Tag: Horse racing

The gambling suicides myth

The rate of deaths caused by gambling has been foolishly exaggerated

The rate of deaths caused by gambling has been foolishly exaggerated

Artillery Row by Christopher Snowdon May 2024

here is one gambling-related suicide in the UK every day. There are up to 496 gambling-related suicides a year. Ten per cent of all the suicides in England are caused by gambling. 

These statistics, and other iterations of them, have become mantras for the anti-gambling lobby since January 2023 when the Office for Health Improvement and Disparities (OHID) published a report claiming that there are “between 117 and 496 suicides associated with problem gambling” in England. Activists naturally focused on the larger of these two numbers and started putting it on billboards. The monetised value of years of life supposedly lost to suicide make up most of the “up to” £1.77 billion that gambling is said to cost “wider society” each year.

It turns out that these figures are based on nothing. They are a will o’ the wisp. A mirage. They exist only on a laptop in Whitehall. They are worthless.

How can we possibly know how many suicides are linked to problem gambling, let alone how many are solely caused by it? Gambling is only mentioned on one coroner’s report a year, on average, which is presumably an under-estimate. In the absence of better evidence, OHID’s predecessor Public Health England turned to a study from Sweden which looked at 2,099 hospital patients who were diagnosed with pathological gambling between 2005 and 2016. Sixty-seven of them died, including 21 who took their own life. The authors noted that the suicide rate among this cohort of pathological gamblers was fifteen times higher than the suicide rate of the general Swedish population. 

Upon this sliver of evidence, everything else rested. In 2021, Public Health England simply estimated how many problem gamblers were in England and then multiplied the number of expected suicides by fifteen. This produced a figure of 409 suicides a year which anti-gambling activists then put on T-shirts. 

Public Health England was closed down soon afterwards and replaced by OHID. Last January, OHID used the same methodology but produced two different estimates, one based on how many people are thought to have “gambling disorder” (previously known as pathological gambling) and the other based on how many suffer from the less severe condition of “problem gambling”. The figures were 117 and 496 respectively.

You don’t need to be intimately acquainted with basic statistics to see the problem here. People who are being given medical or psychiatric treatment in hospitals are inherently different to people who are not. If you are admitted to hospital, there is already something wrong with you. If you are admitted to hospital and asked to take a survey to diagnose gambling disorder (or any other psychological problem) then you are very likely to be at the higher end of the risk spectrum.

Sure enough, there was a lot wrong with the 2,099 people in the Swedish study. Between 2005 and 2016, 65 per cent of them suffered from “injury, poisoning, and other consequences of external causes”. 60 per cent had an anxiety disorder. 51 per cent suffered from depression. 41 per cent had a substance-use disorder. 29 per cent had an alcohol-use disorder. 19 per cent had a personality disorder. 19 per cent intentionally self-harmed. 12 per cent were bipolar. 9 per cent had schizophrenia. In the context of all this human misery, a suicide rate of one per cent does not seem too surprising and it is absurd to assume that all the suicides were the result of problem gambling. For many of these unfortunate people, gambling may have been the least of their worries.

The authors of the study freely admitted that these hospital patients were unlikely to be representative of the average problem gambler:

It is therefore likely that results may be skewed toward a population of individuals with more severe forms of GD [gambling disorder]. It is likely that this once again implies that this study sample might contain patients with higher mental health comorbidity, as well as individuals with more severe forms of GD, since these individuals are more likely to receive specialized psychiatry care.

Public Health England and OHID ignored all this and extrapolated the suicide rate among pathological gamblers with multiple co-morbidities in Swedish hospitals across the estimated number of problem gamblers in the general population in England. No attempt was made to adjust for the many other risk factors for suicide that these people obviously had. 

Last year, however, one of the two authors of the Swedish study did exactly that. Using the same dataset in a new study for her PhD thesis, Anna Karlsson found that “gambling disorder did not appear to be a significant risk factor for the increase in suicide and general mortality when controlling for previously known risk factors”. She concluded that her research “could not determine whether GD [gambling disorder] is an independent risk factor for suicide”.

This does not mean that there is no link between gambling disorder and suicide. History and common sense tell us that people who get into severe financial difficulties are more likely to take their own lives and it is obvious that problem gambling is one way to suffer financial distress, albeit the only one that is now treated as a “public health” issue. What it does mean is that gambling disorder, on its own, was not a big enough risk factor for suicide to show up among the people studied by the Swedish authors using standard statistical practice. If you extrapolated the properly adjusted figures from the Swedish study across the English population, the number of gambling-related suicides would be zero.

It is hard to believe that OHID was not aware that it had made an error that a literal schoolboy could have spotted. Public Health England was closed down because it was incompetent and was too easily distracted by lifestyle issues when it should have been focusing on public health. It was more of an in-house lobby group than a serious scientific agency. It seems that closing it down and re-opening it under a new name with the same staff was not enough to make the leopard change its spots.

The Great Suicide Deception – Part IV – What purpose is served by spurious statistics?

Dan Waugh-Regulus Partners May 2024

This is the fourth and final article in our series on attempts by state bodies to claim widespread suicide mortality associated with problem gambling. In the first three articles we demonstrated why estimates prepared by Public Health England and the Office for Health Improvement and Disparities were irretrievably flawed; we examined the conduct of PHE and OHID, including evidence of bias and inappropriate behaviour; and we considered the role played by the Gambling Commission, the Advisory Board for Safer Gambling and others in either propagating the PHE-OHID claims or withholding concerns about their reliability. We conclude by addressing the wisdom of attempts to boil down a matter as complex as suicide to any single factor.

It has long been understood that people with gambling disorder are at elevated risk of death by suicide. The DSM-5 (the American Psychiatric Association’s ‘bible’) comments on elevated rates of suicide ideation and attempts among people in treatment for gambling disorder (and makes similar observations in relation to a large number of other mental health conditions, including alcohol use disorder). Concerns in relation to gambling disorder and self-harm – and what might be done to prevent suicide by people with the disorder – are entirely valid.

It is also widely accepted that suicidality is a complex matter. In their 2016 meta-analysis of 50 years of suicide research, Franklin et al. made the following observation: 

“…any individual with nearly any type of mental illness (i.e. internalizing, externalizing, psychotic, or personality disorder symptoms), serious or chronic physical illness, life stress (e.g. social, occupational, or legal problem), special population status (e.g. migrant, prisoner, nonheterosexual), or access to lethal means (e.g. firearms, drugs, high places) may be at risk for [suicidal behaviours and thoughts]. A large proportion of the population possess at least one of these risk factors at any given time, with many people possessing multiple factors.”   

Understanding that people with a gambling disorder are at elevated risk of suicide is helpful when it comes to devising self-harm prevention strategies. For example, Hakansson & Karlsson (the Swedish researchers relied upon by PHE-OHID) conclude their 2020 study with the following recommendation:

“The findings call for improved screening and treatment interventions for patients with gambling disorder and other mental health comorbidity.”

It is questionable however whether studies of discrete associations between any single activity or human characteristic and death by suicide should – by themselves – be used to justify state controls on that activity.  By way of illustration, a 2021 study on the prevalence of suicidal behaviour in a group of patients with behavioural addictions (Valenciano-Mendoza et al.) found: 

“the highest prevalence of suicide attempts was registered for sex addiction (9.1%), followed by buying–shopping disorder (7.6%), gambling disorder (6.7%), and gaming disorder (3.0%).”

These findings may be useful for addressing risk of self-harm within population groups suffering from these mental health conditions. They do not – by themselves – justify bans on sex, shopping or playing video games. A 2017 study of young adults in England (aged 20-24 years, n=106) by Appleby et al., found that four deaths by suicide were linked to ‘gambling problems’; and this has been used to suggest that 250 deaths by suicide each year are ‘gambling-related’. The study also found that 44 of those who had died “had a reported history of excessive alcohol use. Illicit drug use was reported in 54 (51%)”; seven “were reported as experiencing problems related to being a student” (including five experiencing “academic pressures”. One might therefore estimate (using the same methodology as for gambling problems) that around 3,200 suicides are related to illicit drug use; 2,625 to excessive alcohol use; and 440 to academia. Such findings should prompt concern and policy responses; but it is questionable whether these should extend – for example – to complete bans on advertisements for beer or universities.

Some activists have called for coroners to assess, as a matter of routine, the possible involvement of gambling in deaths under investigation – the Bishop of St Albans has doggedly pursued a Private Members Bill to mandate this. At first blush it seems to be a reasonable suggestion. The problem is that it places an additional requirement on already over-burdened coroners; and risks distortion if other known factors are not also investigated with the same degree of rigour. The presence of Adverse Childhood Experiences (‘ACEs’) is a well-documented antecedent of suicide with one study (Dube et al., 2001) finding that as many as 80% of suicide cases analysed had a history of ACEs. There are also well-documented associations between relationship breakdown and self-harm. The practicality and wisdom of asking coroners to probe into every corner of the deceased’s life should be carefully considered.

