ReadSpeaker:
ListenLarger documents may require additional load time.
Strengthening the Canadian alcohol advertising regulatory system
Canadian Journal of Public Health. 103.4 (July-August 2012): p263+.
Abstract: 

Research evidence points to harmful effects from alcohol advertising among children and youth. In particular, exposure to alcohol advertising has been associated with adolescents drinking both earlier and heavier. Although current federal and provincial guidelines have addressed advertising practices to prevent underage drinking, practice has not been supported by existing policy. While protective measures such as social marketing campaigns have the potential for counteracting the effects from alcohol advertising, the effectiveness of such measures can be easily drowned out with increasing advertising activities from the alcohol industry, especially without effective regulation. Research reviewed by the European Focus on Alcohol Safe Environment (FASE) Project has identified a set of key elements that are necessary to make alcohol advertising policy measures effective at protecting children and youth from the harmful effects of alcohol marketing. Using these key elements as an evaluation framework, there are critical components in the Canadian alcohol advertising regulatory system that clearly require strengthening. To protect impressionable children and youth against the harmful effects of alcohol advertising, 13 recommendations to strengthen current alcohol advertising regulations in Canada are provided for Canadian policymakers, advertising standard agencies, and public health groups.

Key words: Alcohol drinking; government regulation; public health; advertising as topic

Les donnees de recherche font etat des effets nefastes de la publicite sur l'alcool chez les enfants et les jeunes. On a en particulier associe l'exposition a cette forme de publicite a une consommation d'alcool plus precoce et plus importante chez les adolescents. Bien que des lignes directrices federales et provinciales actuelles visent les pratiques publicitaires afin de prevenir la consommation d'alcool par les mineurs, ces directives ne sont pas soutenues par les politiques en vigueur. Des mesures de protection, comme des campagnes de marketing social, pourraient eventuellement contrer les effets de la publicite sur l'alcool, mais leur efficacite est facilement noyee par un accroissement des activites publicitaires de l'industrie de l'alcool, surtout en l'absence d'une reglementation efficace. Des etudes examinees par le projet europeen Focus on Alcohol Safe Environment (FASE) definissent un ensemble d'elements cles necessaires pour que les mesures contre la publicite sur l'alcool protegent efficacement les enfants et les jeunes des effets nefastes du marketing de l'alcool. En utilisant ces elements cles comme cadre d'evaluation, on remarque que des volets essentiels du systeme de reglementation canadien de la publicite sur l'alcool doivent clairement etre renforces. Afin de proteger les enfants et les jeunes suggestibles contre les effets nefastes de la publicite sur l'alcool, nous formulons, a l'intention des responsables des politiques, des organismes d'etablissement des normes publicitaires et des groupes de sante publique canadiens, 13 recommandations pour renforcer la reglementation actuelle de la publicite sur l'alcool au Canada.

Mots cles : consommation d'alcool; reglementation gouvernementale; sante publique; publicite comme sujet

Full Text: 

While advertising is a legitimate marketing tactic used by alcohol producers to promote their products, recent reviews point to a clear link between exposure to alcohol advertising and subsequent drinking behaviour in young people. (1,2) More specifically, the more alcohol advertising young people are exposed to, the more likely they will start to drink, or, if they are already consuming alcohol, drink more. (2) This link has been attributable to elements of alcohol advertisements that create favourable attitudes among children and youth towards drinking, thereby affecting intentions to consume alcohol. Among youth, alcohol advertising "has been found to promote and reinforce perceptions of drinking as positive, glamorous, and relatively riskfree", (3) all of which encourage a higher consumption of alcohol, often well before the legal age of purchase. (3-5)

Protective measures in Canada

In Canada, despite federal and provincial guidelines that restrict alcohol advertisements from appealing to children and minors, children and youth are exposed to more than 300,000 alcohol ads each year through radio, television and the Internet. (6) Alcohol advertising countermeasures have typically taken the form of social responsibility messaging initiatives that increase the public's awareness of the potential harmful influences from alcohol advertising. In Canada, alcohol media literacy campaigns have been the primary measures for counteracting the effects of alcohol advertising. (7-9) While these initiatives have the potential of doing so, the effectiveness of such measures can be easily drowned out with increasing advertising activities from the alcohol industry, especially in the absence of effective regulation.

