Wednesday, 24 April 2019

Transport for London spends £1000s making its own ads compliant with the 'junk food' ban

Last month Farmdrop, a woke farmer's market on wheels, had an advert rejecting by Transport for London because it included butter, bacon and other 'junk food'.

If you thought this was the most absurd manifestation of the inherent puritanism of Sadiq Khan's policy, you were wrong. A few weeks ago, I sent TfL a Freedom of Information request, asking them to provide details and costs of any work undertaken to make their own adverts compliant with the new rules.

TfL's adverts only promote public transport but they still have to comply. The documents I received are remarkable. To cut a long story short, they spent more than £16,000 doctoring perfectly inoffensive advertisements to remove any trace of 'unhealthy food'. You can't put a price on totally ineffective anti-obesity policies!

Read the full story at Spectator Health.



PS. Meanwhile, Food Active - a pressure group funded by local authorities - has just launched a campaign to give local authorities the power to introduce the same daft rules elsewhere.

Tuesday, 23 April 2019

Worms addicted to mango flavoured poison (plus nicotiiiiiiiiiine)


Whenever you think the USA's anti-vaping fanatics have reached their limits, they find new depths to plumb. This, from the ironically named and state-funded "Truth Initiative", is something else.

I am lost for words. Just watch the video.





Thursday, 18 April 2019

Campaigners push for the most extreme version of bottle deposit scheme

It seems that the campaign for a bottle deposit scheme has already reached the reductio ad tobacco stage...

Supermarkets have been warned they will be demonised alongside tobacco and oil firms if they fail to back a deposit and return scheme for plastic drinks bottles and cans.

The Marine Conservation Society, backed by Dragons' Den star Deborah Meaden, says only a fully comprehensive scheme covering all sizes of plastic drinks bottle, as well as cans and glass bottles, will tackle waste, litter and pollution.

The question here is whether a deposit scheme should include smaller cans and bottles (up to 500ml) which tend to be binned when people are out and about or whether it should include larger containers which are generally collected and recycled via kerbside collection.

There's a lot to unpick...

Firstly, it seems that it is not enough for these campaigners to lobby for the most extreme form of an inefficient system. Everybody else must do so too - or else. Put aside your misgivings and say something don't believe or you will be cancelled.

Secondly, I can't see the public demonising supermarkets just because they don't think large bottles should be in a deposit scheme. On the contrary, if Deborah Meaden gets her way and we have to start carting empty 3-litre bottles to collection points along with the smaller 'on the go' bottles that were the original target of this campaign, people might wish the government had listened to their concerns.

Thirdly, what has this got to do with the Marine Conservation Society? Michael Gove has promoted a bottle deposit scheme as a way to tackle plastic pollution in the oceans, but it is unlikely to have any measurable impact on it. As I mentioned in my IEA briefing paper, ten rivers transport 88-95 per cent of all the plastic found in the oceans. Eight of them are in Asia. The other two are in Africa. DEFRA barely mentions ocean pollution in its impact assessment. It is a red herring.

Fourthly, I'm not sure why the campaigners are focusing on supermarkets. Various industries have concerns about the scheme while others, like Coca-Cola, support it. As far as I can tell, the main concern of supermarkets is that reverse-vending machines will take up valuable space in their stores. That is a reason for them to oppose a bottle return system. It is not much of a reason for them to oppose a deposit scheme that excludes certain sizes of container. In for a penny, in for a pound.

The people who are most concerned about expanding the scheme to include large bottles are small retailers who will be required by law to set up manual collection points in their shops. The likes of Deborah Meaden don't mention them, presumably because it would be bad optics for a multi-millionaire to be threatening small shopkeepers. The government has also ignored them, but it is worth reading what the Association of Convenience Stores have said to get an idea of the range of unintended consequences that they will have to deal with.

