Thursday, 22 August 2019

Public Health England's great chess board

Yesterday, the Daily Mail reported the findings of a study which found that packaged food in the UK is healthier than it is in eleven other countries. This isn't very meaningful because the authors averaged out tens of thousands of very different products.

Useless though it may be, it's the kind of aggregate data that Public Health England is relying on in its reformulation efforts, so I wrote about it for the Telegraph...

A study recently evaluated the nutritional quality of packaged food in twelve countries. It may surprise you to hear that Britain came top and the USA came second. The least healthy food was found in two of the world’s least obese nations: Hong Kong and India.

According to the research, average sugar content of packaged food in the UK is 3.5 grams per 100 grams; the lowest of the twelve countries studied and less than half of the 7.7 grams found in China. The overall energy content of Britain’s packaged food was also the lowest. With 252 calories per 100 grams, our processed grub is much less calorific than that of India, where the average is 380 calories per 100 grams.

These findings may strike you as counter-intuitive. After all, Britain is one of the fattest countries in Europe and the USA has the highest obesity rate in the western world. But crude averages don’t tell us much about the diet of individuals. In the UK alone, the researchers found 68,153 different packaged food and beverage products to study. In the USA, the number was 162,297. Taking an average from such a vast range of options is almost meaningless.

The average doesn't dictate what people eat. People have choice. Even under PHE's reformulated regime, people will still be able to switch from low-calorie food to high-calorie food.

After citing this sadly overlooked study, I end with a bit of Smith...

The great economist Adam Smith mocked central planners for believing that they can "arrange the different members of a great society with as much ease as the hand arranges the different pieces upon a chess-board". They forget that "in the great chess-board of human society, every single piece has a principle of motion of its own, altogether different from that which the legislature might choose to impress upon it."

It is a mistake to see the world through averages. The bureaucrats at Public Health England should lift their eyes from their spreadsheets, heed the warnings of Adam Smith and remember the power of human agency.

Do read it all. It's paywalled but you get two articles a week if you register for free.

Wednesday, 21 August 2019

Does alcohol really cause breast cancer?

The anti-alcohol lobby got very excited in April when a Mendelian Randomisation (MR) study suggested that there are no overall health benefits from moderate drinking. Put very simply, MR takes account of genetic differences to see if an epidemiological association has been confounded by genes or other factors.

The authors of the study chose to look at people living in a specific area of China where two genes associated with teetotalism are very prevalent. They didn't explain how these genetic differences explain the J-Curve and - more importantly - they didn't explain what relevance their findings had to countries like the UK where these genes are rare. As I said at the time...

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.

Nevertheless, it was good enough for The Lancet which published an extraordinary editorial pronouncing the death of the J-Curve, declaring that there is no safe level of drinking, and calling for a Framework Convention on Alcohol Control. Hello confirmation bias, my old friend.

The 'no safe level' claim is largely based on epidemiological studies of drinking and breast cancer, which purportedly show an increase in risk from very low levels of alcohol consumption. The evidence for this, in fact, very weak and a new MR study - currently in pre-print and based on a large sample of people in the UK - has found that the relationship between drinking and breast cancer doesn't exist at all. Moreover, it found that there is a threshold (ie. a safe level) for the handful of rare cancers that are genuinely associated with alcohol consumption.

Alcohol was observationally associated with cancers of the lower digestive system, head and neck and breast cancer. No associations were observed when we considered those keeping alcohol consumption below the recommended threshold of 14 units/week. When Mendelian randomisation was used to assess the causal effect of alcohol on cancer, we found that increasing alcohol consumption, especially above the recommended level, was causal to head and neck cancers but not breast cancer.
Our results where replicated using a two sample MR method and data from the much larger COGS genome wide analysis of breast cancer. We conclude that alcohol is causally related to head and neck cancers, especially cancer of larynx, but the observed association with breast cancer are likely due to confounding. The suggested threshold of 14 units/week appears suitable to manage the risk of cancer due to alcohol.

Strangely, the temperance lobby alcohol research community hasn't said much about this, even though it was reported in New Scientist.

Tuesday, 20 August 2019

The madness of food reformulation

I've written about the government's food reformulation ruse for Spiked...

At the heart of the reformulation delusion is an ignorance of market forces, a deep suspicion of industry and a naive faith in the power of bureaucracy to remedy supposed market failures. One of David Cameron’s greatest mistakes as prime minister was creating Public Health England in 2013. This quango, which relieves the taxpayer of over £4 billion a year, was always going to attract ideologues and activists from the clown show that is ‘public health’ academia. These people are relatively harmless when confined to their echo-chamber conferences and rinky-dink journals, but are a menace when allowed off the leash. At Public Health England, they have real power and influence. It is telling that the only ‘stakeholders’ from civil society involved in the reformulation work are Action on Sugar and the Obesity Health Alliance, two mouthpieces of the fanatical Graham MacGregor, who flood the media with hysterical claims about the ‘shocking’ levels of various ingredients in normal, everyday food.

As Josie Appleton showed in her superb report for the IEA last week, these activist groups are the outriders of reformulation, working hand in glove with PHE to soften the public up for further interventions in the food supply. The bone-headed approach of these extremist pressure groups has been bought wholesale by the apparatchiks at PHE. They allow no room for personal autonomy. As they see it, the public will buy whatever products the food industry throws at them. For some mysterious reason, the industry has traditionally chosen to put lots of unnecessary fat, sugar, salt and, er, calories in these products. Therefore, all the government needs to do is to tell them to use saccharine and brown rice instead and the British public will lose weight without even noticing.
It is the kind of idea you might hear from someone who owns a collection of bongs, but thanks to Public Health England it is official government policy.