Those determined to produce figures on the prevalence of gambling-related suicide should first set out a clear operationalised definition of what this term means. How is the relationship to be characterised (e.g. does the individual need to have gambled in the prior 12 months? Does he or she need to have a diagnosis of gambling disorder?) and to what extent is there evidence of causal contribution to death (e.g. was gambling disorder a significant factor or a minor factor?). Finally, they should be required to contextualise their findings by reference to other risk factors.

Running through some of the institutional responses to PHE-OHID is the idea that unreliable estimates of mortality serve a valid purpose pending the production of more robust statistics – something along the lines of ‘fake it until you can make it’. The chair of the Gambling Commission’s Advisory Board for Safer Gambling (‘ABSG’), Dr Anna van der Gaag, for example has written that: 

“Good research, especially if it is on an under-researched area like this one, tends to begin and end in a different place, prompting challenge, replication, debate, and the research in this important area is no different.”

It is a view that overlooks four important points. First, the PHE-OHID work on the cost of gambling harms is riven with errors (including mathematical mistakes) and should not be considered “good research”. Second, the ABSG specifically called for “action” as a result of the PHE estimates – with no suggestion of the need for caution or refinement. Third, rather than welcoming challenge, the ABSG has engaged in ad hominem disparagement of those attempting to apply scrutiny to the PHE-OHID claims (likening this, without substantiation, to the activities of Big Oil). Fourth, it is questionable how far we should trust ‘better research’ if those responsible for it have propagated or tolerated misinformation in the past. As we saw during the Covid pandemic, the production of misleading statistics may in fact set back the cause of harm prevention by undermining trust in authority. 

Suicide risk among people with a gambling disorder is a legitimate issue and warrants an intelligent response; but this is unlikely to be achieved through the publication of spurious estimates of prevalence. As the US economist, Professor Douglas Walker has observed; 

“If researchers continue to offer social cost estimates, they should estimate costs that are measurable. But for other costs such as psychic costs that cannot be measured…let us identify them without providing spurious empirical estimates. Offering methodologically flawed cost estimates does not improve our understanding nor does it promote sound policy…In areas where research is still quite primitive, perhaps no data would be better than flawed data.”

Coda

We are aware that some individuals and organisations will resent this series of articles on PHE-OHID (not least the OHID researchers themselves). Our intention in writing them has not been to hurt or insult – but to shine a light on the way that some statistics are created and the distortive effect that ‘bad statistics’ can have on government policies. The application of scrutiny to research is an important part of the scientific process; and where state bodies are concerned, an important part of the democratic process too. It is entirely consistent to be concerned about a particular issue (e.g. risk of self-harm in a gambling context) and at the same time to believe that research into that issue should be conducted with honesty, openness and in accordance with scientific principles. In this way, we may hope to reduce the stigma associated with self-harm (such that gambling firms and other businesses gain the confidence to openly confront it); and that, over time, we may apply greater intelligence to the prevention of suicide in a gambling context and more generally. 

Unreliable Suicide Claims in Gambling: ABSG’s Questionable Stance

The Great Suicide Deception. Part III – Conspiracy of Silence

Dan Waugh, Regulus Partners. May 2024

The Great Suicide Deception. Part III – Conspiracy of Silence

This is the third in a series of articles examining claims made by state bodies in England about rates of suicide associated with ‘problem gambling’. In the first we demonstrated that estimates of suicide mortality produced, first by Public Health England (‘PHE’, 2021) and then by the Office for Health Improvement and Disparities (‘OHID’, 2023) were irretrievably flawed. In the second, we looked at the behaviour of PHE and OHID, finding indications of a priori bias or inexplicable negligence and unsound governance. In this third article, we examine the conduct of others in positions of authority and ask why so many people who knew that PHE and OHID’s claims were unreliable decided to look the other way. We also recognise those who were prepared to apply critical analysis. Once again, we observe that, while gambling disorder has been recognised as a risk factor for self-harm for more than 40 years, efforts to tackle this are unlikely to be advanced by the use of junk science.

1. Why did the Gambling Commission not ‘do the right thing’?

By April 2022, Britain’s Gambling Commission knew that estimates of suicide mortality published by PHE were “unreliable” and based on “inaccurate” assumptions. This may have been a somewhat uncomfortable finding, given that the regulator had previously described the review as “important and independent”. It had arrived at this opinion despite not having received anything more than an executive summary (which it had not read when it agreed to provide “a supportive quote”). It also knew that PHE was far from “independent”, having been made aware of its intention to apply tobacco-style controls to participation in betting and gaming.

At a meeting in March 2022, Gambling Commission officials admitted that they did not understand how PHE had arrived at some of its estimates (no-one could have been expected to – given the fact that the calculations were mathematically incorrect). In April, these officials circulated a highly critical review of the PHE report, in which they noted that the suicide claims were not based on “reliable data”. The Commission however, elected not to take the matter up with the OHID (which had subsumed PHE upon the latter’s disbandment) or to inform the Secretary of State. The market regulator – which counts “doing the right thing” among its corporate values – elected to suppress its critique. In one rather sinister coda to the Commission’s critique, one official speculated that PHE’s claim of more than 400 suicides might be rescued, if only future prevalence surveys showed a higher rate of ‘problem gambling’ in the population. At this point, the Commission had started work on a new Gambling Survey for Great Britain in the expectation that – as a result of methodological issues – would produce a higher rate of ‘problem gambling’ than reported by tNHS Health Surveys.

 

When asked by journalists whether it considered the PHE claims to be reliable, the Gambling Commission responded that it was not its role to review the work of other state agencies; but failed to mention that this is precisely what it had done. As late as 2023, its chief executive, Andrew Rhodes continued to defend the PHE-OHID estimates, despite being aware of the problems with them; and it seems likely that the market regulator has been involved in disseminating the misinformation via approval of regulatory settlement funds.

2. the ABSG and the irrelevance of accuracy

In the summer of 2022, the OHID wrote to the Gambling Commission’s Advisory Board for Safer Gambling (‘ABSG’) to ask for its opinion on criticism of PHE’s suicide analysis. In her response, the ABSG’s chair, Dr Anna van der Gaag appeared to agree that there were indeed a number of issues. She wrote: “I see their point about basing calculations on the Swedish hospital study leading to an over estimation of the numbers”. She then proceeded to suggest that accuracy in such matters was unimportant and that attempts to apply scrutiny was “a distraction from what matters to people and families harmed by gambling”. This represented a change in attitude from three months earlier when the ABSG had described PHE’s highly exact estimate of 409 suicides associated with problem gambling as a “catalyst towards action”. The Gambling Commission allowed the ABSG to publish this opinion in the full knowledge that it was based on unreliable data. 

The following year, Dr van der Gaag was one of two co-adjudicators responsible for allocating around £1m in Gambling Commission (regulatory settlement) funding for the purposes of research into suicide and gambling. Applicants were specifically directed towards the OHID analysis (i.e. estimates that the ABSG knew were flawed) as well as claims by the activist group, Gambling With Lives (despite the fact that even the OHID had indirectly criticised one of GwL’s claims). One of the successful bids (a £582,599 award to a consortium led by the University of Lincoln) included Gambling With Lives as an active member of the research team. 

3. the Silence of the ‘Independents’

Among those who have supported the claims of PHE-OHID are a number of self-styled ‘independent’ researchers. These include academics from the universities of Cambridge, Hong Kong, Lincoln, Manchester, Nottingham and Southampton, as well as King’s College, London, who have cited the estimates uncritically in their work. Perhaps they considered (naively, if so) that research produced by the Government is unimpeachable; yet the errors made by PHE-OHID are so glaring that no researcher of any calibre could have failed to notice them. The failure to subject such serious claims to critical analysis before repeating them indicates – at the very least – an absence of intellectual curiosity. Much is made of the need for research independence (typically defined solely by an absence of industry funding, regardless of ideology or other affiliations); but independence has little value if it is not accompanied by intelligence and integrity. 

4. Breaking ground

A small number of groups and individuals have been prepared to apply scrutiny and challenge, despite the circumstances. The Racing Post and the think tank Cieo have published a number of our own articles on the problems with PHE-OHID (as well as other issues with research-activism); and a handful of journalists, including Chris Snowdon, Steve Hoare and Scott Longley have been prepared to challenge the PHE-OHID claims. Figures from trade groups, bacta and the Gambling Business Group have spoken out publicly on issues with PHE-OHID.

