Published in October 1994 by the National Viewers' and Listeners' Association (called mediawatch-uk from March 2001)



he National Viewer's and Listener's Association welcomes the thorough-going review of the BBC made possible, firstly, by the publication of the Green Paper (Cm 2098 HMSO) and, secondly, by the publication of the White Paper on the Future of the BBC (Cm 2621 HMSO). The consultation and invitation to comment on these documents has enabled a healthy public debate on a whole range of issues related to broadcasting in Britain, not least, the important question of programme standards.

The National Viewer's and Listener's Association believes that Broadcasting is a most powerful means of social communication and exerts considerable influence on public attitudes on a whole host of issues at home and abroad. In a democracy it is of critical importance that the people who make up such a society have the best information, the best education and the best entertainment. The responsibility on broadcasters to pursue these aims is enormous and of overriding importance. It should be regarded as a service and a privilege to work in the industry for the good of the individual, the family and the society.


1. That a new formula on programme standards be added to the Licence and Agreement as follows:

"That the programmes for which they are responsible should not offend good taste or decency or contain unnecessary and gratuitous violence, sex or bad language or incite to crime or lead to disorder or promote a culture of cruelty and violence or be offensive to public feeling".

2. That the formula on programme standards to apply at all times and that the "Watershed" not be used as a time when standards can be suspended.

3. That the Broadcasting Standards Council issues a summary of the Code of Standards and Practice to be widely available to the public.

4. That the Broadcasting Standards Council ceases its practice of upholding or not upholding complaints and that complaints be compiled into monthly reports and presented to the Broadcasting Authorities for remedial action. The Broadcasting Authorities to report back on action taken.

5. That the new BBC Programme Complaints Unit should have its address regularly advertised on all TV and Radio Services

6. That the Obscene Publications Act 1959 be made effective.

7. That European law regulating Direct Broadcasting by satellite be amended so that the country receiving programmes is responsible for granting licences.

Comments on the White Paper


ational VALA welcomes, above all, the acknowledgement that "many people believe that there is too much violence, sex and bad language in programmes" and that "they are concerned not only about incidents in particular programmes but also about the cumulative impact of many programmes containing such incidents". (para 3.13)

Programme standards


he Board of Governors of the BBC has resolved to ensure that "so far as possible" programmes "should not offend good taste and decency or incite to crime or lead to disorder or be offensive to public feeling". This statement is to be found within the Annexe to the Licence and Agreement signed on 8 January 1981 by the Chairman of the Governors and the Director General of the BBC. It is widely recognised that this part of the Resolution is poorly defined, badly understood, not infrequently ignored, and is in urgent need of clarification. Such a need is amply illustrated by the films screened recently by the BBC described in Appendix 1. It is, therefore, very disappointing that the White Paper, in paragraph 3.14, restates this inadequate formula as the sole means of determining programme standards.

This formula has been devised in a way that pre-supposes that the burden of proof that offence (or any other ill-feeling) has been caused requires viewers and listeners to go to the trouble of writing or telephoning to say they have been offended.

It is extraordinary, therefore, that the BBC journalist, Miss Polly Toynbee, writing in the BBC publication 'Radio Times' 20-26 August, marginalizes those licence payers who express their concerns about programmes on the grounds that they give "a false legitimacy to a tiny handful of complainants who may or may not speak for a majority of the people". We would respectfully point out that an even tinier handful of people are responsible for producing the programmes that give rise to the complaints in the first place. Why should it be assumed, without question, that all programmes should be acceptable by the majority of the people when plainly there is growing dissatisfaction.

Despite the inconvenience and the expense it is apparent that widespread offence is being caused in view of the significant increase in complaints received by the Broadcasting Standards Council. (BSC Annual Report published 21.7.94).

