If a recent movie hadn't already taken the title, Jack Valenti could be dubbed "Jack the Bear."

As president of the Motion Picture Association of America for the past 27 years, Valenti has a reputation for being irascible and feisty, especially when it comes to defending his baby, the Classification and Rating Administration, better known as the movie rating system.Valenti created the ratings in the late '60s, putting them into effect in November 1968. Since then, rotating board members have passed judgment on some 10,000 movies, the vast majority receiving R ratings.

In a recent telephone interview from his Washington, D.C., office, Valenti offered a brief history of the rating system, described its inner workings and answered specific questions on the subject to clear up possible public mis-con-cep-tions.

Question: Can you describe for us what the rating system is and why the Production Code, which was enforced for 20 years, from the mid-'30s to the mid-'50s, was dismantled?

Answer: The rating system is a voluntary system whereby producers submit their films to the rating board in California, and then the rating board gives a rating:

- G, for general audiences, nothing offensive to a parent if they bring a child.

- PG, which says to parents, "Parental guidance suggested, some material may not be appropriate for your young children."

- PG-13 says, "Mr. and Mrs. Parent, extra parental guidance on this picture." Some material may not be suitable for young children.

- R is restricted, children 16 and under should have a parent or an adult guardian [with themT. And there is adult material in this picture. So, we say to parents, "Please don't take your kids or allow them to see this, unless you have a chance to check this picture out first."

- NC-17 means no children allowed under 17; this is a picture that, because of theme or sex or violence or language, has been labeled a film that adults should see and not children. It does not mean pornography, it does not mean obscenity - those are legal words. It merely means a film that young children should be barred from seeing.

The whole objective of the rating system is to give parents some advance cautionary warning, so that the parent can make the decision as to what movies his or her child should or should not see.

Question: So, the rating system is for parents, that's who it's aimed at.

Answer: It is directly for parents. If you have no children, or your children are over 16, this rating system is of no meaning to you.

Question: Tell us about the Production Code.

Answer: The Production Code came into being in the 1930s. One of my predecessors, Will Hays, installed it and it was literally a catalog of do's and don'ts, such as you couldn't have open-mouth kissing; if two people were in bed, even if they were married, each of them had to have a foot on the floor . . . .

The Production Code worked perfectly, so long as the studios owned all the theaters. Therefore, if you didn't have a seal of approval, as a producer, you literally couldn't get a playdate for your movie. But in 1950, the Department of Justice, broke up what they said was anti-competitive practice and forced the studios to sell off their theaters. And on that day the Production Code was severely crippled and shortly thereafter really expired. It reallydidn't have any force and power.

And when I came into this job as a leader of the industry in 1966, I realized something would have to be done, there would have to be a replacement for the Production Code, and so I invented the rating system.

This is all a voluntary system today. That is, no producer is forced to cut one millimeter of his film, if he - the producer or the director - doesn't choose to. So, it isn't censorship at all. And if any editing is done, it's because that is the choice of the director or the producer.

Question: Wasn't one of the reasons you created the rating system to avoid government censorship?

Answer: In April of 1968, shortly before the rating system was born, the Supreme Court said that it was perfectly legitimate and did not torture the First Amendment for cities and counties and municipalities to have their own rating system. You can imagine if we had 300 or 400 rating boards in America, it would be alphabetical chaos out there, and the movie industry as we know it couldn't survive in a rating board jungle.

Question: How is it enforced? How can parents be sure their kids won't be allowed into an R-rated movie?

Answer: The enforcement is totally up to the theater. The National Association of Theater Owners, which is a partner in this enterprise, tells me that some 75-80 percent of the theaters are enforcing the ratings. If a parent finds out they aren't, I suggest that they use a good old American tradition, of going down to the theater owner and saying, "Look, a lot of families live around this theater, we want you to enforce these ratings." And I think most parents will get some kind of a favorable response.

Question: Who sits on the rating board and how are they chosen?

Answer: The only person in the industry that has a connection with the rating board is me, which means I stand between the rating board and the entire film industry and, indeed, everybody else. So there is no pressure of any kind. Only I have the power to hire and fire the chairman of the rating board, and only I, along with the chairman, have the power to employ the permanent members of the rating board.

There are 11 members on the rating board - men and women, blacks, whites, Hispanics, Protestant, Jewish, Catholic. We try, if you can do this in 11 people, to get a microcosm of the country. And they stay on the board two, three years at a time, and then they leave and new people come on. We try to make sure there's a replenishment of new people. The sole criterion is that you must be a parent - (each) rating board member has to be a parent.

Other than that, we want them to love movies, to be intelligent, to care about the ratings themselves. We've been in business now for 24 years, and nothing lasts that long in a volatile marketplace unless it's providing some kind of benefit to the people that it aims to serve - in this case, the parents of America.

Question: How do you choose the board members?

Answer: They write in and say they'd like to become a member of the board. Sometimes a teacher will take a sabbatical and want to stay on the board a year or two. Letters come in from all over the country, we interview them and we pick them. There's nothing mysterious about it, it's done like any business would try to hire people.

Question: But you don't reveal their names.

Answer: No, we don't. We give a demographic profile of each person. And the reason is, I don't want some angry producer, mad because he got a more severe rating than he thought he deserved, harassing these people, either by letter or phone call.

Question: Is this a full-time job?

Answer: It is a full-time job and they're paid to do this. They see two to three pictures a day. So, if you don't like movies, you won't like this job.

Question: How much are they paid?

Answer: That is what we call an IRS confidentiality secret.

Question: Are there any hard-and-fast rules about what deserves a certain rating?