Officials at the Department for Culture, Media and Sport have displayed a capacity for critical analysis, notable by its absence elsewhere in Whitehall. Their White Paper on reform of the betting and gaming market acknowledged valid concerns about self-harm but conspicuously omitted the OHID figures. Lord Foster of Bath, a stern critic of the gambling industry, has acknowledged that the PHE-OHID claims are not reliable and – in a show of honesty and humility rare in the gambling debate – apologised for using the figures himself. He continues to make the case for self-harm to be treated seriously in a gambling context; but without recourse to spurious statistics. Philip Davies, the Conservative Member of Parliament for Shipley, has challenged unsound statistics in parliamentary debates; and Dame Caroline Dinenage’s select committee for Culture, Media and Sport noted concerns of reliability in its report on gambling regulation. 

One member of the Gambling Commission’s senior management team – Tim Miller – has been prepared to discuss and acknowledge problems with PHE-OHID; an attitude that contrasts sharply with that of his colleagues.

5. ‘Noble lies’ and consequences?

Underlying the PHE-OHID saga is a sense that some people in positions of authority consider it acceptable to publish inaccurate or misleading statistics if the cause is – in their opinion – just. Some have even suggested that scrutiny of misinformation is unethical, rather than its manufacture. In July this year, the Gambling Commission intends to publish statistics on the prevalence of suicidality amongst gamblers. Given its role in PHE-OHID (in addition to major issues with its new survey), it is questionable why anyone should consider these results credible. It has also – via Gambling Research Exchange Ontario – sponsored a programme of research into wagering and self-harm. Given that these studies have been explicitly grounded in the PHE-OHID deception – and the complicity of many of those involved – suspicions of bias will accompany publication. It is the publication of unreliable research – rather than scrutiny of those statistics – that undermines public trust in authority. Attempts to address health harms in any domain will be ineffective if they are based on inaccurate evidence.

An independent and open review should be carried out into the PHE-OHID deception; but it is difficult to see how this will happen. The Department of Health and Social Care and the Gambling Commission are unlikely to embrace scrutiny; and the DCMS will not wish to embarrass either its regulator or another government department. There are too many people in Parliament and the media who have played a part; and too few prepared to break ranks. The gambling industry meanwhile (with a number of notable exceptions) has shown little inclination to challenge. There is one hope – that the Office for Statistics Regulation will be prepared to take an interest in the integrity of public health estimates. Such an intervention would go somewhere at least towards restoring trust in public bodies.

A Very Public Deception: On the manufacture of mortality statistics in gambling

Part II – Why did public health get things so badly wrong?

n the first in this series of articles, we examined the problems with claims made by state bodies – specifically Public Health England (‘PHE’) and the Office for Health Improvement and Disparities (‘OHID’) that up to 496 deaths by suicide each year in England are associated with ‘problem gambling’. We demonstrated that the basis for these claims is irretrievably flawed. Analysis of the Swedish dataset upon which they rely concluded that “gambling disorder did not appear to be a significant risk factor for the increase in suicide” (Karlsson, 2023). PHE and OHID researchers overlooked critical research findings and clear warnings about the advisability of their approach. While gambling disorder has long been recognised as a risk factor for self-harm, the estimates published by PHE-OHID are categorically unsound.

Read Part One: Lost in Translation?

In this second article in the series, we attempt to understand why PHE and the OHID persisted in following such a clearly problematic approach in the face of strong evidence of its unsuitability; we examine a number of issues of governance; and consider whether officials may have deliberately misled policy-makers and the public.

The Tobacco Road: why did PHE make such unsound claims?

In May 2018, at the conclusion of its review into gaming machines and social responsibility, the British Government’s Department for Culture, Media and Sport asked PHE to “conduct an evidence review of health aspects of gambling-related harm to inform action on prevention and treatment”.  More than three years later, in September 2021, PHE responded with the publication of five reports on the subject. One of these reports (‘The economic and social cost of harms’) claimed annual costs of £1.27bn a year associated with ‘problem gambling’ – with roughly 50% attributable to deaths by suicide.

It was this rather speculative document, rather than PHE’s more robust quantitative review of evidence from NHS Health Surveys, that officials chose to emphasise – prompting Britain’s Gambling Commission to surmise that PHE’s goal was, “to ensure gambling is considered as a public health issue.”

The Gambling Commission had already been given a glimpse of what “a public health issue” would entail. In a draft press release (seen by the Commission), PHE officials called for:

“a public health approach to gambling…similar to how we tackle tobacco consumption or unhealthy food consumption…”.

In the summer of 2022, the PHE researchers (now transferred to OHID) spelt out what this tobacco-style offensive would involve. Their paper, published in the Lancet Public Health, contained 81 measures for state intervention in the gambling market. The list included prohibitions on: all gambling advertising and marketing (including at racecourses); all in-play betting; and the sale of wine, beer and spirits in bingo clubs and casinos. It also included limits on the number of people permitted on a website at any one time, annual tax increases above the rate of inflation and even ‘plain packaging’ for all gambling products (no colours, logos or images permitted on playing cards, gaming machines, National Lottery tickets and so on).

There were other indications that PHE’s endeavours were not entirely objective – or morally neutral. In 2020, for example, its project leader stated that “more research is required to support advocacy and action” against gambling – hardly a statement of impartiality or scientific rigour. Meanwhile, documents made available under the Freedom of Information Act (‘FOIA’) reveal that PHE had agreed to be part of a research group set up by the activist charity, Gambling With Lives (‘GwL’) during the review period – an engagement it failed to disclose within its report.

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Why did OHID publish its report…and did officials mislead?

In January 2023, the Department of Health and Social Care (‘DHSC’) withdrew the PHE report and published an updated set of cost estimates – this time in the range of £1.05bn to £1.77bn a year (underpinned by a choice of 117 or 496 deaths). OHID described the decision to review PHE’s work as “a standard approach for previously published reports ”; but this seems to be untrue. The decision to re-examine the PHE cost estimates alone (none of the other four reports was reviewed – despite the presence of errors) was taken in July 2022 and announced to Parliament shortly afterwards. We have found no evidence that reviewing state agency reports within ten months of publication is a “standard approach” or that any such policy exists.

Disclosures made under FOIA reveal the true reason for review. On 26th July 2022, an unnamed DHSC official circulated a memorandum, stating:

“We are going to need to make changes to two of the evidence review reports as an error has been spotted, and as it’s a change to results, its [sic.] probably what you would classify as a major change.”

Given that the PHE report contained quite a few errors, it is difficult to know which particular mistake prompted re-examination; but the decision was certainly not part of a “standard approach”. This raises the possibility that OHID may have deliberately misrepresented the grounds for review.

The Gambling Commission and the Advisory Board for Safer Gambling were both told by OHID researchers that “nothing in the report has changed substantially”; but this is incorrect. In fact, every single line item in the OHID cost estimate differed from the PHE version – in some cases substantially. Its estimate of direct costs to the Government was £234.1m lower than PHE’s – a reduction of more than one-third. This was masked by the introduction of a new area of intangible costs, relating to depression and several revisions to the suicide calculation. OHID’s estimates were also based on a ‘harmed population’ 59% smaller than in PHE. As chart 1 (below) shows, the claim that ‘nothing changed substantially’ appears misleading.

In August 2022, the then Health Minister, Maggie Throup MP advised Parliament that the PHE report would be reviewed and that the calculations underpinning its estimates would be published. The review however, has never been made public and – according to disclosures made under FOIA – no such document is held by the DHSC. Contrary to the minister’s pledge, the PHE calculations have still not been released. To do so would reveal a number of errors, such as the fact that PHE’s suicide figure was based on a 21% over-statement of the population prevalence of ‘problem gambling’.

The mystery of the OHID expert panel

OHID was at least prepared to admit – with a heavy dose of understatement – that its estimates were “uncertain”. It relied on a study of hospital patients in Sweden with a clinical diagnosis of gambling disorder (among many other health issues) to estimate the health risks for people in England with no diagnosed mental or physical health conditions whatsoever. In consequence, OHID leaned heavily on the opinion of its expert panel of health economists and academics who, it is claimed, approved the approach.

There are, however two problems where this opinion is concerned. The first is that one member of the expert panel, Dr Henrietta Bowden-Jones of the NHS had publicly criticised the PHE-OHID methodology. At a fringe meeting of the Conservative Party Conference in September 2022, Dr Bowden-Jones stated: “we cannot extrapolate from Swedish studies, from Norwegian studies – it doesn’t work”.

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The second issue is that the meeting of the expert panel – to discuss the most significant matter in the OHID report – is entirely undocumented. In February 2023, the DHSC admitted that:

“there was no agenda or papers shared before the meeting or minutes circulated afterwards”.