“You’ve got someone wanting £5 on a Paypoint, 20 king-size, a bottle of Buckfast, and, oh, ‘here’s a bag of empty milk bottles’. You have to sort them, scan them. You could not do it. It’s ludicrous. There’s three of four people standing in a queue, they’ll walk away. Speed of service is key thing and you would lose your customers.”

“We are fighting for every space inch of space. If someone comes in with a black bag of plastic bottles, where are you going to keep this stuff?”

“I don’t have room in any of my stores. It’s filled with stock or cardboard to go back. There isn’t the room.”

The ACS has serious concerns about time, space and hygiene which the government has not addressed. Many shops simply do not have the room to store a load of dirty cans and bottles which will be buzzing with flies in the summer. This problem will be even worse if the government forces them to take back large wine bottles and two litre bottles of pop - which, to repeat, are already being collected at the kerbside.

Consumers will have to do much the same thing. They will also have to transport the containers to the queue for a reverse-vending machine or manual collection point. They - you - are the other stakeholder that is being overlooked. You only need to picture your own household to see the futility of including large bottles in the scheme. How many times have you bought a three litre bottle of something and deposited it in a street bin? How many times have you thrown such a bottle down in a street or park?

Probably not many. These containers are overwhelmingly used in the home and are recovered (and recycled) via kerbside collection. There is virtually nothing to be gained from making you store these bottles at home, piling them into the car and taking them to a collection point. The only benefit will be to the companies that make the machines because they'll be able to flog the government more complicated, and thus more expensive, equipment.

The Daily Mail article quoted above continues with a typically misleading statistic:

Currently, only around four in ten of the estimated 35million plastic bottles and 20million aluminium cans used across the UK every day are collected and recycled. The rest are either buried in landfill, burned for energy or end up as litter.

By contrast, recycling rates of more than nine in ten are achieved in other European countries with full deposit return schemes, such as Norway and Germany.

The 'four in ten' figure is simply wrong, but even if it were correct it would be wrong to compare it to the figures from Norway and Germany because the first figure relates to all plastic bottles while the second relates to single-issue plastic drinks bottles. As I said in my briefing...

The charity RECOUP says that 59 per cent of plastic bottles are recovered from households, and the recycling company SUEZ quotes a figure of 57 per cent. Both these figures include containers such as shampoo and milk bottles which would not be affected by a DRS and should not be compared with the figures shown above which are for beverage containers only.

This can cause confusion, such as when the BBC reports that ‘In Norway, 95% of all plastic bottles are now recycled, compared with England at the moment where the rate is 57%’, or when the Guardian claims that ‘Recycling rates for plastic bottles stand at 57%, compared with more than 90% in countries that operate deposit return schemes’.

These are apples and oranges comparisons. The recycling rate for plastic drink bottles is 74 per cent in the UK and 95 per cent in Norway - and Norway is exceptional. Parts of the USA, Canada and Australia, which have had a DRS in place for many years, have recovery rates that are similar to - or lower than - the UK.

The idea that a deposit scheme will increase recycling rates from 40 per cent to 90 per cent is for the birds. It is only going to affect drinks containers and DEFRA's own impact assessment expects an increase from the current 72 per cent to around 85 per cent. That is all well and good. The question is whether that relatively small change is worth spending £800 million a year and forcing the public to carry out £1.7 billion worth of unpaid labour for.

I don't see how it can be, and DEFRA's impact assessment resorts to some very dodgy economics to make it appear even marginally cost-effective. But the case for including large containers is blindingly, crashingly, patently non-existent. It's a shame we don't have figures showing the percentage of large bottles that is currently being recycled, but I bet it is an overwhelming majority. Including them in a deposit scheme would place a quite unnecessary burden on shoppers and shopkeepers alike.

But this is what happens with public consultations. When the government puts forward a range of options, single issue fanatics focus on the most extreme scenario and accuse the government of a 'U-turn' and 'buckling to lobbying' if it chooses to do anything less.

Monday, 15 April 2019

A load of old rubbish

I want to talk to you about bottle deposit schemes.