Critical elements of an effective alcohol advertising regulatory system

As part of the European Focus on Alcohol Safe Environment (FASE) Project, a 2010 report by the Dutch Institute for Alcohol Policy and the European Centre for Monitoring Alcohol Marketing (EUCAM) reviewed 190 papers from the literature along with alcohol marketing regulations in 23 European countries to identify components and criteria that make policy measures effective at protecting against the harmful effects of youth exposure to alcohol marketing. (10) As outlined in Table 1, the results from this report indicate that three components are necessary for an effective alcohol advertising regulation system: 1) content restrictions, 2) volume restrictions, and 3) an overall supporting system. An effective supporting infrastructure consists of a supporting legal context, a commitment of all stakeholders, transparency of the decision-making process, a mandatory pre-screening system, an effective complaint system, an independent advertising committee, effective sanctions, and a monitoring system. In addition, such supporting infrastructure should cover all forms of marketing activities and have the flexibility to adjust restrictions accordingly. Using these key elements as an evaluation framework, there are critical components in the Canadian alcohol advertising regulatory system that clearly require strengthening. (11)

Limitations in the current alcohol advertising regulatory system

A number of limitations in the current federal, provincial and industry regulations governing alcoholic beverage advertisements in Canada exist. In terms of content restrictions, the Canadian Radio-television and Telecommunications Commission Code for Broadcast Advertisement of Alcoholic Beverages (CRTC Code) has not been updated since 1996. Not all elements that appeal to youth, such as party scenes, have been addressed. In terms of volume restrictions, regulations do not mandate place restrictions, coverage of all types of advertising mediums are not standardized, and underaged viewers are not protected from the total volume of alcohol advertisements they may be exposed to. Finally, in terms of the infrastructure, pre-screening has been made voluntary as of 1996, complaints are not monitored by a third party, and there lacks an independent advertising committee independent from commercial interest. Through current regulations, it is also possible for international broadcast stations to advertise alcoholic beverages to Canadians through cable and satellite services without complying with the CRTC Code. (12) As a result, thousands of irresponsible alcohol advertisements are aired or displayed with a large proportion of them being exposed to young and impressionable children and adolescents.

The voluntary pre-screening process provided through Advertising Standards Canada (ASC) as a means of enforcing the CRTC Code represents one of the largest gaps in alcohol advertisement regulations in Canada. This process, which was made voluntary in 1996, has made it possible for alcohol advertisers, fearing little in terms of consequences, to disregard the CRTC Code. (13) Without key deterrents in place that guard against potential irresponsible alcohol advertising, young and impressionable children and youth will not be protected from exposure to alcohol advertisements. Even if contravening ads are pulled by advertisers, it is post-facto because children and under-aged audiences will have already been exposed to them.

The need to strengthen alcohol advertising regulation in Canada

Consistent with recent reviews on alcohol advertising (1,2) and the Global Alcohol Strategy, (14) there is a dire need for effective alcohol advertising control policies to address the harmful effects of alcohol advertising, especially among children and underage youth. Without a unified regulatory system governing and enforcing compliance around alcohol advertising, several limitations exist. To address such limitations, evidence gathered from literature reviews and key informant interviews were used to inform recommendations made for Canadian policy-makers, advertising standard agencies, and public health groups.

Table 2 outlines 23 activities to support 13 recommendations within three primary domains that can be made to strengthen current alcohol advertising regulations in Canada, organized according to predicted feasibility based on the authors' analysis. Implementation of all of these recommendations will require development of political will. The majority of recommendations are feasible within current regulatory structures. Some novel approaches will require creative solutions and even international cooperation to be most effective. As shown, recommendations to regulate scope of advertising including introducing volume and content restrictions, are generally feasible. Regulations to cover new media sources will be more difficult to implement and will require creative cross-jurisdictional partnerships to better ensure success. The majority of recommendations related to regulating procedures are seen as feasible within existing administrative structures. The main difficulty will be the implementation of effective enforcement sanctions. Recommendations for the provision of additional support are generally feasible. Nevertheless, implementation will need to address the lack of dedicated funds to increase public awareness around system limitations. Predicted barriers are similar across all recommendations and include weak political will, differing political priorities, and a lack of funding and staffing to establish new protocols. Also problematic are the anticipated lobbying efforts from the alcohol industry against any new controls.