It is difficult to understand how this panel of experts might have been expected to review OHID’s work without access to any documents; and why officials did not consider it necessary to record the panel’s deliberations on this critical point.

Why did public health get things so badly wrong?

Inappropriate behaviour?

The task attempted by PHE-OHID was always going to be challenging, given the dearth of actual data available. This does not explain or excuse the large number of errors and omissions made by researchers and officials:

  • PHE and OHID ignored warnings by Karlsson & Håkansson about the representativeness of the sample in the 2018 Swedish study (upon which they relied);
  • PHE and OHID ignored findings in the 2018 study of high rates of mental and physical health comorbidities.
  • PHE and OHID ignored the follow-up study by the Swedish researchers (Håkansson & Karlsson, 2020), which found that risk of suicide attempt was significantly mediated by the presence of other disorders.
  • PHE and OHID ignored the opinion of Dr Anna van der Gaag, chair of the Gambling Commission’s Advisory Board for Safer Gambling, that the PHE calculation was likely to be inaccurate.

A large number of issues with the PHE-OHID reports were brought to the attention of its Director-General, Jonathan Marron in July 2022 and again in September 2023. On both occasions, Mr Marron promised to investigate. Last year, he wrote that he would provide “a proper explanation” for the errors and methodological flaws; but more than seven months later, none has been forthcoming. In what may well be a breach of the Civil Service Code, OHID officials resorted to ad hominem disparagement of their critics – including one national news media outlet – rather than engage constructively.

What is particularly disturbing about the PHE-OHID scandal is not the fact that researchers (presented with an unenviable task) made so many mistakes; but that state officials proved so unwilling to confront them – responding with hostility to legitimate scrutiny.

Next week, in our third article, we will consider the behaviour of others in positions of political or moral authority who variously connived in the deception or turned a blind eye to it. We will reflect on what this means for their future involvement in research and policy-making.

Dan Waugh

May 17th 2024

Regulus Partners

A Very Public Deception: On the manufacture of mortality statistics in gamblingA study of suicides in gambling, are we being told the truth? Part 1

Public Health England was closed down because it was incompetent and was too easily distracted by lifestyle issues when it should have been focusing on public health. It was more of an in-house lobby group than a serious scientific agency. It seems that closing it down and re-opening it under a new name (OHID) with the same staff was not enough to make the leopard change its spots.

Dan Waugh- Regulus Partners

In recent years, the claim that up to 496 deaths a year in England are associated with problem gambling has become a staple of the debate on gambling market reform. The estimates originate from a 2023 report by the British Government’s Office for Health Improvement and Disparities (‘OHID’) and have been used to support demands for a wide range of additional controls on consumers and the market. There is just one problem – they are based on junk science.

While it has long been recognised that people with gambling disorder are at elevated risk of self-harm, the specific estimates produced by OHID – accepted uncritically by many in Parliament and the news media – rely on a number of ‘flat-Earth’ assumptions.

In this series of articles, we examine the methods used (and errors made) in calculating these figures and consider the conduct of those who have propagated them. In this, the first article, we demonstrate why the OHID estimates are unsound. In subsequent weeks we will describe the behaviour of the public health officials responsible for their manufacture; consider the actions of other notionally responsible bodies; and ask what public benefit is served by the generation of spurious statistics.

The first state-sponsored estimate of gambling-related suicides in Britain appeared in September 2021 with the release of Public Health England’s (‘PHE’) report, ‘Gambling-related harms evidence review: the economic and social cost of harms’. It contended that, in England, 409 suicides a year were “associated with problem gambling only”. In January 2023, the PHE report was replaced (due to identification of errors) by an update from OHID. It offered a choice of either 117 or 496 suicides “associated with problem gambling”.

Both the PHE and OHID estimates were based on a 2018 study of the medical records of patients treated in Swedish hospitals between 2006 and 2016. Dr Anna Karlsson and Professor Anders Håkansson from Lund University found that patients in the dataset with a clinical diagnosis of ICD-10 ‘pathological gambling’ (renamed gambling disorder in the ICD-11) were on average, 15.1 times more likely to die by suicide compared with the general population. PHE applied suicide mortality ratios from this study to NHS Health Survey estimates of the prevalence of PGSI ‘problem gambling’ in England to produce a figure of 409 deaths a year.

In 2023, OHID repeated the exercise, using precisely the same information, and produced figures of either 117 or 496 deaths (the lower figure based on the application of the Swedish mortality ratios to the population prevalence of DSM-IV ‘pathological gambling’). In doing so they ignored critical information and clear warnings that their methods were unsound. The hospital patients whose records were analysed in the ‘Swedish study’ suffered from a wide range of diagnosed mental and physical health conditions (see charts 1 and 2, below). As a group, they were at elevated risk of self-harm, regardless of the presence or absence of gambling disorder. PHE-OHID thought otherwise – assuming that  health risks for hospital patients in Sweden with a wide range of illnesses were the same as for people in England with no diagnosed health disorders whatsoever. In other words, they made the ‘flat-Earth’ assumption that there is no association between mental and physical ill-health and risk of suicide.

In making this assumption, PHE and OHID ignored a clear warning from Karlsson & Håkansson. Their paper advised that the hospital patients whose records they had studied were likely to suffer from particularly severe and complex disorders:

“It is therefore likely that results may be skewed toward a population of individuals with more severe forms of GD [gambling disorder]. It is likely that this once again implies that this study sample might contain patients with higher mental health comorbidity, as well as individuals with more severe forms of GD, since these individuals are more likely to receive specialized psychiatry care”.

The PHE-OHID researchers also ignored findings from the follow-up to this study (the second in a series of five undertaken by the researchers from Lund University). Håkansson & Karlsson (2020) showed that comorbid health conditions were even higher within the group of patients who had attempted or completed suicide (see chart 3).

Professor Håkansson and Dr Karlsson showed that risk of suicide attempt was five times higher for patients with gambling disorder if they also had diagnoses of alcohol use disorder and drug use disorder. Of those patients who had made a suicide attempt, 70% had a diagnosis of alcohol use disorder or drug use disorder or both. The researchers at Lund University provided a range of adjusted odds ratios based on the presence of other diagnosed mental health conditions (see table 1). This study – which was published ten months prior to the PHE report – indicated that suicide risk for patients with gambling disorder was halved where no alcohol use or drug use disorders were diagnosed. Even before adjusting for other risk factors, these findings clearly demonstrated the inappropriateness of PHE’s approach.

A third study assessed the effect of socioeconomic factors on risk of suicide attempt. In the fourth study, a control group was used to identify discrete risks associated with gambling disorder. It concluded that:

“gambling disorder did not appear to be a significant risk factor for the increase in suicide and general mortality when controlling for previously known risk factors”.

This finding creates a dilemma for OHID and those who have propagated its claims. If one believes that analysis of the Swedish National Patient register by Karlsson & Håkansson provides a reliable basis for assessing suicide risk in England, then one must conclude that – contrary to PHE-OHID assertions – gambling disorder is not “a significant risk factor”. If on the other hand, one does not believe this is a suitable approach, then the PHE-OHID claims also cannot stand because they rely entirely on the mortality ratios from the first of the Swedish studies.

The fact that PHE and OHID got things wrong does not mean that underlying concerns about gambling disorder and self-harm are misplaced – or that gambling operators, treatment providers and policy-makers should ignore the issue. It has long been recognised that people with the disorder are at elevated risk of suicide, even if the precise nature of the relationship is complex. A number of recent inquests in England have determined that excessive gambling contributed to loss of life. Operators should do more to promote positive mental health and to address risk of self-harm among their customers and employees – whether gambling is involved or not. The PHE-OHID claims are, however, irretrievably flawed and should be disregarded by policy-makers. There is simply no coherent logic that allows them to stand.

In next week’s article, we will consider why PHE-OHID produced such obviously flawed findings and examine potentially serious issues of governance attending their publication.

List of abbreviations

DSM-III: The third edition of the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Health Disorders.

DSM-IV: A screening questionnaire published by the American Psychiatric Association within the fourth edition of its Diagnostic and Statistical Manual of Mental Health Disorders

OHID: the Office for Health Improvement and Disparities. Part of the Department of Health and Social Care.

PGSI: The Problem Gambling Severity Index. A screening instrument developed by Ferris & Wynne (2001).

PHE: Public Health England. A state agency, reporting to the Department of Health and Social Care. It was disbanded in 2021.

Dan Waugh is a partner at the global strategic sports and leisure advisory firm, Regulus Partners.