No, come back. It's more interesting than it sounds. Michael Gove wants us to take our empties to one of 34,000 reverse-vending machines because it will help save the turtles or something. It's not going to save any turtles and it is a fantastically expensive way of achieving very little.

Still, it sounds like a nice idea and so it will probably happen. It seems to have worked quite well in some other countries so there seems no reason not to adopt it in the UK. This is faulty reasoning. The deposit scheme is a classic example of a feel-good policy that fails basic economic analysis.

The government's own economic analysis is a bit of a joke, as I explain in an article for Spiked today...

Could a bottle-deposit scheme make a difference to marine pollution? On the margins, perhaps, but DEFRA doesn’t seem to have high hopes. Reading its impact assessment, the first thing that struck me was that it barely mentions the ocean and only alludes to possible ‘further additional benefits’ when it does. This is in stark contrast to DEFRA’s press release and Michael Gove’s op-eds, which talk of little else. One gets the impression that Gove wanted to be seen to be doing something in response to Blue Planet II and came up with an idea that, upon closer inspection, wasn’t going to cut the mustard. Rather than saving the turtles, the impact assessment focuses on the less glamorous objective of reducing street litter.

The second thing that struck me was how damn expensive it is going to be. According to DEFRA, it will require 35,000 reverse vending machines to be installed around the country and a new quango – the Deposit Management Organisation – to be created. Small retailers will be required by law to turn themselves into manual take-back points, with minimal remuneration. The system is expected to cost over a billion pounds in its first year, with ongoing costs of £814million per annum. The government expects this to be paid for by consumers who don’t return their drink containers and by producer fees charged by the Deposit Management Organisation. Either way, it means higher prices for consumers.

Even under DEFRA’s somewhat optimistic assumptions, the financial returns from this system are meagre. It expects to collect extra recyclable material worth £37million, reduce litter collection costs by £50million and produce ‘greenhouse-gas emissions savings to society’ worth £12million. The estimate for litter collection looks high, but even if it is accurate, the system will make less than £1 for every £8 spent.

This is patently not cost-effective, and so DEFRA conjures up nearly £1 billion of intangible benefits while overlooking the huge amount of unpaid labour that will be required to make the system function. The impact assessment is hopelessly skewed towards finding a net gain.

Whether your objective is reducing marine pollution or reducing street litter, the huge sums of money that will be spent on this make-work scheme could be better used in so many ways. Britain already recycles 74 per cent of plastic drinks bottles, which is more than some places that have a deposit scheme. There is room for improvement but most of the bottles that go unrecycled are used out of home and could be recovered if better street bins were available.

Layering a deposit system on top of kerbside collection makes no economic sense. It just adds to the workload. (This is the big difference between the UK and most countries that have deposit schemes - the latter didn't have kerbside recycling when their deposit schemes were introduced.)

In layman's terms, the question here boils down to: 'Does a modest reduction in littering justify spending £814 million a year and forcing tens of millions of people to take their empty drink containers to a recycling station when 72 per cent of these containers are already being recycled and kerbside collection covers 99 per cent of British households?'

This question can only be answered in the affirmative if you put a huge value on the cost of littering and no value on people's time. That is essentially what DEFRA has done and I can see no justification for it. You can't throw the normal rules of cost-benefit analysis out of the window just because an idea sounds nice - and no amount of talking about turtles is going to change that.

You only have to subject the policy to normal cost-benefit analysis to see that it makes little sense. That is what I have done in this IEA briefing paper.

Read the rest of my Spiked piece here.

Saturday, 13 April 2019

Minimum pricing - a brief overview

I've written an introduction to minimum pricing for Freer.