In response to all of these recommendations, governing bodies and advertising standard agencies need to take active roles in controlling all alcohol advertisements, including both volume and content exposed to children and youth, so that all types of media channels are consistently and effectively regulated and enforced.

Finally, it is important to recognize that no single measure can act as a definitive solution to tackle the effects of alcohol advertising on young people's drinking, and therefore regulation should be complemented with other policy levers and interventions led by Public Health, while given adequate time to have an effect. (3) Such interventions may include educating and mobilizing a community around the limitations of the current system along with advocating for additional research-based limits through political means, such as provincial alcohol strategies.

Received: December 29, 2011

Accepted: May 5, 2012

REFERENCES

(1.) Smith LA, Foxcroft DR. The effect of alcohol advertising, marketing and portrayal on drinking behaviour in young people: Systematic review of prospective cohort studies. BMC Public Health 2009;9(51). Available at: www.biomedcentral.com/content/pdf/1471-2458-9-51.pdf (Accessed October 1, 2010).

(2.) Anderson P, de Bruijin 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 and Alcoholism 2009;44(3):229-43.

(3.) Babor TF, Caetano R, Casswell S, Edwards G, Giesbrecht N, Graham K, et al. Alcohol: No Ordinary Commodity. Research and Public Policy. Oxford, UK: Oxford University Press, 2003.

(4.) Barry AD, Goodson P. Use (and misuse) of the responsible drinking message in public health and alcohol advertising: A review. Health Educ Behav 2010;37(2):288-303.

(5.) Heipel-Fortin RB, Rempel B. Effectiveness of alcohol advertising control policies and implications for public health practice. McMaster University Med J 2007;4(1):20-25.

(6.) Association to Reduce Alcohol Promotion in Ontario. ARAPO ADS UP! [Newsletter], 2004. Available at: www.apolnet.ca/arapo/newsletters/ARA-POWinter04Newsletter.pdf (Accessed October 1, 2010).

(7.) Newfoundland and Labrador's Teacher's Association. Education program for youth on alcohol advertising. The Bulletin 2005;49(2). Available at: www.nlta.nl.ca/files/documents/bulletins/bultn_nov05.pdf (Accessed November 1, 2010).

(8.) Association to Reduce Alcohol Promotion in Ontario. Under the Influence? Educator's Kit on Alcohol Advertising for Students in Grades 7-10, 3rd Edition. Toronto, ON: Ontario Public Health Association, 2006. Available at: www.tigweb.org/images/resources/tool/docs/1349.pdf (Accessed November 5, 2010).

(9.) Association to Reduce Alcohol Promotion in Ontario. The Booze Buzz Peer Education Project. Toronto: Ontario Public Health Association, 2006. Available at: www.apolnet.ca/resources/pubs/briefingnotes/BN-BoozeBuzz.pdf (Accessed November 1, 2010).

(10.) van den Broeck A, de Bruijn A. Effective alcohol marketing regulations: Policy report. The Netherlands: Dutch Institute for Alcohol Policy & European Centre for Monitoring Alcohol Marketing, 2010. Available at: www.eucam.info/content/bestanden/policy-report-alcohol-marketing.pdf (Accessed November 1, 2010).

(11.) de Bruijn A, Johansen I, van den Broeck A. Effective alcohol marketing regulations: A proposed framework to evaluate existing alcohol marketing strategies. The Netherlands: Dutch Institute for Alcohol Policy and European Centre for Monitoring Alcohol Marketing, 2010. Available at: www.faseproject.eu/content/bestanden/effective-alcohol-marketing-regulations- a-proposed-framework-to-evaluate-existing-alcohol-marketing-regulations.pdf (Accessed November 1, 2010).

(12.) Fortin R, Rempel B. The Effectiveness of Regulating Alcohol Advertising: Policies and Public Health. Prepared for the Association to Reduce Alcohol Promotion, 2005.

(13.) Novak J. Alcohol Promotion and the Marketing Industry: Trends, Tactics, and Public Health. Association to Reduce Alcohol Promotion in Ontario. Toronto: OPHA, 2004. Available at: http://www.apolnet.ca/resources/pubs/rpt_Effectiveness-Dec05.pdf (Accessed August 18, 2010).

(14.) World Health Organization. Draft Global Strategy to Reduce the Harmful Use of Alcohol, 2010. Available at: www.eucam.info/content/bestanden/who-2010-global-strategy.pdf (Accessed November 1, 2010).