Unibet’s favourite ambassador

There’s a dangerous saying in Racing. ‘How dare you question me?’ One could introduce  perhaps ‘I am beyond reproach.’

unibet2

But Nicky, you’re not beyond reproach, for a second. In fact it does appear to coin another well turned phrase, ‘he doth protesteth too much’

Whilst I personally find Nicky,  a most amiable sort, and of appreciable talent, there are two things which he has to take fully on board. One, racing fans don’t have reason to appreciate nor like the commercial stance you are adopting in relationships with Bookmakers. And second, you have to accept that the behaviour of those who work in your yard, or how information is utilised, will be the target for speculation, for as long as you maintain horses are in great order, only to withdraw them a couple of days later.

The ‘some journalists are dead meat’ comment, is unprofessional, and unjustified. Frankly it’s a dangerous precedent, from a yard that so dominates the sport. Journalists have an important role to fulfil, and it’s not to kiss people’s backsides. Fine, we all accept Racing press notoriety not for hard headed sports journalism, rather a deserved reputation for the supine. Printing the rubbish peddled by top trainers as gospel has long since reached epidemic proportion.

See this interview with Matt Chapman from ITV’s feed in which he denies there was a problem with Altior on the Saturday before the Tingle, and maintains there was ‘no issue’

https://www.google.co.uk/url?sa=t&rct=j&q=&esrc=s&source=web&cd=2&cad=rja&uact=8&ved=0ahUKEwjn1YjumaXYAhXpCsAKHX7WAJ0QFggwMAE&url=https%3A%2F%2Fwww.itv.com%2Fracing%2Farchive-clips%2Fmatt-chapman-speaks-to-nicky-henderson-about-the-altior-controversy&usg=AOvVaw1OlX8-6oTcPV6qZcU03oJu

And here is Nick’s Unibet version which maintains there WAS an issue with ALtior’s breathing the Saturday before

https://t.co/4dfZFYlzfq

 

I don’t know about you, but I’m struggling to understand which version I am to believe?

 

To deal with each point. One, the practice of association with Betting companies is an abhorrent development, something Henderson should be fully aware is deeply unpopular. Let me remind people how companies such as Ladbrokes utilise information to their advantage, gained from accounts they operate,  as in the David Evans- Rule 4 saga. Anyone that imagines these betting behemoths behave with impeccably good manners when it comes to money must be living in some form of fantasy world. None of them behave well. In fact there’s compelling daily evidence to show how low they have stooped as companies in their pursuit of accounts and money. They’re bound to use associations with top trainers to their commercial advantage, and to penalize their customers therefore. And Nicky knows this, hence his exaggerated indignation at Cheltenham.  Unibet have no reason to release your ‘information’ promptly. They are not a news service.

Punters simply think they are being cheated, whether that’s true or not, such association used to be outlawed, for very good reason. The BHA haven’t supplied any rationale for this decision, and don’t expect a docile Gambling Commission to do anything about it either.

To boot Unibet have ensured the very latest flow of information from Seven Barrows, via their association with your stable Jockey, Nico De Boinville. Couldn’t get any more insidious.

unibet1

Henderson simply shouldn’t be releasing information via any medium other than the stable’s own twitter feed, or perhaps via the racing press feed. Good news, or bad news. A Bookmaker is simply not the right vessel.

altior

As a bookmaker, we were aware of very significant monies for Fox Norton, for the Tingle Creek in the day PRIOR to the withdrawal of the mighty Altior. And we were not alone as the news was all over Twitter. Betfair exchange and other bookmakers reported the same pattern of monies. Fine, Hendo may not have personally made a final decision as to the participation, but others quite clearly had leaked their doubts to their associates, as to the participation of Altior. The fact remains, some people generously helped themselves before the information was released, and they were proven correct. Who was leaking this information, or were they all better informed than Henderson himself? You were after saying the horse was in ‘magnificent order.’

One concludes either Henderson doesn’t know the well being of his horses, he’s waiting on the strength of the opposition to show their hands, or someone else in his organisation knows his charges better than he does.

Perhaps it could be the myopic focus on the Cheltenham Festival. A subject which concerns many racing fans, excepting the regulator itself. The Tingle, Fighting Fifth and many more top races decimated. The BHA far too slow to establish minimum conditions of entry for the Festival. Something they’re told by the likes of Henderson ‘isn’t possible.’

It is. Yesterday I heard the NFL, the world’s best sporting body, totally re-jig it’s schedule next week, to put all potential playoff games on at the same time. Doubtless upsetting giant TV networks. That’s how to run sport. Act

The truth is – Altior will be another one of those top stars who turn up in March, having not experienced a real race (of his class) in the six month lead up to Cheltenham.

The pigs ended up in the betting trough, and people are fully entitled to know why, since they are investing in the sport.

Associations with big betting companies by jockeys and stables has to be ended by this BHA. There’s no sensible regulatory reason for such deals, other than to upset the very people who funded the sport to the tune of 52 million last year.

Remember, Mr Rust, the only people to benefit from those deals are the best of trainers and jockeys. The little guys rarely share in such windfalls, and if it in any way has the whiff of impropriety,-  it has to be outlawed.

unibet3

Finally, I would add that Henderson’s ‘how dare you’ approach, as a top trainer needs to be roundly condemned, in all quarters. This arrogant approach, that if you dare question anything I do, in the manner so common in other sports, is damaging to the good governance of racing. nobody should be above fair interview. Tell me why Nicky Henderson thinks he only deserves good press?

It wasn’t so long ago Nicky, that you were handed the softest ban in living memory for doctoring records, to conceal guilt, and administering banned substances to your horse. I don’t doubt the shame of reporting in those days leaves a hurtful stain in your memory, but you have to accept that those journalists, then and now, are simply, and fairly, doing their job. You broke the rules, knowingly, and with appropriate disregard for the rules. It’s more than a bit rich to claim the moral high ground over your associations with betting companies, especially if you don’t bet with Unibet. I expect most people get their racing news from the Racing Post, or the Guardian. Aren’t these more appropriate mediums?

So Nicky, accept the brickbats as they come, because you most definitely benefit from a veritable avalanche of good press when your horses do well.

I suppose I’m dead..

 

 

 

 

Champions Day – The Bookies view..

 

 

champ

A few years ago the Emperor of Jockey Club surveyed his tracks in response to a grand plan from British Racing for a season’s end panto. Cheltenham seemed too bumpy and that of grotesque tweed, ohh no. Newmarket can’t stand kids, hard to find, even with Google maps. Kempton is quite simply a nasty little shack, full of dead flies. He decided he’d make more cash if they went along with the plan to create a season ending bash, at which the finest Port and cheese would, of course, be served. Ascot had been busy building a structure so vast in stature, it created it’s own weather pattern. If you’re going to have a jolly event, it’s important you have a Swinley Bottom. Or Bottoms.

Let’s get the humble pie bit out of the way-I prattled on, along with a few other lesser mortals, that the timing needed revision. The fact remains the whole shebang was saved by the very participation of one horse. Frankel. Had he not bothered turning up in 2012 i believe, the BHA think tank would have been meeting to reconsider upsetting the our froggie friends by moving it back a month. I still believe that’s the best option if we are to secure participation of faster ground animals, but I was outvoted by people wearing waist coats and deerstalkers.

image_update_4e775acb75c2601f_1353588126_9j-4aaqsk

Anyway, they threatened Teddy Grimthorpe with violence, and Frankel duly turned up. The party was saved along with a few jobs at Great British Racing. Ascot was the right venue. It has the infrastructure, class and grandeur to organise an end of season bash and serves drinks in a real glass. It’s been blessed with much better weather over the last few years, and with that the arrival of some of the top equine stars to entertain us. We can all be a toff for the day at Ascot..

Even the French send over the odd runner. Foreign equine stars are my absolute pension. Ridden by Thierry’s and Moet’s. All who think they can turn in to the Ascot straight, 6 lengths back, and possibly win. Mais Non, Espece de Cretin..

I quaffed a few glasses and joined the great unwashed in the betting ring. and the big bets were flying about on Order Of St George and a number of notably lumpy wagers set the tone. It was down and dirty and they didn’t seem to care if I lost.. David Power gave me some fun money for O’Brien’s star. He’s no shrinking violet when it comes to betting. My eyes were stinging, not the kind of bet you get with the Supermarket operators.. St George wasn’t however the only one they came for, Stradivarius was popular and a few saddos backed the French runner.. I should have discovered betting in running..St George touched 33/1 with the Bot traders.

Whilst Harry’s thingy was popular in the sprint, one other horse swamped my book. A fellah I recognised as a warm order, stuffed a chunkin my hand and said ‘put that on horse 5.’  I checked the board. Tasleet – 14/1. ‘Don’t you mean Harry’s?’. No, I’m sure, Tasleet.