Answer: The only hard-and-fast rule we have is language. If you use a particularly vulgar word that is connected to sex - the so-called "F-word" - if you use it more than twice in a film, you're automatically going into "R." So, we use that as the only automatic rule. Other than that, sex, violence, theme, general demeanor of the film are all subjectively valued by this board. It's very difficult to have precise rules. What is too much violence, for example? That's a subjective enterprise.

Question: It seems to me, however, that quite a few films rated PG-13 use that word more than just a couple of times.

Answer: The rating board has the power in this automatic rule - that if they believe the film is otherwise fairly benign, and that the language is not part of an overall hard realism - they have the power to say, "OK, we'll forgive that and give it a PG-13." But it depends on what the rest of the film is like.

Question: One of the complaints I hear most is that certain categories are inconsistent. For example, it's difficult to understand why the same R rating can be given to movies as widely disparate as, say, "A Few Good Men" and "Basic Instinct."

Answer: That's true, because you can't draw fine lines in this thing and have the R split up into four or five different sections. What R says is, "There is adult material in this film, Mr. and Mrs. Parent. Therefore, we caution you, we really strongly caution you, to find out more about this film either by seeing it yourself, or reading the reviews or reading in magazines or talking to a neighbor who has seen the film. Check it out before you allow your young children to see it." And that runs the whole gamut of R films. While there might be hard, harder and hardest in an R film, all of them contain adult material, as far as the rating board view is concerned.

Question: Even though the ratings are for parents, a lot of adults do use the ratings to get an idea of how rough the film is going to be. And it is hard to tell just by the rating.

Answer: Yes, and that's why we say, `Find out more about this film.' Keep in mind, the rating board is not a surrogate parent. We can't really tell you in a rating, even if you had seven alphabetic terms in there, what a film is about. When you say violence, it can run the gamut of violence - anywhere from the rustler being killed by the sheriff to a serial killer. Violence is a wide spectrum. The only way you can really find out about a film is either to see it or to talk to someone who has seen it.

Question: What about films rated PG? Parents do, in most cases I think, feel a PG-rated film is probably going to be fairly safe for their kids. But aside from family pictures, movies like "Housesitter," which has a fair amount of sexual content, also carry a PG. And when parents let their children see these pictures, they sometimes feel betrayed.

Answer: Yes, and I can understand that. The rating board has rated over 10,000 films since it came into being, and I have not agreed with all the ratings of the rating board. I have to say that honestly to you. But keep in mind that the rating board is composed of people like you and me - they're human beings. And I dare say that you have erred a couple times in your career. I certainly have many times in mine. Maybe I've made bad judgments or bad calls. Same thing with the rating system. They're not impervious to error. They don't have barriers against which error cracks itself. So, the fact is that maybe we do make some mistakes from time to time, but they try to do the best that they can, and all parents are different. There are 250 million people in this country, and some of them are upset by violence, some are upset by sex, some by language, some by theme. So, it is impossible to please everybody all the time. I think disappointment and error are built into any kind of man-made operation like this.

Question: What's your response to the accusation that the ratings have become softer over the past 25 years, that board members seem more liberal in their view of violence and sex and therefore give films softer ratings?

Answer: Let me ask a counter-question? Has the society changed in the last 25 years? I think the answer is, it has changed greatly. I know that as an observer, there seems to be much more violence in our society, people getting killed more. There is a lessening of some of the old values. There's been insurrection on the streets and rebellion on the campuses and the rise of feminism, which has changed the way we look at things - and I think for the better. And there have been all the civil rights lawsthat have come in, that have changed the kind of way we look at others of different race and nationalities. There has been a lot of change in the mores and the customs of the society that have reflected itself in a rougher, sometimes, kind of society.

So, it's impossible that movies, the most creative of all the art forms, would be immune to these changes in the social landscape. So, the answer to your question is, `Sure.' I think what might have been an R in 1966 or '68 today probably is a PG-13. Keep in mind that an X-rated picture - which was the adult category up until two years ago [when it was replaced by NC-17T - an X-rated picture, "Midnight Cowboy," won the Academy Award (for best picture). Since then, the mores and customs have changed and there've been no adult pictures that have been nominated for an Academy Award, much less won it.

Question: Do you have keep figures on the films you rate, percentages of those in each rating category?

Answer: Yes, last year the rating board rated about 450 films, of which 161 came from the major companies and the rest came from independent producers. About 55 percent carried R and NC-17, and the rest were G, PG, PG-13.

Question: So, the majority of the films are rated R.

Answer: Yes, the majority of the films are rated R - but from the major companies, the majority are not rated R.

One of the things that I should point out is, ratings have absolutely nothing to do with box office. I have what I call "Valenti's Law," and that is, "If you make a film that a lot of people want to see, no rating will hurt you. If you make a film that few people want to see, no rating will help you."

How many people do you know, families, men and women, who wake up in the morning and say, "Tonight, let's go see an R-rated movie," or, "Let's go see a PG-13." They don't do that. They say, "What's playing? Oh, I want to see Clint Eastwood's new film," or, "I want to see `A Few Good Men' or I want to see `Aladdin.' " They don't go to movies based on ratings, for goodness' sake.

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Question: You have said that you have a 75 percent public acceptance rating with the movie ratings, is that right?

Answer: Every year we take a poll by the Opinion Research Corp. of Princeton, N.J. We interview about 2,600 people nationwide, which is more than most national political polls do. For the past 15 years, 70-75 percent of parents with children under 13 say that the rating system is very useful to fairly useful in helping guide parents' moviegoing decisions for their children. About 20 percent say it's not useful and the rest have no opinion.

Question: Do you see the possibility of further changes in the system in the near future?

Answer: We foresee absolutely no changes in the rating system.

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