National VALA is aware of the important innovations introduced by the BBC in the last year to enable the public to express opinions about programmes. In particular, we welcome the announcement in May 1993 that a questionnaire is to be included with the TV Licence Renewal reminder. This Association suggested such a scheme as long ago as 1988! The questionnaires sent out in April and July of this year have been designed to ascertain which programmes on Television and Radio have been 'consumed' by the respondent. A number of reasons for viewing or listening are suggested and an appreciation rating (out of ten) is provided for. There is also space for the respondent to make additional comment although no suggestions in this section are offered. It would be helpful, in view of the above Resolution, if respondents were asked directly, for example, if any programme "offered good taste and decency". It is not clear at the present time exactly what effect the results of the questionnaire will have on programme standards.

This Association cautiously welcomes the appointment of Mr Peter Dannheisser as head of a new Programme Complaints Unit.  In its quest for greater accountability the Corporation should give a high public profile to this Unit. Indeed we can see no good reason why the PCU's address should not be transmitted regularly by the BBC on all TV and Radio Services and published in all programme guides. It is perfectly legitimate for the 'consumers' to be far more involved in determining programme standards than has hitherto been the case and the PCU is an ideal vehicle for this.

However, replies from Mr Dannheisser to public complaints that this Association has seen indicate that his primary role is to defend BBC interests and reject complaints by simply asserting his own opinions on the programmes complained of.

This is a cynical ploy to demonstrate that the BBC is responding to calls for improved accountability when, in fact, it appears to be placing yet another obstacle in the path of licence payers who simply seek better programme standards. With such impregnable defences it is surprising that so many people persevere!

This Association also welcomes innovative programmes like 'Right to Reply' (Channel 4), 'Biteback' (BBC 1), 'It's Your BBC' (BBC1) and other access programmes which enable the public to express their opinions about programme standards. However, at the present time these programmes provide little more than limited opportunities for animated debate on television and there is no discernible improvement in programme content as a result. Indeed producers regularly appear to vigorously defend the excesses complained of and proceed to 'carry on regardless'! These programmes could provide a forum for proper dialogue and result in change where it matters.

National VALA believes that the White Paper on the Future of the BBC presents an ideal opportunity to put in place better defined requirements on programme standards that are capable of being better enforced by those in positions of authority representing the public interest.

In February 1988, the Chairman of the Board of Governors, Mr Hussey, gave a public undertaking to the Home Secretary that he would "take firm steps to eradicate unnecessary and gratuitous violence, sex and bad language from our programmes". More recently in March 1993, the Director General, Mr John Birt, said that the BBC would not promote the "culture of cruelty and violence".

This Association recognises the very real difficulties of determining matters of taste and decency and we, therefore, believe that these statements made by Mr Hussey and Mr Birt should now be added to the Resolution contained in the Annexe to the Licence and Agreement.

mediawatch-uk recommends a new formula as follows:

"That the programmes for which they are responsible should not offend good taste or decency nor contain unnecessary and gratuitous violence, sex or bad language or incite to crime or lead to disorder or promote a culture of cruelty and violence or be offensive to public feeling".

National VALA believes that such a formula, while retaining a generalised approach, would provide much needed clarification for the industry and would go some way to satisfying the growing public concern on these matters. It would also provide the public with an improved framework within which to assess and judge programmes.

Furthermore, we can see no good reason why such a revised formula could not replace Section 6(1) (a) of the Broadcasting Act 1990.

The "Watershed"


lthough the White Paper does not refer to the BBC's "Watershed" Policy, National VALA believes that clarification is required on this too. The "Watershed" Policy, as described by the BBC, means that on the whole programmes transmitted before 9.00pm are not suitable for an audience in which children are likely to be present. After 9.00pm, the BBC asserts, programmes are more "demanding" and more suited to an adult audience. No definition of what it means to be "adult" is ever given or what it means to be "suitable". The "Watershed" Policy, although said to be well understood by the public, is one which the BBC itself invented, we believe, to excuse programmes which have become, as time has passed, progressively more extreme in terms of violence, sex and bad language.