I threw the money into the bag as if i stood such bets every day of the week. I gave David Power an interest for being such a nice fellah. He didn’t bat an eyelid. I got on with standing the favourite for a threatening lump. The race looked all over at the two marker with Harry’s sauntering along, – to suddenly be pressed by this Hamdam thing..my big chance lay in the whip, Hamdam doesn’t take to the whip for his stars, two cracks and out, the order of the day. Fortunately. I survived the race this time, back in front.

gosden

I spot Lord Gosden in the walkway, surrounded by 20 or so press folk. ‘Tell us what you had for breakfast John, for the fans you understand..’
‘well I’m rather partial to kippers’ JG replied, in his most aristocratic tone, and they all looked excited. scribbling away. The Gosden accent bothers me. I know John’s public school, and they don’t talk like that. He’s done a study course in phwah phwah and taken the Missus along, so they can converse appropriately.

What he can do, is train. If they stuck a Galileo in his yard covering everything we’d be celebrating 25 English group ones (or you English would) He also strikes me as rather a decent sort, batting for a bit of fair play.

Chapman was also in the ring. Wearing some kind of welly boots, and blanking me for dissing the Opening Show. Even though he was caught on camera dozing off by all 32 viewers. ITV is a paradox, their Opening Show is quite dismal, their afternoon show is, I have to say it, great. I think what they do so much better than Channel 4 is deliver it with style, if not with the Channel 4 quality of production, but that’s quibbling. Everyone looks smart, and everything is great. If you bought the ‘it’s great’ on Sporting Index, you’d be worth one Oppenheinmer…

itv

But Champions Day is great. And so equally have so many of this season’s flat events. In said regard, ITV is totally appropriate. There are those that say I’m hopelessly in love with Francesca Cumani, but that’s a total exageration..

Nice mix on ITV with the intelligent Weaver and Brough Scott brought back from the dead (literally) Cumani’s accuracy with horse action and Chamberlin’s style. Nice, it works for me. Chapman eternally entertaining, he makes me laugh and offers balance, but don’t tell him that, his ego is insufferable. Somewhere in the mix I hope they find jobs for Luck and Cunningham. If you’re committed to the best, then have the best in some capacity.

Viewing figures suggested a half a million, far short of the BBC ideal we were supposed to be treated to. Here you have to blame racing for its failures. Simply far too many opportunities for horses like Enable, Ulyssees and Cracksman to square off. You think it doesn’t matter? Of course it does. Far too often television companies showcasing this sport are presented with half the available participants for a top race. Too many group ones, too many countries failing to co-operate and not enough stars. Cracksman hasn’t raced since York, swerved the Arc and the Breeders and its a miracle if he trains on as a 4 year old it’s a miracle as right now he’s worth as much as his Dad. The National Hunt is in terminal decline because we ignore this cancer. A sport that denies the paying public the best squaring off can’t hope for top viewing audiences when the other channel is showing Manchester United vs Liverpool.

Cracksman strolls onto the field for the main event, balls gently swaying in the wind. Let’s deal with any blithering idiots reading this. If you think Enable would have downed this machine with her far more workmanlike Arc performance, you’ve taken total leave of your senses. He destroyed a top class field, as indeed he did in the Dante. This is the best I’ve seen since his Papa. He would have danced all over the filly. FACT.

I’m sure we can look forward to Enable and Cracksman squaring off as four year olds. Not.

I stood Cracksman for an appropriate amount, – and lost an appropriate amount. Ryan Moore, who’d been brilliant all day, when not under a microphone, drove Highland Reel up Sunninghill High Street. In truth his chances on rain softened ground were limited. The French nags were, predictably, hopeless, and Barney Roy, popular in the ring was held up at the back, and stayed at the back. Two Enables wouldn’t have beaten Cracksman.

cracksman

I deposited some more money with the punters in the last as the favourite came from another planet to upset the day. I enjoyed some of the Ascot atmosphere with friends before leaving, observing thousands having a great time watching a couple of nice bands. No trouble, well stewarded, a lot of very smart folk enjoying a well rounded event. And yes, Newmarket, children actually do go free. Were I to offer one suggestion to Ascot, it’s to install some kind of sub air system to Swinley Bottom, the one area that jeopardizes meetings and diverts runners.

It’s a success. I don’t say that about the National Hunt, expect a few broadsides, but its been an excellent flat season and I believe we are heading in the right direction there. Ascot knows its job and British Racing got this one right.

Pass the sherry someone? Will they make me a steward now??

gb33

 

 

 

 

National Hunt – a code in crisis

Racing fans comprise four sets of folk. The outraged form 49% (A). This group won’t hear speak or listen to any criticism of the sport, they either work for a racetrack, punt favourites over the jumps, or sit indoors with the curtains shut.. The disaffected, numbering 50% (B), a group whose numbers rise annually and constitute the biggest moaners in Racing. Escapees from the Betfair forum, sitting in their underpants at home whining about getting on. The third group go Racing, but only view it from corporate boxes, don’t drink beer, miss all the fights and haven’t a clue what’s really going on outside the box. (Group Q) Excuse merchants, apologists and evangelists form another strange sect (Group E). Then we have a small section of disaffected journos and pundits who’d better shut up or else (X)

The final 1% work for the BHA (Z). The persecuted ones. They would join St Peter being crucified upside down.

crucify

The executive are selected by the racetracks on rolling three year contracts. The current Chairman knew less about Racing than my cat when he arrived, presided over some notable fails like Mathew Lohn, then quietly and ‘humbly’ voted into another 3 year term..

Now tell me – why would you vote to Chairman someone who knew so little about the sport? Why did he then go about the removal of a more experienced board in favour of amateurs with equal skill level? Why are commitees informed a reduction in the programme is ‘off the table?’

Is the regulator looking after the interests of racing, or is the system of election of the Chairman dependent on what he does for  racetracks? Chairman of the BHA isn’t akin to golf club captaincy.

harman

Look, I know you all think I hate the BHA (Group Z). Come come now, I’m not that bad really, honestly. I’ve made clowns of them once, but I’d like to think their decisions were based on regulating and promoting the sport, not battling bookmakers for cash. Truth is the BHA  (Z) hierachy is never going to act for Racing for as long as the tracks sit on the board and appoint the leaders.

Turkeys rarely buy Xmas cards. More galloping about the ovals keeps the track bosses in tweed and BHA execs in badges. Kempton makes more money than any other JCR track (Group A) – except Cheltenham. Pop there on a Wednesday night and you’d swear the gates had been locked shut. It subsists on an attractive Levy payment for every race. Three runners or fifteen, its all gravy.

The swing to sandpits, to include the gothically dull Newcastle straight (A), needs runners from the available horse population, and owners. If you’re a prospective jump owner, up against wannabee’s like Rich Ricci (Q and E), forking out hundreds of thousands a horse, – you can afford 65 pence a purchase. Ricci stables his muckers the Mullins pad, coffee machine, babestation and minibar in every box. Regular owners on limited budgets can’t compete nor cover the exxes. And your trusty milker can only hack around 5 or 6 times a year. On the all weather, chances are you’ll do better. Even if you’re the only one interested if it wins..

549178-drunk-aussie-racegoers-steal-uk-headlines

It is a matter of pure fact belting out sand races at the rate of 3 meetings a day harms the winter code. Is there any chance a whole summer of jumps nobody cares about is a pointless exercise, for everyone except Plumpton? Or have i taken leave of my Scottish mind?

Jump Racing sacrificed on the altar of an engorged BHA all weather list . Months of 4 and 5 runner events. It’s not on, and time you fans stood up and demanded change.

This year, and with apologies the excuse merchants (E), the fields in jump racing have never been so poor. 3 and 4 runner events abound. When they’re strung out for 465 yards, this is what sporting people (B) call ‘uncompetitive’or ‘dull’- unless that is you like Formula one

racing

The ground isn’t firm. It’s good racing ground, so stop telling me a its akin to a bed of nails to a horse. Indeed they’ve been running all summer. And when the ground is good in April at Aintree – they’ll be running, this is what explodes the myth about ground..There’s simply too much racing and too few runners to support the code and it cannot roll on for 3 or 4 months in this vein every year, whilst we all sip champagne in our box, waiting on Cue Card. A couple of weeks ago we had 19 runner fields at Doncaster on the flat. 7/1 the field and 1/4 the odds if you’re a betting man. Competitive, and attracts people to watch on telly. Yesterday I watched Lydia Hislop (X) trying to make Wincanton sound interesting. She should have been awarded a DSO..

stiers

So Mr Harman and Mr Rust (Q E and Z) I know the issue of racing volume gets dull, but that’s because you refuse to accept it’s a failed system..  I fully accept your jobs depend on the goodwill of masters more interested in Levy than bums on seats. I’m staring at a Kempton card with 3 three runner races and a Carlisle card with a 2 runner heat. It’s your turn in the chair and you’ve got two years left to save a code so many love before you’re replaced by the fellahs who run Southern Rail (Q).

