Published: 19th June 2009
The Christian Medical Fellowship (CMF) is an interdenominational organisation with more than 4,500 British doctors as members. All are Christians who desire their professional and personal lives to be governed by the Christian faith as revealed in the Bible. Members practise in all branches of the profession, and through the International Christian Medical and Dental Association are linked with like-minded colleagues in over 100 other countries. CMF regularly makes submissions on ethical and professional matters to Government committees and official bodies. All submissions are on our website at www.cmf.org.uk/ethics/submissions/. Perhaps most relevant to the subject matter of this submission to the BCAP is our submission in 2007 to the House of Commons Science and Technology Committee's new inquiry into 'Scientific developments relating to the Abortion Act 1967 .
One of CMF's aims is 'to promote Christian values, especially in bioethics and healthcare, among doctors and medical students, in the church and in society'. While therefore advocating marriage as God's intention for human sexual relationships, and families headed by married couples as the ideal context for the procreation and nurturing of children, our members practise within the whole range of relationships and behaviours current in UK society, and this submission endeavours to reflect that.
We confine ourselves to the consultation questions directly relevant to our aims, namely those concerning proposed TV advertising of family planning centres and of condoms to children aged 10-16.
Given BCAP's policy consideration, do you agree that it is necessary to maintain a rule specific to post-conception advice services and to regulate advertisements for pre-conception advice services through the general rules only?
We note that the discussion of 'post-conception advice services' appears to apply only to the consideration of whether or not to have an abortion, and not to ante-natal advice for women continuing with their pregnancy. We therefore limit our discussion to the question of whether, on balance, abortion advice services should be advertised on television?
We answer this question 'No'. Because of the cost of TV advertising, it is likely that only those 'advice services' with large incomes from the performance of abortion (and therefore also with financial vested interests as well as ideological ones) will be able to afford significant advertising. Thus there will be a disproportionate opportunity for abortion providers to advance their cause, in a morally contentious area. Almost everybody in the UK thinks '200,000 abortions a year is too many' and TV advertising will increase this number.
We argue that such advertising is both unnecessary and unethical.
Any woman considering abortion will be sufficiently motivated and will easily be able (with the help of friends if necessary) to find information about abortion providers from the wide range of sources currently available – internet, print advertisements in newspapers, women's magazines, etc. There is simply no need to advertise abortion providers on television.
Such advertising would be unethical on two grounds:
Medical considerations, and the approach taken by abortion providers
Abortion is always a procedure with a 50% mortality – the life of the fetus is intentionally ended. However, there is also growing recognition of serious long term medical consequences for some women undergoing an abortion:
Subsequent pre-term delivery
There have been many reputable studies confirming the association between abortion and pre-term delivery. , , ,  This association is significant for health outcomes in subsequent pregnancies and for their economic costs to parents and to society. Extremely preterm delivery is associated with high risk of neonatal death and of permanent brain damage causing long term disability. Most women considering abortion will subsequently deliver one or more live children, who will face these risks. Women should be adequately counselled about abortion and risk in subsequent pregnancies, and the counselling offered by the main abortion providers is inadequate here.
Psychological and psychiatric consequences
Any association between abortion and mental health problems has effectively been dismissed not as causal, but as incidental due to other confounders. But in the last decade, there has been much evidence from robust and methodologically sound controlled studies that abortion causes:
In addition to this quantitative psychiatric data we have summarised the psycho-social consequences some women undergoing abortion suffer. 
A possible link with breast cancer
Breast cancer rates are rising in Europe and North America and are projected to rise further. There is evidence suggesting that having an abortion may increase a woman's risk of breast cancer in later life.  A 1997 review that pooled 23 studies found that the risk increased by 30%  but authors of a 2001 review have denied a link. However, it is undisputed that a full term pregnancy protects against subsequent breast cancer, and that significantly pre-term deliveries make it more likely. The link is therefore biologically plausible.
Women should be adequately counselled about all these risks, and given the 'space' necessary to make a truly informed decision. The limited service of the main abortion providers in these respects is inadequate. Permitting TV advertising of abortion services is likely to cause more women to have abortions and therefore will harm more women.
BCAP must consider issues of context, of interpretation, and of the 'message' that TV advertising of abortion services would bring. We are aware that BCAP acknowledges the unique power of television as a medium. TV does not just convey information; it inevitably conveys a powerful message of what is accepted and acceptable. Television creates culture as well as reflecting it.
Males watching abortion adverts will become even more likely to conclude that the prevention of pregnancy is the responsibility of the female, and that abortion is there as a socially acceptable back-up means of contraception. This ignores the destruction of the fetus; the possible serious health consequences to the female; and if it makes the male less likely still to use barrier contraception may put him at even greater risk of acquiring a sexually transmitted infection.
