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The new (2003) guidelines for the Classification of Films and
Computer Games have been released. They take effect immediately.
Young Media Australia has carefully examined the new guidelines,
and has a number of strong concerns about them.
1. Summary of concerns:
a) The new guidelines reduce the protections for children that
exist in Guidelines in present use.
b) The Guidelines Review process (from October 2001) has been
deficient, in that;
• the public were not given the opportunity to comment
on the new set of guidelines before their approval by the participating
Ministers;
• the only draft Guidelines put out for public comment
were those included in the October 2001 Review of Guidelines
conducted by the OFLC. This draft was withdrawn after the March
2002 meeting of the participating Ministers and replaced by
a "simplified" set.
Members of the public who protested that they were not given
the opportunity to comment on this new draft, were assured that
they did not change the standards set in the October 2001 draft.
They plainly do.
c) The guidelines place much emphasis on the concept of "impact",
to the detriment of assessing particular types of content. This
introduces more subjectivity to the assessment process. (see point
2 below)
Further, the assessment of "impact" on a child audience
is a specialised task, requiring child development expertise.
d) The guidelines also rely heavily on "context" .
(see point 3 below)
e) Of particular concern is the apparent weakening of the protections
provided by the G and PG classifications, due to significant changes
in the criteria. (see points 4 & 5 below)
f) The guidelines for PG and G8+ have been amalgamated. These
represent two different concepts and require two different sets
of guidelines. (see point 6 below)
g) The new M guidelines also appear to have been weakened (see
point 7 below)
2. The issue of "impact"
"Impact", both of individual scenes, and cumulatively,
is a key factor in the new guidelines. The recognition of the
importance of the impact of both individual scenes, and of the
cumulative impact of a number of scenes, provides a degree of
clarification over the previous guidelines.
However, the assessment of impact will almost always be subjective,
depending on the viewer's threshold of sensitivity. Classifiers
(who see impactful material routinely) will need to be very in
tune with the ordinary viewers' likely reactions.
Further, in relation to the child audience, there are difficulties
in determining "impact" in relation to different age
groups of children. The preface to the new guidelines says that
"impact" will be judged by factors such as detail, accentuation
techniques, special effects, length of sequences, repetition,
realism rather than stylisation, and interactivity.
This may constitute an adequate list of factors that may heighten
impact on adults, but may not be satisfactory in relation to children.
For example, the under 7 year old audience may be as fearful after
exposure to "stylised" or animated films as they are
from realistic ones.
A reliance on impact requires classifiers with specialised knowledge
of child development.
3. The issue of "context"
While "context" is indeed important (viz who does
what to whom and the outcomes), the concept of "justified
by the context" should not be used to permit the inclusion
of individual depictions that would otherwise not be allowable
within a category. For example, the fact that, say, some very
violent depictions were set in an historical, or horror context,
or stylised contexts should not necessarily justify the inclusion
of more extreme material in a lower classification.
4. The new G guidelines: the new criteria
The preamble that exists in the present Guidelines has been
modified. It no longer requires that material in this category
should be suitable for children to watch without supervision.
The impact of classifiable elements has to be very mild. How
is it intended that an effective judgement will be made in relation
to children, especially those under age of 7? This requires specialised
knowledge.
Themes: the only caution is against themes that have a sense
of threat or menace. This is an inadequate approach to the issue
of themes. There is no mention of themes that are otherwise disturbing
to children such as divorce, loss of or separation from parents,
loss of control. These themes do not have to be detailed or frequent
to be impactful to children. The impact of such themes will depend
on a child's understanding of the concepts.
Violence: the significant omission here, from previous guidelines
is that violence is no longer required to be infrequent. The only
cautions are against that violence which has a very low sense
of threat or menace. This ignores the evidence that other forms
of violence can harm young children, for eg animated/glamorised
violence by heroes, which may not have a sense of threat or menace
for the child viewer, but which can contribute to an acceptance
of the use of violence to solve conflict. The previous requirement
of "infrequency" ensured that children were not exposed
to much violence of any type in a G film. Notably, the guidelines
for PG do retain the requirement that violence is to be infrequent.
Sex: again the requirement that the depiction of sexual activity
be infreqent has been removed.
Language: this is unchanged.
Drug use: while there were no criteria dealing with drug use
in the old guidelines, it could be assumed that, as children should
be able to watch G films without supervision, there would be no
drug use depicted in G films.
The new guidelines have no frequency limits and allow depictions
provided they are justified by context. This is not adequate protection
for a child audience.
Nudity: not previously a criterion
5. The new PG/G8+ guidelines : the new criteria
The meanings of these two categories (PG and G8+) are different
and the concepts should not be treated as interchangeable.
Themes: this now removes the existing provision that treatment
of themes be discreet. Again, see as for "G" above,
the themes that may harm or disturb children can include many
that may not necessarily be characterised by a sense of threat
or menace.
Violence: here, there is a welcome provision that violence should
be "infrequent". Why is it deemed to be necessary here,
but not in "G"?
Sex: essentially as before.
Language: essentially as before, and the requirement that coarse
language be "infrequent" is preserved.
Drug use: there is a big loss here from old guidelines, in that,
so long as the impact is "mild" , and the depictions
are justified by context, these are allowed. Changed are the requirements
that drug use references be discreet and depictions incidental,
and must not promote or encourage drug use.
Nudity: mostly unchanged.
6. The merging of PG and G8+
The merging of the criteria for "PG" (films and videos)
and "G8+" (computer games) is undesirable. The two concepts
are not equal and interchangeable. "PG" implies the
film will be OK for children under 15 years with parental supervision.
"G8+" indicates a product that is OK for children 8
and over (without parental supervision). The new PG/G8+ criteria
does not properly capture what would be needed for an effective
G8+ category.
There had been much support for the introduction of a G8+ category
for films and videos, but such a category should include criteria
that clearly indicated material that would make the product unsuitable
for under 8 year olds ( ie a developmental approach was needed).
If a new G8+ classification were to be introduced, it needs to
be accompanied by a new G13+ category.
7. The new M classification:
Themes: no longer have to be treated discreetly.
Violence: there is a loss of the requirement that depictions
that have detail be infrequent.
Sex: as previously.
Language: much as previously.
Drug use: previous requirements that depictions be discreet
, and not promote encourage drug use, have gone.
Nudity: previous requirements that nudity in a sexual context
not contain detail or be prolonged have been removed.
NOTE: this review of the Guidelines has not included the classification
categories above "M".
To view the new Guidelines, visit the
Office of Film & Literature Classification.
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