Carly M. Heung, MPH, [1] Benjamin Rempel, MPH, [1] Marvin Krank, PhD [2]

Author Affiliations

[1.] Ontario Public Health Association, Toronto, ON

[2.] University of British Columbia, Kelowna, BC

Correspondence: Ms. Carly Heung, Research Coordinator, Health Promotion, Chronic Disease, and Injury Prevention, Public Health Ontario, 480 University Avenue, Suite 300, Toronto, ON M5V 1V6, Tel: 647-260-7341, Fax: 647-260-7600, E-mail: carly.heung@oahpp.ca

Acknowledgements: The authors acknowledge and thank all of the key informants who provided valuable insights to inform this paper. Funding for the work discussed in this paper was supported by a research grant secured by the Ontario Public Health Association.

Disclaimer: Ms. Heung and Mr. Rempel are now at Public Health Ontario, Toronto, ON. The opinions, results and conclusions reported in this paper are those of the authors. No endorsement by Public Health Ontario or by the Ontario Public Health Association is intended or should be inferred.

Conflict of Interest: None to declare.

Table 1. Evidence-based Framework for an Effective Alcohol Advertising
Regulatory System (10)

Component                        Elements

Content Restrictions--Content    Content restrictions are said to be
restrictions can protect all     effective at protecting young people
consumers against misleading     against attractive advertisements
or deceptive alcohol             only if:
advertisements and in            1. Content restrictions address all
particular, young people            elements that have shown to be
against attractive                  appealing to young people and do
advertisements.                     not just state that alcohol
                                    advertising cannot be specifically
                                    aimed at minors. Such elements
                                    might include lifestyle images,
                                    use of humour, celebrities,
                                    cartoons, and sexual content;
                                 2. Content restrictions limit
                                    advertisements that young people
                                    find appealing even if these are
                                    not specifically targeting minors,
                                    or that are specifically appealing
                                    to minors (but to adults as well);
                                    and
                                 3. Alcohol advertisements are
                                    evaluated according to young
                                    people's interpretation and not
                                    according to the intention of the
                                    advertiser.

Volume Restrictions--Volume      Volume restriction measures are said
restrictions are a necessary     to be effective only if they meet the
tool in protecting young         following criteria:
people against the cumulative    1. Volume restriction measures are
effects of exposure from large      not merely symbolic policies but
volumes (both in quantity or        contribute substantially to the
specific locations) of alcohol      total volume of alcohol
advertisements on drinking          advertising to which adolescents
behaviour. In practice, there       are exposed; and
have been three types of         2. No significant substitution
volume restriction measures,        effects arise (e.g., shift to
including a) restrictions on        other media or price decrease).
certain times or places, b)
restrictions on certain types
of media, and c) restrictions
on certain types of alcoholic
beverages.

Supporting Infrastructure--      Elements to an effective alcohol
While both content               advertising regulatory system
restrictions and volume          include:
restrictions should be           1. A supporting legal context--No
employed, the effectiveness of      conflicting regulations on the
alcohol advertising                 national or international level
regulations depends not solely      and a legal backstop is needed to
on these content and/or volume      support the enforcement of the
restrictions, but also on the       restrictions;
system that supports them.       2. Commitment of all stakeholders
                                    (including policy-makers, public
                                    health advocates/consumer
                                    representatives, and
                                    industry-related stakeholders) to
                                    increase the support of and
                                    adherence to the restrictions;
                                 3. Transparency, which includes the
                                    availability of information to the
                                    public at every stage of the
                                    regulation process--including what
                                    and how decisions are made during
                                    the pre-screening and complaints
                                    process;
                                 4. A mandatory pre-screening system
                                    with a public health interest to
                                    prevent both public exposure
                                    to advertisements that are
                                    non-compliant with restrictions
                                    and breaches of the
                                 5. Effective complaint system with
                                    easy access to and support from
                                    the public--Complaints should be
                                    monitored by a third party;
                                 6. An independent advertising
                                    committee--Evaluation by parties
                                    independent from commercial
                                    interests (not by advertising
                                    industry-related or alcohol
                                    industry-related, but by judges,
                                    public health advocates or
                                    consumer representatives);
                                 7. Effective sanctions--Sanctions
                                    that are expected to be most
                                    effective are: withdrawing
                                    broadcasting rights and
                                    substantial financial penalties.
                                    Sanctions that are expected to be
                                    less effective are: bad publicity
                                    or voluntary action;
                                 8. Monitoring to assess the
                                    effectiveness of the system and
                                    record the potential effects of
                                    new marketing techniques;
                                    monitoring should 1) be performed
                                    by parties independent from
                                    commercial interests, 2) be
                                    conducted routinely and
                                    systematically, 3) include
                                    content, volume, as well as
                                    "unmeasured" types of alcohol
                                    marketing practices, and 4)
                                    include public disclosure of
                                    alcohol marketing expenditures to
                                    third parties (government,
                                    academic institutes, or civil
                                    society);
                                 9. Coverage and flexibility--
                                    Restrictions should cover the
                                    entire range of forms of
                                    marketing activities and should be
                                    updated regularly to respond to
                                    potential shifts in unregulated
                                    types of alcohol marketing
                                    practices.