This is a sport very much in crisis, and you are tasked to act in the interests of the sport as a whole, even if the Trustees are more interested in levy grants. Do better than serve out your time and a 0.1 runner increase per race per year. We’ll all be pushing up daisies by the time you start delivering.

 

Or am I being too diplomatic??

ascot

ps. If you want to earn money from Betting, try enforcing a minimum margin on operators in return for hefty levy rate reductions. Not a tip you’ll get from the current crop of non execs..

Banks.(X)

Response to SP regulatory commission

Response to SP regulatory system – consultation

Former NJPC chief exec Clive Reams,  recently penned a letter in response to the criticism levelled at the SPRC, after the Grand National, advocating ‘no change’ to the SP system.  When the current mechanism was devised in the 1990’s he argued vehemently against the then proposed system whereby 5 bookmakers could govern the SP returns – as ‘a bookies benefit.’

Of course he was at the time in violent disagreement with a system being proposed where the largest five firms produced the SP’s. And of course he would have been right. To permit those same firms to control the returns, when their off course empires were of such high worth in comparison to a veritable ‘cottage industry’ – would clearly disfavour punters. Any notion of those same organisations using their on course positions to actually bet competitively – and disfavour their huge shop and mobile empires, would have been nonsensical.

Yet now, we see that same official arguing in favour of the current mechanism. Despite the fact that same system has been modified several times, to permit now as low as three trading on course bookmakers, not only to provide an SP, but importantly the shows, otherwise known as board prices

Mr Reams hasn’t been seen in the betting rings for many years to the best of my knowledge.

It’s my conviction the SP mechanism – in its current form, was practicably out of date shortly after its inception and requires thorough modernisation. Not abolishment.

The commission, in its call for responses to the system, makes clear it supports little to no change to the system. That we are afforded a workable and simple mechanism, which provides for such as guaranteed odds against SP. Why the commission feels ‘board’ prices would disappear in any revisions is beyond my understanding. Perhaps to scare people into the false belief that show odds would be consigned to the bin.

We already utilise industry odds in some meetings – Meydan and Longchamp for example. There’s no argument to support the commission’s assertion a system based on track bookie’s odds- is the only one which would support guaranteed odds

It’s rather apparent the SPRC depends upon the advice and views as reported by the press association staff, tasked with returning a fair SP from the racetracks. They are neither witness nor party to discussions between bookmakers – and their customers. Their honesty is not in question here- but they clearly cannot have the ground level experience to report accurately what is really transpiring.

The commission will also consult with the FRB, namely Robin Grossmith for his advice. Whilst Robin is a respected colleague of many years’ experience, it should be remembered that an important part of his remit is to secure payments for on course bookmaker’s data. He would naturally argue the system as working in a satisfactory manner – and without any knowledge or understanding of how the mechanism, currently being employed, affects off track companies. Most track firms care little for the impact their activities have on the wider betting community

The dynamics of betting have fundamentally changed in the last 20 years, whence the current system was put in place. In that time changes have been few and limited in nature. 20 years ago a pitch at Sandown at the top of the rail would have been worth well in excess of £100,000 – and very hard to come by. These days – those same pitches can be purchased for less than a third of that value- and with minimal interest, most certainly not from someone trying to get into racecourse bookmaking as a career! In the same 20 years- the average turnover per race to on track firms would have declined to not less than 1/6th the value of the late 1990’s. Midweek racing has declined in interest to customers to attend. Rings are often ghost towns. Few punters turn up, and in a cashless society they have less to spend with bookies trading. Mobile betting apps have taken over – being more aggressive in nature, easy to use, from funded accounts and related to offers. Racetracks have taken over betting at some tracks –and this new competition to the business a track bookmaker is afforded will have significant impact on their very existence.

My average midweek turnover, as a leading layer, in strong betting positions, is now routinely less than £500 a race- if I bet in any way sensibly. A risible figure. For this reason I rarely attend midweek fixtures. Nor do many of my colleagues. The only way to buck such turnover figures is to exceed exchange odds, then to risk arbing from other bookmakers. If a bookmaker does not offer a pure exchange price on a ‘fancied’ runner- it’s difficult to field any appreciable money for it

Bookmaker numbers have been shored up by some firms operating multiple positions. One bookmaker (John White) operates three positions at Kempton – a small ring as you are aware. Kempton – for example, routinely operates with a sample of around six firms – they are providing prices for a huge off course industry, from a venue where few punters turn up to bet

At the same time as this decline has been evidenced- the off track firms have increased in size, technology advances, and power. Where once betting rings were vibrant and busy, with standard place terms, minimum lay to lose guarantees – and by extension a useful ‘guide’ to SP’s – now they are ripe only to cheap manipulation of their odds. Huge multi national betting concerns can control a weak market with veritable pennies. This imbalance would simply be outlawed in any other financial sphere. It is important for the SP commission to give this point full consideration.

 

VOLUME OF RACING

Since 1995, and importantly in the era of Peter Saville at the BHB in 2005, the volume of actual meetings has soared from around 1000 annually – to 1450 currently. Racetracks have also focussed their business more towards Saturdays and providing cheap funded product. This has had a thoroughly negative effect to the turnover on track and split the punters interest between meetings. Further a customer can now sit at home and watch either ATR or RUK on his satellite – even watch live streaming racing on the likes of Bet365. All have had an entirely negative effect to bookmakers on track. In the same period the expenses of running an on course business have soared. Many bookmakers have quietly retired from the ring

RACECOURSE DATA TECHNOLOGY

In the last 20 years or so most firms now utilise software provided for them by RDT. The build of their system and its layout is specifically designed to facilitate easy wagers to and from exchanges. A wager can be practicably negotiated faster than on a web browser, a whole set of prices backed, or an entire position closed out. RDT receive a commission from Betdaq for such activities. Such software did not exist in said advanced form when the SPRC devised the mechanism in the 1990’s. All bookmaker software on track is designed to facilitate wagers with exchanges. It has caused a sea change in how bookmakers engage in business on track. They differ from their off track colleagues in that instead of being viewed as traditional ‘layers’ – balancing books with real money, they have metamorphosed to ‘traders’

TRADING

What should also be considered is the wholesale change in the approach by on course bookmakers to betting. When the mechanism was put in play, the majority of firms were traditional in nature. That is to say they were in the business of framing a book and accepting risk. This has fundamentally changed. The vast majority now ‘trade’ many wagers away with exchanges to create margin and keep risk levels low. In order to engage sufficient liquidity to make this practice work – prices must virtually mirror those available on exchanges. For example – a firm will typically offer 4/1 a horse for any variance on an exchange from 4.9 to 5.4. If the operator is lucky, he will be able to trade at 4/1 and hedge at 5.4 – bookmakers have become the new ‘arbers’

There’s little discernible difference between ‘show’ odds and exchange odds for the more fancied runners

Off track firms are, by extension, accepting wagers – and risk, on shows therefore based almost purely on exchange odds. This is a far from healthy system – and a central plank for lower levy returns – down over 50% in recent times. Most bets are accepted at board odds- rather than the more ‘protected’ SP returns. Off track firms do not ‘trade’ wagers in the manner in which on course firms do. To boot, since the shows being returned are up to one minute behind changes in exchange odds, off track firms find themselves subject to arbing from punters. This business is unprofitable and most bookmakers close accounts from those engaged in this practice. Such moves are unpopular and leave firms open to unjustified criticism.

THE STARTING PRICE

Let us consider the actual SP – in practice most track firms have stopped trading aggressively, or at all – it’s often too risky to bet to exchange odds and risk a sizeable wager which a bookmaker cannot trade, with the exchange, in the limited time before the off. Prices are revised downwards throughout the ring – or unavailable. Most books are structured and the operator is loathe to change it. Large operators, such as William Hill on course, are naturally particularly mindful to ‘bet well’ with one eye understandably on their important off course entity.  In my experience their returns are given considerable weight in any return. SP’s are, in practice, more favourable to the industry for these simple reasons.

There’s habitually a considerable difference between exchange SP’s and Bookmaker Sp’s

PRICE REVISIONS

It is common in circumstances to hear criticism of course bookmakers for failing to balance books by pricing up horses which they have not significantly laid, at times when they take substantial monies from legitimate hedging activity happening fast and late throughout the ring. Through the year we will hear many examples- the Grand National being a notable one, of an overround which disfavours punters betting at SP.