If a minimum price of 50p is ‘evidence-based’, then what would a minimum price of 60p or 70p be? The Sheffield model suggests that a 70p unit price would be more effective in reducing alcohol-related harm than a 50p unit price. Presumably, a £3 unit price would ‘work’ even better, but nobody is seriously calling for it. Why? Because it would increase the cost of living and make drinking unaffordable for many people. But so does a 50p unit, and it is easy to detect of element of snobbery here. It is deemed acceptable to increase the cost of living for people who tend to buy cheap alcohol, but not for those who can afford more expensive brands. MUP targets off licence beer while leaving the price of champagne untouched. 

Drinking is not illegal, nor is it illegal to exceed the government’s gerrymandered guidelines. Insofar as there are external costs associated with alcohol consumption, they are comfortably exceeded by alcohol duty revenues. MUP is a shamelessly paternalistic and patently regressive policy. Unnecessary and seemingly ineffective, it has no place in a free society. 

Have a read of it.




Wednesday, 10 April 2019

Have the health benefits of drinking been disproved?


A study in the Lancet got a lot of media attention last week because it purported to disprove the health benefits of moderate drinking. No single study can do that, of course, but that's how it was reported. It was accompanied by an astonishing editorial calling for readers to 'Unite for a Framework Convention on Alcohol Control' next to the 'no smoking/drinking' image shown above. No slippery slope, eh?

In short, the study looks at a Chinese population and argues that the J-Curve showing lower levels of stroke risk for moderate drinkers is an artifact of genetic differences. Two genotypes - ALDH2-rs671 and ADH1B-rs1229984 - are identified as suspects. The problem is that the former '
is mainly absent among Europeans but is prevalent in populations in East Asia' and the latter 'is found in 19 to 91% of East-Asians and 10 to 70% of West-Asians, but at rates ranging from zero to 10% in other populations'. Since most of the evidence for the J-Curve comes from western countries, it is not at all obvious that this explanation would hold up outside of Asia.

I was in Belgrade for LibertyCon when the study was published and didn't have time to look at it in detail. In any case, I don't pretend to be an expert on Mendelian randomisation, which is what the findings rely on, and its authors aren't likely to win any awards from the Plain English Campaign.  

So here instead is the view of Christopher Oakley who has kindly written a guest post... 


It is clear to anyone who has being paying attention to the shenanigans of the public health industry that the new Holy Grail for this pseudoscience is finding “proof positive” that the protective effects of moderate alcohol consumption are a myth. This is crucial to the more extreme elements that sadly dominate the discourse because, in their minds, it removes the last barrier to treating the alcohol industry as they have the tobacco industry and “denormalising” drinkers the way they have smokers.
Most of the attempts to do this have been exposed as pseudoscientific window dressing for puritanical agendas but last week’s effort involved some real science for once.

A study performed in China looked at people with genetic variants that reduce alcohol consumption. There are two genes involved so nine possible combinations of genotypes with a range of effects from making drinking alcohol very uncomfortable indeed to not having much effect at all. By looking at these groups it is possible to study incidence of stroke and heart disease relative to genotype and therefore ability to consume alcohol. Not a bad idea as it cuts out the reliance on what people say they drink and other confounders that make many epidemiological assertions equivalent to claiming to have split the atom with a bread knife.

The normal process for revealing a novel technique or discovery in science is to rigorously test prior to publishing in the most prestigious journal possible, defend it in peer review, modify if needs be and eventually, perhaps inform the wider public. But public health isn’t science. It has agendas and rushes to publicise anything that supports them, often avoiding prestigious focussed journals by publishing in medical journals with low standards but high media profiles.

So, unfortunately the world was made aware of this novel approach courtesy of uncritical journalism based on a press release issued by The Lancet that begins:

The Lancet: Moderate alcohol consumption does not protect against stroke, study shows

Blood pressure and stroke risk increase steadily with increasing alcohol intake, and previous claims that 1-2 alcoholic drinks a day might protect against stroke are dismissed by new evidence from a genetic study involving 160,000 adults.