The BBC argues that after the 9.00pm "Watershed" parents should exercise control over their children's viewing and the well known fact that many children continue to view without supervision until well after 9.00pm seems to have little influence upon those responsible for programme scheduling.

Moreover, the Video Cassette Recorder, now to be found in a very high proportion of homes, has made the "Watershed" Policy irrelevant. Late programmes can simply be recorded and viewed at a more convenient time. It is astonishing that BBC officials persist in refusing to recognise this reality.

National VALA believes that the Licence and Agreement should make it clear that the Resolution on programme standards applies at all times and that the "Watershed" may not be regarded as a sort of 'exclusion zone' when the standards on taste and decency can be suspended.

The Broadcasting Standards Council


ational VALA welcomes the White Paper's proposal to merge the British Standards Council with the Broadcasting Complaints Commission. Such a merger would enhance the status of both bodies and help to secure their future. The merger, however, should not in any way diminish or blur the distinctive roles performed by the Commission and by the Council.

However, National VALA believes that the current activities of the Broadcasting Standards Council need to be modified in two crucial areas.

The Broadcasting Standards Council was set two important tasks, among others, by the then Home Secretary, The Rt Hon Douglas Hurd MP, firstly of drawing up a Code on the portrayal of violence and sex and standards of taste and decency, secondly, "to receive, consider and make findings on complaints and comments…."

The Code of Practice drawn up by the BSC is a lengthy and complex document which differs very little for Codes drawn up by the Broadcasting Authorities. The BSC Code published in November 1989 and revised in February 1994 lacks definition and firm direction and consequently excessive latitude is allowed. It is apparent from much contemporary programme content that little notice is taken by the broadcasters of the BSC Code of Practice or, indeed, their own Programme Codes and Guidelines. (see Appendix 2)

However, the Council is to be commended for making copies of the Code of Practice available free of charge although more could be done to promote it. This Association believes that it is important for members of the public to know and understand the standards that have been set on their behalf.

The function of receiving and considering complaints and comments from the public and making findings requires modification.

The BSC has interpreted this part of its brief in such a way that the Council itself upholds or does not uphold the complaints received. This practice above all, which has resulted in the vast majority of complaints being "not upheld", has given rise to feelings of frustration and loss of public confidence in the Council.

The Council, which was established to improve standards, in a report published on 26 January 1994, identified worsening trends with regard to violence, explicit sex and bad language during exactly the period in which it had been in operation and with its statutory status!

It is therefore, evident that the broadcasting organisations take little notice of the BSC as it presently operates and proceed to transmit programmes which defy the standards set out in the Code of Standards and Practice by the BSC, by the Broadcasting Authorities themselves and by Parliament. The films described in Appendix 1 exemplify this.

Despite the difficulties and frustrations it is encouraging that the number of complaints received by the Council, according to its Annual Report for 1993 published 21.7.94, has risen dramatically most notably with regard to violence (25%) and swearing and blasphemy (60%) With a 26% overall increase in complaints.

National VALA recommends that the Broadcasting Standards Council should publish a summary of its Code of Standards and Practice and make it widely available to the public. The Council should continue to issue monthly compilations of complaints received, as it does by way of the "Complaints Bulletins" but instead of the Council acting autonomously in upholding or not upholding the complaints to the Broadcasting Authorities. The Broadcasting Authorities should report back to the Council on the action taken to remedy the causes of the complaints the Council has received.

The Broadcasting Authorities would thus be seen to be dealing properly with the expressions of public concern and dissatisfaction and the frustration felt by many would to some extent be alleviated.

This Association welcomes the proposal to bring the BBC within the Citizen's Charter regime. However, the revisions set out in this paper are essential if the Charter, in this application, is to have any meaning.

