa appear to have been influenced by pornography’s exploitative messages.

The public should not need to have to wage campaigns such as submissions and protests merely to avoid having the material forced on them. The time, energy and effort that individuals and community groups needed to use to stop TOP TV from broadcasting p*rn, for example, is a case in point. Thousands of people expressed their outrage at the possibility of p*rn on TV by writing to the CEO of TOP TV, some even boycotting them. We know that the FPB does not deal with broadcasting, but the outrage expressed by the public at pornography shows that most South Africans have much higher standards of morality than the FPB has taken into account.

Moral, law-abiding citizens are tired of always being on the back foot. It appears, therefore, that the FPB’s standards could be raised to better represent the public's interests. The Classifications should certainly not lower the standard.

Role of Film and Publications Board
The Film and Publications Board should support and represent the interests of the parents. At all times they should be aiming for higher moral standards, not simply reflecting “levels of tolerance”.

Praiseworthy Improvements
The new classifiable elements of Blasphemy, Sexual Violence, Imitable Acts and Techniques, Criminal Techniques, and Horror are all excellent positive improvements.

Blasphemy
We believe that blasphemy is never justified in any context. We submit that even a single occurrence of blasphemy such as the taking of God’s name in vain, should receive a blasphemy warning on a film, or computer game.

At the least, if there are several occurrences of blasphemy in a film it should get a 16 age restriction.

Language
In the PG, 10 and 13 categories, no vulgar, or obscene language should be allowed, even if it is supposedly of a “low impact”. In most communities it not considered appropriate for primary school children to use such language, therefore such children should not be allowed to hear such language in films either.

Sexual Conduct
If a film or magazine depicts adultery that is condoned in the story-line, it should get a 16 age restriction.

Any films that glamorize promiscuity, pornography, lap dancing, prostitution, or where women are objectified or portrayed as sexual play-things, should receive an 18 restriction.

Moderate to frequent occurrences of crude, verbal sexual terminology should get a 16 or 18 age restriction.

Substance Abuse
We have a drug epidemic in South Africa. Given the experimental nature of teenagers, substance abuse should be discouraged at all costs.

Any occurrences of substance abuse, up to and including the 18 category, should only be allowed if it is shown to have negative consequences.

Comments on Age Category Guidelines

"PG": Parental Guidance

We welcome the many improvements and stricter Guidelines made over the last 10 years, especially regarding sexual activity.

"10": Not suitable for children under the age of 10

It should be remembered that a 10-year-old is in grade 4, in Junior Primary.

Sex: We are pleased to see that this has been improved to not allow any scenes of implied sexual activity.

"13 PG" and “13”: Not suitable for children under the age of 13 years

It should be remembered that a 13-year-old is in grade 7, in Primary School.

Nudity: No nudity in a sexualized context, even if it is supposedly of a low impact, should be permitted in this category.

Sexual Conduct: Sexual conduct, even if it is supposedly of a low impact, should not be allowed. It is not clear what is meant by “low impact sexual activity”.

"16": Not suitable for children under the age of 16 years

It should be remembered that a 16-year-old is in grade 10.

Theme: Should include: "They may include troubling social and moral issues, but with a positive result showing realistic consequences for actions". The condoning of troubling issues, such as abortion, homosexuality and cross-dressing should not be allowed as teenagers even at the age of 16, are still very vulnerable to issues effecting their personal identity.

Nudity: Given the high incidence of teenage pregnancy, we should not be showing close-ups of nudity. Teenagers are impressionable and will compare themselves to big screen stars – this is not fair and has serious psychological consequences. The big screen is not reality, nor are actors and actresses your average citizen. This adds to teenage image and health problems, especially regarding their bodies.

Sex: Sexual scenes must not glamourise sexual promiscuity, prostitution, sodomy and where shown, they must show the negative consequences associated with promiscuous sex, e.g. pregnancy, AIDS, STDs. If sex with a condom is implied or depicted, it must be made clear that condoms were only designed to prevent pregnancy, not the transfer of the HIV/AIDS virus. To do anything else is misleading and irresponsible.

Violence: Given our culture of crime, the number of youth in prison and the number of serious crimes committed by youth, to show gratuitous violence without serious consequences, (e.g. law enforcement, pangs of conscience, loss of life, etc.) is irresponsible and even complicit in aggravating the high levels of crime in our country.

"18": Not suitable for children under the age of 18 years

It should be remembered that an 18-year-old is in grade 12.

Violence: Sustained and graphic violence is unnecessary especially for matriculates. Considering the school massacres in the US and the bullying and school violence in South African schools, we cannot afford to expose our children to such scenes. To do otherwise is to be complicit in the very serious consequences of violence in our society. Consider the horrific effects of "Natural Born Killers," for example. Any violence shown should be seen to have serious consequences, as that is reflective of reality.

XX Category
We believe that all pornography should be banned, however, in the meantime, as much of what is allowed in the XX category depicts acts that are unconstitutional: exploitative, harmful and violate the right to dignity, we think this category should be done away with.

If it is illegal to traffick, exploit, assault or harm someone, especially in the work place, why is it permissible for people to possess images or films containing such?

In accordance with this, any material that condones “sexual violence” should be Refused Classification.

Some of what is allowed in South Africa in the XX category would be Refused Classification even in Australia and Canada.

Hyper-Sexualisation of children

The Guidelines have failed to take note of the sexualisation of children. The damaging impact of the sexualisation of girls has been well documented in the American Psychological Association’s Report on the Sexualization of Girls and the UK-based Letting Children Be Children: Report of an Independent Review of the Commercialisation and Sexualisation of Children by Reg Bailey.

Furthermore, the criterion of “artistic and literary merit” should be considered irrelevant in determining the classification of a sexual or sexualised depiction of a child such as suggestive posing.