Dismissed is a strong word in academia that should have given the journalists a further clue that this was a less then impartial perspective. An even bigger clue comes in the penultimate paragraph, which reads:

Writing in a linked Comment, Professor Tai-Hing Lam and Dr Au Yeung, from the University of Hong Kong…call for a WHO Framework Convention for Alcohol Control (FCAC), similar to the Framework Convention on Tobacco Control (FCTC): “Alcohol control is complex and stronger policies are required. The alcohol industry is thriving and should be regulated in a similar way to the tobacco industry.”

So, a novel scientific approach that should be cautiously rolled out open to question and peer discussion is rushed into the public domain with sensational claims linked to a call to arms aimed at fans of industry / lifestyle hyper regulation. And the BBC didn’t think to question this? Or read the study?

The rest of the press release talks about the study in brief detail but ignores an important section for reasons those of us familiar with the ethics of The Lancet and the lifestyle public health industry are all too familiar with.

The new approach of genetic epidemiology was performed alongside a larger conventional epidemiology study which produced very different results.


The conventional epidemiology produced the familiar J-shaped curve with non-drinkers and ex-drinkers having risk of stroke equivalent to people consuming around 25-30 units per week, which is consistent with many similar studies. The genetic epidemiology, by contrast, shows a steady increase in risk with consumption.

Thanks to the laziness (or prejudice) of journalists and the selective briefing from The Lancet, most people, including those who make our laws will be blissfully unaware that the contradictory conventional results exist. I don’t think that is accidental.

But why the difference in results? The authors of the paper are more circumspect than the press release but understandably talk up their genetic approach. They don’t offer any real explanation other than 'reverse causation and confounding', which is a feeble argument when you have segregated non-drinkers from ex-drinkers. If it were true, all of the lifestyle epidemiology that we have been bombarded with for decades becomes highly questionable.

Mendelian randomisation does have benefits provided that the assumptions made are correct. However, the implementation in this case also has downsides and I have listed the pros and cons in the table below.


The great strength of the genetic approach is that it cuts out a lot of uncertainty around misreporting and other human confounding problems that bedevil conventional epidemiology, but the great weakness is that it doesn’t link individual drinking patterns to risk.

The genetic study calculates mean consumption for each genotype in each area and assigns it to all participants in that group. This is a big departure from conventional epidemiology in which individuals are asked how much they drink. In this study, everyone has the same predicted consumption and therefore risk, irrespective of their actual consumption.

That is OK if you are wanting to show that genotype mediated capacity to drink is linked to increased risk of stroke or that stroke risk increases with consumption at the population level. It is less than fine if you are trying to claim that “one drink a day increases stroke risk” because you have no idea what is happening to individuals within groups, and sub populations can introduce bias.

In this case matters are made worse by not segregating non-drinkers, higher risk drinkers and ex-drinkers from current drinkers.  If we ignore the controversial non-drinkers and look at the composition of the six genetic groups with a focus on group C4, which is a proxy for moderate drinkers in conventional studies, this is what we get:


So, in the moderate drinker proxy group, the two most risky categories from conventional epidemiology are represented in almost equal numbers as moderate drinkers and considerably outnumber those drinking within UK government guidelines.

The C4 group also included 12% non-drinkers and 48% occasional drinkers who were assigned a 0.5 unit (5g) weekly consumption. The net effect of that is to significantly reduce the mean for the group to the extent that it does not realistically represent consumption for current drinkers.

One of the very concerning features of this study is that the authors seem over-eager to promote some contentious aspects but dismiss or ignore others. For example, the genetic study implied that around 10% of total strokes can be attributed to alcohol, double what is expected from the apparent impact on blood pressure. Rather than question the numbers, as any good scientist using a novel methodology would, the authors airily hypothesise why they are correct and then mass publicise them courtesy of The Lancet.

If they are correct, we might expect to see some impact on regional stroke incidence but there is none. At the study extremes, the province of Gansu, where drinking incidence is lowest, has a higher incidence of stroke than Sichuan where consumption is over 12 times higher.