Most females viewing abortion adverts will not actually be pregnant at the time, but again are likely to take on board the message that abortion is there as a quick fix if they have failed to use contraception or if contraception has failed. This will discourage a responsible approach to sexual behaviour and lead to other attendant risks.
CMF therefore holds 'that it is necessary to maintain a rule specific to post-conception advice services' and believes that rule should continue to prohibit the TV advertising of abortion services.
We are not in a position to comment on whether 'to regulate advertisements for pre-conception advice services through the general rules only'.
Given BCAP's policy consideration, do you agree that rule 11.11 should be included in the proposed BCAP Code? If your answer is no, please explain why.
Because of our real concern that the only agencies able to afford sustained abortion advice advertising will be the current abortion providers, and because of our conviction that advertising by them is both unnecessary and unethical, we argue that there should be no such advertising.
Should that argument not prevail, we would seek 'a level playing field' for advertising by agencies from both sides of the debate. We dispute the claim from the House of Commons Science and Technology Committee's new inquiry into 'Scientific developments relating to the Abortion Act 1967' that pregnancy counselling services that do not refer for abortion intentionally mislead, and cause dangerous delay should abortion ultimately be performed. We counter (see above) that the counselling of the abortion providers intentionally misleads by omission.
In any case, BCAP notes that some agencies do not have the legal power to refer directly. We suggest that should such advertising go ahead, all agencies should be required to make a statement about their referral practices. For some this might read along the lines of:
'XXX does not have the legal power to refer directly for abortion, but aims to give you the space and balanced information you need to make your own choice. Should you conclude you want a referral for consideration for abortion, we will if necessary give you appropriate advice.'
Those advice services that do have the power to refer directly (very probably to their own staff) should be required to publish the statistics of referral rates for the preceding year, along the lines of:
'YYY can refer you directly to our own staff for abortion. In 2008, ZZ% of those we counselled were referred for abortion.'
Should TV advertising be permitted, we would accept the principle of a statement about referral policy and practice. We believe the policy outlined above, applied fairly and equally to both sides of the debate, would lead to a greater probability of the woman eventually making a fully informed choice.
Do you agree that television advertisements for condoms should be relaxed from its present restriction and not be advertised in or adjacent to programmes commissioned for, principally directed at or likely to appeal particularly to children below the age of 10? If your answer is no, please explain why.
We argue that this proposal is also unnecessary and unethical. We note that 'Baroness Gould of Potternewton, Chair of the Government's Independent Advisory Group (IAG) on Sexual Health and HIV, wrote to BCAP to request a review of the scheduling restrictions on condom advertising, noting that the UK had the highest teenage pregnancy rate in Europe and spiralling rates of sexually transmitted infections'.
The presupposition in this proposal is that more condom advertising to an ever wider range of young people will reduce unintended pregnancy and offer some protection against sexually transmitted infections. Briefly, the evidence shows, instead, a correlation between the government's policy of increasing promotion of contraception and the very rises Baroness Gould notes.   Again, as we argue above, the negative effect of the 'message' trumps any possible positive medical benefits.
The more that sexual behaviour is trivialised, the greater will be the numbers of those involved in casual behaviour. Whether they set out intending to use condoms or not, the greater will be the adverse health consequences. The correct strategy is to promote responsible sexual choices by young people and television can have great power for good here.
We question whether the current 9pm watershed (on most channels) is in any case a deterrent to children and young people aged 10 upwards – they are likely to have access to such adverts already. We emphasise that it would be impossible to prevent children under the age of 10 from watching such adverts screened earlier, should this proposal be adopted.
Further promotion of condom advertising to children aged 10-16 is unnecessary and unethical. Those for whom condom knowledge is relevant will find it anyway, and the ever increasing trivialisation of sexual behaviour will damage more and more children and young people.
Christian Medical Fellowship is grateful to have had this opportunity to comment, and wishes BCAP well in its many deliberations. We would be willing to help further on these two specific matters.
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Dr Peter Saunders (CMF Chief Executive) 020 7234 9660
Philippa Taylor (CMF Head of Public Policy) 020 7234 9664
John Martin (CMF Head of Communications) 020 7234 9665
Alistair Thompson on 020 3008 6063 or 07970 162 225
Christian Medical Fellowship (CMF) was founded in 1949 and is an interdenominational organisation with over 4,000 British doctor members in all branches of medicine. A registered charity, it is linked to about 65 similar bodies in other countries throughout the world.
CMF exists to unite Christian doctors to pursue the highest ethical standards in Christian and professional life and to increase faith in Christ and acceptance of his ethical teaching.