Table 2. Strengthening the Regulation of Alcohol Advertisements in
Canada

Recommendations                     Activities

Regulating Scope

1. Strengthen content               Mandate content restrictions to
   restrictions (governing          address all elements appealing to
   bodies)                          youth;

                                    Consolidate all content
                                    restrictions into one document;

                                    Outline what is allowed in content
                                    restrictions, rather than what is
                                    not allowed.

2. Develop and implement            Employ statutory watersheds to
   codes for volume restrictions    limit the time of day alcohol
   (governing bodies)               advertisements would be allowed to
                                    be shown on television;

                                    Develop and implement volume
                                    restrictions based on the viewing
                                    habits of underaged viewers.

3. Increase coverage of alcohol     Regulate both measured and
   advertising regulations          unmeasured media outlets,
   (governing bodies)               particularly new media and the
                                    Internet;

                                    Prohibit marketing practices that
                                    are difficult to monitor and are
                                    being used to reach children and
                                    underage youth.

Regulating Procedures

4. Reinstate federal mandatory      Revert back to enforcing mandatory
   pre-screening process            pre-clearance of alcohol ads by
   (governing bodies)               federal and provincial bodies with
                                    a strong public interest mandate.

5. Improve current complaints       Adjust the current complaints
   system (governing bodies)        systems to ensure both a simpler
                                    and quicker process;

                                    Remove biases from reviews being
                                    made on complaints.

6. Create an independent            Include representatives free from
   panel of representatives         any alcohol industry ties to
   (governing bodies)               review the appropriateness of
                                    alcohol advertisements during the
                                    pre-screening process as well to
                                    review complaints;

                                    Include representatives from
                                    public health, children and youth
                                    organizations, objective media,
                                    and marketing experts.

7. Increase transparency            Ensure that all alcohol
   (governing bodies)               advertising decisions are made in
                                    consultation with both federal and
                                    their respective provincial health
                                    agencies.

8. Develop and implement a          Develop a self-regulatory code
   public health-informed           that specifically addresses
   advertising standards code for   advertising of alcoholic
   alcoholic beverages              beverages;
   (advertising standards
   agencies)                        Ensure that development of a self-
                                    regulatory code is made by people
                                    with a public health background
                                    rather than with a legal or
                                    exclusively business background.

9. Implement an effective           Implement regular and systematic
   monitoring system                monitoring of alcohol advertising
   (governing bodies)               activities, including public
                                    disclosure of alcohol marketing
                                    expenditures, use of various
                                    mediums for alcohol
                                    advertisements, and compliance of
                                    advertisements with codes for
                                    responsible advertising.

10. Enforce effective sanctions     Develop and implement an effective
   (governing bodies)               administrative and deterrence
                                    system for infringements on
                                    marketing restrictions;

                                    Include real consequences, such as
                                    bans on marketing products for a
                                    specified time period or financial
                                    penalties, on advertisers who
                                    breach rules.

Provision of Additional Supports

11. Advocate; cultivate             Advocate for additional limits on
   collaborations and               alcohol advertising to prevent
   partnerships (Public Health      irresponsible messages from being
   and community interest           targeted to underage drinkers;
   groups)
                                    Ensure Public Health's role in
                                    cultivating collaborations and
                                    partnerships.