Obscene Publications Act 1959


he removal of the exemption for Broadcasting from the provisions of the Obscene Publications Act 1959, brought about by the Broadcasting Act 1990, was also welcomed by this Association having campaigned for this amendment over many years. However, it is essential that this weak and ineffective Act of Parliament be amended, so as to fulfil Parliament's intention to "strengthen the law concerning pornography".

International Agreement


e also believe that the Government, in the increasingly aggressive international broadcasting environment, should press, through the European Union, for a simple but radical change in European law. The law currently requires satellite television stations be licensed in the country from which programmes are transmitted. We believe that the country receiving the programmes should be the one with responsibility for granting or refusing the licenses.


'CARNAL KNOWLEDGE' - BBC2 29.5.94 10.35pm U.S. Film made in 1971


Sex drama following the love affairs of two male friends from student days to middle age. Part of the Moviedrome season.

Pre-Screen announcement - "strong acting, strong language".

Sex - Young man puts his hand on girl's breast. She objects but he keeps his hand in place. Scene of simulated sex in woods between young man and young woman. Unmarried.

Scene of young man semi-nude on bed with young woman and trying to induce her to have sex. Unmarried. Scene of naked man and woman on bed following sounds of sexual passion. Unmarried.


Man to man- She let me feel her up the first day. Big tits-2 times. Fucked out! Her tits were too small. I wouldn't kick her out of bed. Did you feel her up yet? Fuck you! Jesus!-2 times Bull shit artist!-5 times. Get his number and fuck her! I fucked her once. She's a real ball buster, that one. I don't think I fuck more than a dozen new girls a year now. You can't make fucking your life's work.

Woman to man- You're a prick, you know that?

Man to man- You lucky son of a bitch. Bull shit, it was! Where the fuck is my shoe horn? Do something useful, god dam it! Make this god dam bed! You ball busting, castrating, son of a cunt bitch! You know her problem? She wqants balls. She's so god dam passive. She picked up her skirt, pulled down her drawers and shoved her ass at me. Here's Eileen, my first fuck. Here's a real cunt. Jesus Christ!

'RELENTLESS'- BBC1 25.6.94 11.40pm U.S. Film made in 1989.


Thriller. After being rejected by the L.A. Police training academy because of his mental instability, a young man becomes a psychotic killer, picking out his victims at random from the city's telephone directory.


Man jumps on man from behind, grabs him round neck and half throttles him; then gets kitch knife, clenches it in victim's hand and as victim recovers pushes knife into victim's heart. Thrust indicated but not fully shown. Bloody wound and hilt of knife shown. Very violent and deliberate killing. Man smacks small son across face with hand because child failed to hit target with loaded automatic. Boy falls down. Man pursues woman through house to basement. She hides in clothes drier. He finds her, pulls her out and strangles her with piano wire that he has ripped from her piano. Violent murder which dwelt on her dying gurgles. Woman shown sniffing cocaine. Man attacks man from behind, punches victim violently in kidneys then forces ice pick or needle type bottle opener into victim's throat. Afterwards goes upstairs and attacks almost naked woman on bed and strangles her. Two very violent murders. Man shoots dtective six times with silenced automatic at close range in victim's kitchen. Blood smeared down wall. Bloody body seen in close-up. Violent murder. Man threatens woman and small son with revolver. Detective shoots man dead with revolver in detective's home.


Man to police sergeant. Oh shit.

Man to man- scrape that shit off. Bull shit-4 times. She kicked the shit out of the inside. One Jack shit. Son of a bitch. For Christ sakes. Useless bull shit. Shit. You don't give a shit Jesus. Jesus Christ. You're an arse hole. You're full of shit. You're a bastard.

Detective to Detective-Meanest, toughest son of a bitch I ever met. No shit. God dam. Bull shit. I catch a lot of shit from you. Shit, Molloy, you're just as big an arse hole. Bull shit idea. You arse hole. The shit hit the fan. God damn news conference. Jesus. Oh shit. God lying little prick. Officer kiss my arse.


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