This is fairly easy to explain- since most track bookmakers are less ‘layers’ than  ‘traders’ . When they do catch late funds for a selection, they are far more about dealing with trading the wager profitably on exchanges. In the 1990’s – most firms would have been trying to balance their books by raising the prices of other runners to compensate, if you will. This is no longer necessary with the advent of betting exchanges and software dedicated to trading

Further, the notion that bookmakers should counter raise odds when there are often no punters to offer those odds to, is fanciful.

Finally, large entities sending money back to the tracks place their wagers as late as practicable, certainly never 20 minutes before the race for example. Again such practices, as in the likes of FOREX, would be viewed as questionable. Is racing somehow different? I am not suggesting they are not fully entitled to boss the SP’s, but there are issues of scale and timing.

 

SAMPLE SYSTEM

The current mechanism employs a bank of up to 25 firms at the largest meetings. At the lesser meetings it is exceptionally difficult to find 25 firms, betting within the commission’s guidelines, to return an SP. The SPRC has revised the number of bookmakers required to return an SP to below the level which caused such upset between the NJPC and the commission in the 1990’s, when 66 questions were tabled on the subject The commission has also modified what it permits to return a show to below the accepted industry standard terms and without requirement for a minimum ‘lay to lose’ figure.

At York’s Dante meet recently, I was one of only six firms in the whole ring, to offer an industry standard ¼ the odds a place in two 16-21 runner handicaps on one day, whilst the rest of the ring were legitimately offering a 1/5th. A bookmaker betting to a fifth in said instance could offer 25/1 a horse – whereas I would only be able to offer as low as 16/1. How does the commission handle such anomalies? Or where the favourite is odds on and all but a couple of firms are betting win only? Once again the sample is nowhere near that required for a fair SP, nor takes into account it is supposed to mirror standard terms off track to be seen as accurate – that is if there were appreciable monies to bet to. There are many examples of such cracks in the system throughout the year, which would not be evidenced if we had a system properly balanced by the true weight of money wagered on a race

We are of course well aware that the Grand National return in no way accurately reflected a fair return. Whilst I would argue that 1.66% per runner is by no means excessive- the truth remains the show embarrassed bookmakers on course, and will lead to customers choosing not to wager at the racetrack at all. Many firms were offering 9/1 the favourite – which was returned at 6/1- at the same time the exchange was offering 14.5 on Shutthefrontdoor.

The simple fact is the use of ‘SP Samples’ as a methodology for returning prices (especially where 5 of the 25 firms in the show represent major off track business) is clearly far too easy, and inexpensive, to control. In practice it’s fairly evident who the firms are that are part of the sample

Bookmakers not included in the sample are routinely ignored. Bookmakers within the sample are often asked to accept wagers at less than the odds they are currently displaying. Particularly at small meetings. Is there clear and incontrovertible evidence that this goes on? No. It is however, quite routine to be asked to ‘co-operate’ on shows in return for the crumbs off of a large concern’s table. If you co-operate – you benefit.

IS this system of hedging fair? Not if a wager is proffered ‘with hooks’. Any discussions with other firms will confirm this is precisely what goes on. It is totally acceptable for a large concern to wager to control a price which reflects the full weight of money. But not where said concerns can control a the market for such a tiny outlay and by openly requesting the bookmaker to cut his odds in return for a nominal wager.

WEIGHT OF MONEY

What should concern the SPRC, is the effect on a fair mechanism of such large concerns wagering with such a tiny entity as three to eight bookmakers trading an all weather track for example. What also should engage thinking, is the possibility of manipulation of weaker exchanges on small markets. Especially when one considers RDT controls well in excess of 90% of on course firms and produces software designed specifically to encourage the practice of trading. In reality, it is Betdaq- the weaker exchange of two, who govern on course returns. In my view this could be viewed as a cartel. It takes a tiny movement of exchange money – typically less than £10, to be followed by several on course layers.

kempton

INDUSTRY PRICES

Why have off track concerns not called for control of their own SP’s to date? Two factors explain this anomaly

First, and rather obviously, where the SP itself is required to be revised downwards, it can be easily controlled in a market devoid of regular punters with a very small ‘hedging’ fund. Large concerns represented on course can constitute up to 50% of those available to govern an SP. Especially as the SPRC mandates that in the strongest rings at our festivals, only up to 25 firms are required to return the show. Hedging can therefore be restricted to just those firms. This is precisely what occurred at Aintree. Indeed one pivotal operator, running multiple pitches, informed me ‘where he was in the sample, he was 6/1, – where he was outside the sample – 9/1 about the favourite’.

If all operators are betting to the same commercial terms – there’s really no need to limit the number who return an SP, and it’s clearly a system which fails the means test in such areas.

Second – what concerns major operators off track, when one considers the issue of industry odds, is how their competitors would behave were the mechanism revised. Would, for example, an aggressive operator such as Paddy Power- buck the general acceptance of a new industry return by producing its own ‘enhanced’ SP. As things stand currently – everyone accepts the status quo, warts and all. Of course most firms would prefer an accurate industry SP, not based on exchange odds on course, but the elephant in the room remains their competitors

With the disappearance of John McCririck from television schemes – a major obstacle to industry odds has been removed

OVERVIEW

Centrally the landscape of betting is unrecognisable – were we to compare it with 1995.

The SP regulatory commission is recommending we keep a system where the ‘show’ odds for fancied horses directly mirror exchanges and where the SP is ‘protected’ by circumstances. Where small time traders – desperate for any bettors can be easily bullied by larger operators and where punters feel they are being cheated (unfairly) by track firms.

We are long overdue constructive change. I welcome this consultation

Proposals.

  1. On Course bookmakers to compile one fifth part of a new mechanism, only where there are an absolute minimum of 25 separate entities available to return an SP
  2. Those 25 firms must be betting to recognised tattersalls standards in every race they are engaged to return the SP. Modified terms can not be accepted
  3. At least 25 firms must be available offering a full each way service to return an SP
  4. Sample system to be totally abolished on course. All firms betting to standard tattersalls terms to be included in the returns
  5. Track bookmakers who wish to include their data in any new return, must undertake to lay any advertised price to a minimum of £100 – to include to other operators.
  6. Four fifths of the new mechanism to involve the 19 largest operators. These operators to include Betfair and racetrack bet
  7. Betfair’s SP can only be taken from their each way market
  8. Industry odds governed by weight of money and by provision of prices to SIS
  9. SPRC to consult with operators to produce a formula which most accurately reflects an operators liquidity – and therefore influence on the SP

Geoff Banks

10 June 2015

The BHA – Acting in the best interests of Racing or Stakeholders?

It’s become routine these days to hear and read informed commentators, pundits, industry experts discussing the issue of small fields in racing, indeed last year the BHA undertook an expensive consultation into fixture levels in an attempt to combat the issue of small fields and lack of competitiveness in racing.

The result? More fixtures in 2015

BHA announces races attracting small fields will be deleted from the programme

The result? No races removed, a three month trial period suddenly introduced, and one deleted race restored in the face of opposition from horsemen

9 new board members with little, or no experience running racing, at the BHA. Two of these new directors have been appointed to ‘bed in’ six of the others. Tell me you’re joking, or have the stakeholders grabbed two important ‘blockers’ on the board?

The BHA announces the scrapping of small field events to address the appeal of the sport.

The result? The BHA backs down in the face of opposition from the trainers involved in the race and the NTF. It goes further in placing an NTF official to the BHA Board. I’m sure he’ll be supportive of an initiative which followed an expensive consultation.

What’s the value in an authority that doesn’t govern the sport with its best face in mind? Someone tell me.

After the removal of the best politician we’ve ever had in charge, Paul Bittar, from the equation we’re left with an entiely new board, in every sense of the word. Opposing these new directors – the stakeholders. Betting, Owners, trainers and racetracks and their interests. And they’re clearly out for what’s best for them, even if the sport cannot progress

Do you care? Or would you classify yourself as one of the silent apathetic ones- to criticise the sport is wrong, it’s just not done. To my mind, constructive criticism is a requirement and you should get involved and stop taking the guided tour

BITTAR

Quite what the Australian did wrong or whether he had just had enough is unclear. Nobody is asking the question. I didn’t always see eye to eye with Bittar during his tenure, I’m always going to take issue with the pace of change, but it’s clear he shared many of the same concerns. Particularly in regards to ‘stakeholders’ and their negative impact on the sport, and integrity issues relating to low funded racing we seem determined to produce more thereof.  He was capable of pulling the disparate parties together given time. Continue reading “The BHA – Acting in the best interests of Racing or Stakeholders?”