12. Conduct additional research     Review the literature for specific
   (Public Health and community     elements of initiatives that have
   interest groups)                 been evaluated for effectiveness
                                    at counteracting the influences
                                    from alcohol advertising.

13. Increase public awareness       Inform future provincial alcohol
   (Public Health and community     strategies by specifying the
   interest groups)                 specific elements of the alcohol
                                    advertising regulatory system that
                                    require updating;

                                    Increase public awareness around
                                    the limitations of the current
                                    alcohol advertising regulatory
                                    system.

Recommendations                     Implementation Considerations

Regulating Scope

1. Strengthen content               Feasible to implement:
   restrictions (governing          Recommendation is administrative
   bodies)                          in nature as existing codes could
                                    be altered to accommodate.

2. Develop and implement            Concerns with implementation:
   codes for volume restrictions    A monitoring and compliance system
   (governing bodies)               would need to be established to
                                    ensure restrictions are adhered to
                                    by advertisers.

3. Increase coverage of alcohol     Difficult to implement:
   advertising regulations
   (governing bodies)

                                    Internet and new media are
                                    currently difficult to monitor and
                                    measure. Creative cross-
                                    jurisdictional strategies would
                                    need to be employed to effectively
                                    address this recommendation.

Regulating Procedures

4. Reinstate federal mandatory      Feasible to implement:
   pre-screening process
   (governing bodies)               Before 1996, pre-clearance of
                                    alcohol advertisements were
                                    mandatory. Reverting back to past
                                    processes is predicted to be
                                    feasible for recommendation
                                    implementation.

5. Improve current complaints       Feasible to implement:
   system (governing bodies)        Recommendation is administrative
                                    in nature as existing codes could
                                    be altered to accommodate.

6. Create an independent            Feasible to implement:
   panel of representatives
   (governing bodies)               Before 1996, pre-clearance of
                                    alcohol advertisements were
                                    mandatory. Reverting back to past
                                    processes while ensuring
                                    representatives from health
                                    organizations are included is
                                    predicted to be feasible.

7. Increase transparency            Feasible to implement:
   (governing bodies)
                                    Consultation processes can likely
                                    be established and maintained
                                    under current administrative
                                    structures.

8. Develop and implement a          Feasible to implement:
   public health-informed
   advertising standards code for   Working closely with government
   alcoholic beverages              and national public health
   (advertising standards           agencies, Advertising Standards
   agencies)                        Canada could be tasked with
                                    developing and introducing new
                                    codes.

9. Implement an effective           Concerns with implementation:
   monitoring system
   (governing bodies)               A monitoring system would need to
                                    be established to ensure public
                                    disclosure of alcohol marketing
                                    expenditures, medium tracking, and
                                    compliance rates.

10. Enforce effective sanctions     Difficult to implement:
   (governing bodies)
                                    An administrative and deterrence
                                    system would need to be
                                    established to process
                                    infringements on marketing
                                    restrictions. Complete advertising
                                    bans and financial penalties
                                    within other jurisdictions have
                                    been seen to be effective, but
                                    also difficult to accomplish.

Provision of Additional Supports

11. Advocate; cultivate             Feasible to implement:
   collaborations and
   partnerships (Public Health      Public health units or regional
   and community interest           health authorities could work in
   groups)                          collaboration to advocate and
                                    pressure governing bodies for
                                    additional advertising limits.

12. Conduct additional research     Feasible to implement:
   (Public Health and community
   interest groups)                 Research grants could be secured
                                    by national public health groups
                                    to collate and report on evaluated
                                    and effective initiatives.

13. Increase public awareness       Concerns with implementation:
   (Public Health and community
   interest groups)                 Future provincial alcohol
                                    strategies could specify specific
                                    elements of the regulatory system
                                    that require attention.

                                    Increasing public awareness may
                                    require significant funding to
                                    accomplish.
Source Citation   (MLA 8th Edition)
Heung, Carly M., et al. "Strengthening the Canadian alcohol advertising regulatory system." Canadian Journal of Public Health, vol. 103, no. 4, 2012, p. 263+. Academic OneFile, http%3A%2F%2Flink.galegroup.com%2Fapps%2Fdoc%2FA305660771%2FAONE%3Fu%3Dko_acd_uoo%26sid%3DAONE%26xid%3Dbc7289f4. Accessed 16 Nov. 2018.

Gale Document Number: GALE|A305660771