Gambling as a public health issue?

Gambling Is Not a Public Health Issue


When campaigners call gambling a public health issue, they are not making a loose rhetorical point. They are invoking a specific piece of theory, and it matters that people understand what it is and what it commits them to.


The theory is the Total Consumption Model, imported from alcohol research. It holds that harm in a population rises and falls with total consumption. Under this model, you do not need to identify who is being harmed or show that a policy helps them. You only need to reduce the overall amount of the activity. Less gambling in aggregate is treated as less harm by definition.


Read Gambling with Lives’ own evidence to Parliament this year. They state openly that the policy question is not whether advertising causes addiction. The question is whether it increases participation. Participation itself has become the target. That is the model working exactly as designed. Once it is accepted, every measure that shrinks the market counts as a success, whether or not a single person suffering from gambling disorder is helped.

This is why important racing figures like Martin Cruddace need to revise his view that for political reasons we need to accept the gambling as a public health issue. Because it is false. Were we to accept this premise we could argue driving as a public heath issue similarly.

Road safety policy however differs from the ‘gambling public health argument’ in that it targets the harmful behaviour and leaves the rest of the population alone. Drink driving laws restrict drunk drivers. Speed enforcement restricts speeders. Nobody proposes cutting road deaths by reducing the total volume of driving, rationing mileage, or requiring ordinary motorists to prove they can afford their petrol. That is precisely what advocates seek from gambling reform. It attacks everyone, not just the vulnerable. Changing my old mucker’s mind on anything is like trying to shift the Titanic. He is, however of enormous influence, so we must try. I am not suggesting the boss of Arena Leisure as an anti gambler. Far from it


The participation in argument matters because the model makes a testable prediction, and in gambling the prediction fails. Total consumption rose enormously over two decades. This is a key point. Online betting grew from nothing into the largest part of the market. Advertising spend ran into billions. Smartphones put a betting account in every pocket. If harm tracked total consumption, problem gambling prevalence should have climbed with it. It did not. On the health survey series it stayed at around half of one percent of adults throughout. Exposure went up. The rate of disorder did not. The foundation of the entire framework does not hold for this activity.


Now look at what the model has delivered in practice. Affordability checks applied the total consumption logic directly: restrict the whole betting public in order to reach the few. Customers refused intrusive document demands and left the regulated market. Racing’s funding contracted. The Gambling Commission has produced no evidence that problem gambling fell as a result. Under any normal test that is failure. Under the total consumption test it is success, because the market got smaller. That is the sleight the public health framing performs. It changes the definition of success from harm reduced to gambling reduced, and nobody voted for that change. Gamblers neither want to reduce, nor does it shift the bar on problem gambling one iota (that is if you don’t move the bar, as the gambling commission has with its absurd gambling survey of Great Britain!)


The same logic now underpins demands for tax rises designed to shrink the sector and for the denormalisation of betting called for by the chair of the Lancet Commission, and fanatical anti gamblers like Heather Wardle on gambling. The stated aim in each case is less gambling, not less harm.


Gambling disorder is real and can be devastating. It affects a small minority who need identification, treatment and support. Those are targeted clinical tasks. A framework that measures success by the contraction of a lawful market, while producing no evidence of reduced harm, is not protecting anyone. It is pursuing a different goal under a borrowed name.

Sample Bias – the new normal

 
Great Britain: Regulation – Is the Great British Gambling Debate heading for a Terminal solution?


Last week’s House of Lords debate on gambling advertising was in many respects the same tired old combination of mistruths and moral indignation; but it was notable for providing a glimpse into the next phase of gambling policy discourse in Britain. Lord Foster of Bath, who instigated the short debate told the House that:
 
“I suspect public concern is about to rise because, in July, the Gambling Commission will release new figures about gambling harm. The Gambling Minister in the other place has already indicated that they are likely to show that 1.3 million people will classify as ‘problem gamblers’ and that a further 6 million are at risk. If confirmed, these figures are far higher than those used to inform the Government’s work on their White Paper. This is a real cause for concern, further strengthening the call for action.”


 
The intent could not be clearer. If the publication of the Gambling Survey for Great Britain (‘GSGB’) in July reveals a markedly higher rate of ‘problem gambling’ than the estimates relied upon by the Government in its White Paper, then the wisdom of the policies contained therein will be open to question. Lord Foster’s point is a fair one. In its White Paper, the Government relied on the 2018 Health Survey for England, which reported a ‘problem gambling’ prevalence rate of 0.38%; and the current Official Statistic (from the HSE 2021) is 0.25%. The Final Experimental Stage of the GSGB reported a figure of 2.5% – between six and ten times higher than the HSE. If the Government and regulator are confident that results obtained from the GSGB are reliable, concern groups will justifiably ask for a re-run of certain policy decisions (and possibly even Judicial Review, given the litigious bent of some activists).
 
The problem is, of course, that the Gambling Commission does not appear to be at all confident that results obtained from the GSGB will be reliable. Each of the new survey’s iterations – from the Pilot Survey in 2022 to the Experimental Stages in 2023 to Wave 1 of the official survey in 2024 – has revealed signs of sample bias. In an independent review (‘independently’ funded by the Gambling Commission), Professor Patick Sturgis of the London School of Economics, commented on the “non-negligible risk” that the GSGB would “substantially over-state the true level of gambling and gambling harm in the population”. He also urged caution, warning that “until there is a better understanding of the errors affecting the new survey’s estimates of the prevalence of gambling and gambling harm, policy-makers must treat them with due caution.” Such advice appears lost on the Commission (which prefers to gloss over inconvenient opinions). In addition to rates of ‘problem’ and ‘at risk’ gambling’, it plans to release survey findings in respect of suicidality, violence and abuse, mental ill-health and use of food banks – in the knowledge that the figures may very well be incorrect and misleading. Just when the Department for Culture, Media and Sport might have thought it was nearing the end of a long and tortuous journey on gambling reform, the Commission is throwing down new track.


 
The threat to the licensed betting and gaming market in Great Britain is severe. The public health establishment (including senior figures within the Department for Health and Social Care) has signalled its intention to “tackle gambling” (all gambling and not just harmful gambling) in the same way that it has dealt with tobacco smoking. Demands for total bans on advertising (including at racecourses), the sale of beer and wine in bingo clubs and casinos and the imposition of ‘plain packaging’ for all gambling products (no colours, logos or images – farewell Queen of Hearts), will intensify. In Scotland, it is reported that the SNP plans to raise the legal age of gambling if it achieves independence (presumably with a carve out for anti-gambling vitriol in its Hate Speech legislation) but this is only a stop along the route rather than a final destination. It is far from obvious however, that the industry realises the perilous nature of its current position. Tone-deaf advertising on bus stops and at railway stations only strengthens the ground for those seeking a terminal solution.