Objectification of Women

It once again appears that the objectification of women has been ignored by the FPB with no recognition being given to the myriad of problems associated with hyper-sexualisation.

As well as influencing the treatment and portrayal of female celebrities, research

finds that the 'sex object culture', peddled by the media, has far wider implications for society. The sexual objectification of women is found implicitly to encourage, normalise and legitimise attitudes associated with discrimination and violence against women and girls. This is of grave concern when we live in a country in which a woman is raped every 23 seconds.

Indeed, recent research has exposed the language of sexually explicit magazines to be indistinguishable from language used by convicted rapists when talking about women [1].

The links between sex object culture, discrimination and violence against women are

recognised at the international level by the legally binding United Nations Convention to Eliminate Discrimination Against Women (CEDAW), to which South Africa is a signatory - to take action against the objectification of women [1]. Similarly the UK-based End Violence Against Women coalition has called on the UK Government to tackle the sexualisation of women and girls because it provides a “conducive context” for violence against women [1].

Indeed, the sexual objectification of women and girls is linked to a range of harms – ranging from body image and self-esteem issues to violence, sexist attitudes and racism.

The hyper-sexualisation, objectification and portrayal of women and girls as sexual play-things, should be taken into account and should result in stricter classifications.

Computer Games

Violence: We are concerned that 16-year-olds may be exposed to violence in graphic detail, which could include mutilation and dismemberment. “Strong impact violence”, even in third person game play should be restricted to the 18 category.

Advertising

It is suggested that the FPB request that certain aspects of advertising, especially billboards depicting sexual conduct (so-called ‘adult entertainment’), be moved under the oversight of the FPB and receive classifications. The public are continually subjected to sexually objectifying adverts, billboards in particular, of which they have no warning regarding offensive content. If the sexualized content of some billboard advertising were to be used in another medium, like film, it would receive a 13 or 16 age classification. Yet these billboards are on major highways visible to all ages.

The Advertising Standards Authority has no legal teeth or inclination to deal with offending advertisers. They do not do any research and are unwilling to understand the issue of the objectification of women or the implications thereof. In fact, they seem to protect the advertisers and are very dismissive of public complaints.

Complaints Process Needs Substantial Improvement

The complaints process needs to be improved and speeded up substantially, especially regarding magazines. The entire complaints procedure currently seems to be prejudiced against the consumer and biased in favour of the publishers.

The online complaints system could be improved to allow the complainant to simply state the name, pages and complaint regarding the relevant magazine. The FPB should then obtain the magazine. A time limit of 3 days is more than adequate for the FPB to respond. Complaining about a magazine seems pointless when the next edition is in the shops before a ruling regarding the offending edition has been given.

The initial decision of the Complaints Committee should be carried out even if there is a pending appeal from the publishers/distributors. Repeat offenders should be given much stricter penalties.

Once a new classification is issued in response to a complaint from a member of the public (e.g. a magazine should be X18), the offending publication should be removed immediately to avoid any further harm being done. Children’s Rights are paramount in the South African Constitution.

Hearings should also be held in other cities. Currently, hearings are only held in Johannesburg making it difficult for people from other cities to attend and argue the case in person. This favours the media companies who have resources and lawyers.

There are too few compliance officers. A more rigorous prosecution response will ensure that retail shops for example, toe the line, as presently they are aware of the shortcomings in the enforcement of FPB regulations and take advantage of this.

Please carefully consider this feedback. We thank you for your time and hard work. We hope and pray that the FPB will get better equipped and financed to handle the massive workload.

Yours Sincerely,

Taryn Hodgson                                        
International Co-ordinator
Christian Action Network

What You Can Do:

1. The FPB is requesting submissions on the latest Film and Computer Games Guidelines for Age Classifications. These age classifications are used in cinemas and marked on DVDs for hire. Note that magazines (except those containing material with “sexual conduct”) are not required to be submitted to the FPB before publication for classification. They only receive a Classification if a complaint is made. Complain to the Board about the age classifications given to films/computer games and urge the Board to raise the “community standards” by making the age classifications stricter. Chetty says, “We must say we don’t accept this level of nudity or these sorts of sexually immoral scenes for children.”Even a few paragraphs will do. Note that films, computer games and publications have different Guidelines for classification.
   Click here to view the Guidelines. A good idea is to include examples of films you have watched or heard of where the age classification has not been high enough, or the film should have received for example, a blasphemy warning. The deadline is 12 May 2012 (it says 12 April in the Government Gazette but the deadline has been extended). Send your submissions to: This email address is being protected from spambots. You need JavaScript enabled to view it. .
2. Complaints about a specific magazine, film or computer game classification can be sent to: This email address is being protected from spambots. You need JavaScript enabled to view it. . Complaints about TV or radio programmes can be sent to the Broadcasting Complaints Commission: This email address is being protected from spambots. You need JavaScript enabled to view it.  and advertising complaints to the Advertising Standards Authority: This email address is being protected from spambots. You need JavaScript enabled to view it. .
3. Visit www.movieguide.org to read Christian reviews of the latest film releases or subscribe to the Movie Guide magazine. Movie Guide also includes an analysis of the worldview of each film.
4. Obtain and read The Culture-Wise Family by Dr Ted Baehr, available from Christian Liberty Books, 021- 6897478, This email address is being protected from spambots. You need JavaScript enabled to view it. , www.christianlibertybooks.co.za.

"Have nothing to do with the fruitless deeds of darkness, but rather expose them." Ephesians 5:11

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Ms Nthabiseng May of the FPB has in her possession, the hard and electronic copies of both of these.

Realising Rights, Fulfilling Obligations: An Integrated Strategy to End Violence Against Women (EVAW) 2008.