Overall, I think that the use of Mendelian regression to reduce confounders is a positive for this study but the authors have been far too keen to make the data fit their preconceptions and have introduced their own confounders through their methodology. I do not believe that the study justifies the claims made by The Lancet and echoed in the media.

I find it frustrating that the mainstream media cannot understand that melodramatically embargoed prejudiced press releases from scientifically and ethically questionable sources should be treated with suspicion. Until they do, their output will be distrusted by an increasing number of people who will look elsewhere for news. In some areas, particularly health, it is practically impossible to distinguish the output from the established media from the “fake” news online.

An indication that this is a problem can be seen in the top-rated comments under the superficially balanced but embarrassingly uncritical and preachy BBC article on this study.

“Calm down and wait a few minutes, another expert theory will be along soon”

“Reading all these horror stories about alcohol consumption has given me the wakeup call that I need. It's time to give up reading”

“I wish they'd make their minds up. The warnings mean nothing when they change so often”

“Living one more day increases the risk of stroke”

“Can we please have the original statistic? Saying there is 10 - 15% increase is meaningless without the starting amount. A 15% increase on a risk amount of 0.005 is a tiny amount. A 15% increase on 50 is huge”

“Bored now. Please keep your ever changing health advice to yourselves”

So, not exactly a ringing customer endorsement of public health output, BBC editorial policy and its journalism. But they are not entirely to blame. It would help enormously if CRUK, BHF and the MRC stopped supporting ideological crusades and did something more useful with our money. After all, somewhere between 90% and 100% of strokes are nothing to do with alcohol.

Tuesday, 9 April 2019

Minimum pricing still failing


Minimum pricing was supposed to reduce alcohol sales in Scotland by 3.5 per cent in its first year. Politicians and campaigners left us in no doubt that it would reduce consumption. Alas, with nine months of sales data now available, the previously reported increase has been confirmed...

Scots are drinking more despite minimum pricing

Scots have bought more alcohol since minimum pricing laws came into force, an analysis has found.

Nielsen, a data specialist company, found that 203.5 million litres of alcohol was purchased from shops in Scotland over the 46 weeks to March 29, an increase of 1.8 million litres — the equivalent of four million cans of lager or 2.4 million bottles of wine — on the same period in 2017-18, according to The Mail on Sunday.

The article doesn't say what the change in units (as opposed to volume) is, but the Nielsen figures I've seen show a two per cent increase in alcohol units purchased since then end of April 2018.

As expected, there has been a big, double-digit decline in cider and perry which has been more than compensated for by a surge in spirits, ready-to-drink (RTD) and fortified wine. Beer sales have also risen.

It now seems almost certain that the campaigners-turned-evaluators (this is the 'public health' racket we're talking about here) won't be able to claim any decline in alcohol consumption in the first year. Nevertheless, the state-funded temperance group Alcohol Focus Scotland is strangely optimistic:

Alison Douglas, the chief executive of Alcohol Focus Scotland, said she was confident that further evaluation would show “minimum unit pricing delivers clear benefits”.

I bet she is. The studies might as well have been written before the policy was implemented. Unable to show an actual decline in consumption, the evaluators at Sheffield and Stirling Universities (for it is they) will have to resort to using a back-of-the-envelope counterfactual which will doubtless conclude that consumption is lower than it would have been in the absence of minimum pricing.

This will then be presented to the media as a decline and the policy will be declared as a success, albeit with the caveat that the unit price should be raised to 60p.

It remains to be seen whether the public will swallow any of this. Minimum pricing is costing Scottish consumers tens of millions of pounds. It is one thing to accept this as the cost of reducing alcohol consumption, but shelling out large quantities of cash to increase consumption by a bit less than a theoretical model suggests it might have increased by is a harder sell.

Incidentally, I hear that the Scottish government is running a heavy anti-alcohol advertising campaign focusing on the drinking guidelines, presumably in the hope that 'education' will succeed where minimum pricing seems to be failing.