Do read it all.

Friday, 16 August 2019

Cooking For Bureaucrats


The IEA has an important new report out today - Cooking for Bureaucrats - which looks at the government’s food reformulation scheme. With the noble exception of Laura Donnelly at the Telegraph, journalists have shown little interest in this deranged plan to remake the food supply to satisfy the loonies at Action on Sugar.

Combining investigative journalism and economic analysis, Josie Appleton shows how vast and crazy the whole thing is. It is devoid of common sense and divorced from the wants of consumers. PHE are making it up as they go. For example...

Many of the targets are surreal, such as the recommendation that sweets should contain less than 50 per cent sugar, when boiled sweets are almost solely made up of sugar; or the request that fudge, made from sugar and butter/cream, should decrease its sugar content without increasing its fat content. The guideline for sugar content in nut butters is less than that naturally occurring in cashew nuts. The calorie guideline for olive bread (254kcal per 100g) is lower than that of a plain baguette or ciabatta. The calorie reduction figure for crisps and nuts is 403kcal per 100g, whereas plain peanuts (not allowing for roasting) are 600kcal per 100g.

PHE is also trying to introduce ‘calorie caps’ for a huge range of food products. Josie got hold of the documents showing how these are calculated. They are extraordinary. PHE takes the sales weighted average and simply knocks off 20 per cent. As the graphs below show, this often means making food which is currently at the extreme end of the distribution. It is at the extreme end because hardly anybody wants or needs it.


She has also used Freedom of Information requests to obtain emails between PHE and two groups: the food industry and the nanny state lobby groups Action on Sugar/Salt. These are also illuminating. For example...

This private communication shows that PHE work closely on the development of policy with NGOs. Policies are run past the pressure groups in their early stages, and only released to industry for consultation much later. For example, OHA was briefed on the calorie reduction programme in August 2017, seven months before consultation with industry food bodies (March 2018). In September 2017, OHA had a ‘catch-up meeting’ with PHE, discussing excess calorie definitions, and portion size recommendations, timelines and reporting mechanisms, and the role of the NGO sector. They arrange meetings not to formally consult, but to ‘swap notes’ or ‘catch up’, or to ‘update you on some work we are doing’. They congratulate each other on report launches or media appearances. 
Interest groups are included in policy plans at an early stage, and play a role in the development of these plans, which are later presented to industry as a done deal, to be tweaked but not substantially changed. PHE and Action on Sugar (AOS) exchange emails almost every week, and seem to have a meeting in person around once a month (after each meeting they email to ‘get another date in the diary soon’).

...These health lobby groups appear to be dismissive of the actual public - the choices that people make and the opinions they actually have. They see themselves as speaking in the name of public health, which they present as being a matter of life and death, and are therefore above any profane manifestation of the public, such as what people themselves may think or want. In an email to PHE, AOS said that the aim of the reformulation policy is to ‘save millions of children from disability or early death’, and that ‘[t]his is the priority - not the profits of the food industry, or even public opinion’. The interest of public health policy, then, is something that stands above - and even against - public opinion: it claims a higher mission. So AOS is able to masquerade as the true public good, as standing above the millions of people who actually form the public.

You can download the report for free. I recommend you do. It will be an eye-opener.

Thursday, 15 August 2019

The Nanny State Index conference 2019


The new Nanny State Index was published in May, bigger and better than ever. Next month sees the Nanny State Index conference. It's in Brussels and free tickets are available to anyone who registers.

There will be a keynote speech at 9am followed by three panel discussions and a lunch. Needless to say, I will be there. Join us if you can.

The panel discussions are:

09.30 – 10.30: Benign paternalism across the EU: does the end justify the means?  
Many European countries implemented sugar taxes, plain packing of tobacco products, and other policies that claim to improve the health of their citizens. What are the outcomes of these policies; did life expectancy improve faster in countries with stricter lifestyle regulations than in the countries without such restrictions? Did junk food consumption decrease as a result of the ‘fat tax’ in Hungary or Denmark? Do nations consume less alcohol where minimum pricing and/or high sin taxes were implemented? This panel reviews with local decision makers and public policy experts, how the intended and unintended consequences of lifestyle regulations have been realized.

10.50 – 11.50: Whose responsibility? 
Paying more attention to health and well-being has been both a priority for the political and the corporate sector. Now, more than ever, there is increased attention to provide healthier alternatives in all sectors. Who bears the primary responsibility for improving health outcomes of individuals? Do policy makers on the regional, national, or EU-level have a duty of care? What are the responsibilities of corporates, when it comes to providing healthier alternatives or discontinuing certain products? Should there be a focus on individuals and their particular lifestyle choices? If so, are there clear lines, between benevolent nudging towards certain choices, and arbitrary limitations on the freedom of choice?

12.10 – 13.10: Overregulation & the shadow economy
Regulations often have unintended consequences which were never the aim of policy makers in the first place. Unrealistically high tax rates, bans, and other restrictions on consumer choice push a certain segment of consumption from the legal and regulated area into illegality.
What are the concrete impacts of such regulatory policies on the shadow economy? What plays a more important role in fighting the shadow economy – levels of taxation, the amount of regulation, public perception, detection & penalties, or the income level of citizens? New empirical research from the Lithuanian Free Market Institute provides unique evidence of the actual drivers of the shadow economy and a comprehensive cross-country perspective.

Speakers to be confirmed.

Wednesday, 14 August 2019

Burning injustice tackled

This advert has just been banned in the UK after three cranks complained. See if you can work out why.



The answer, such as it is, can be found here. Thank you, Theresa May.

Monday, 12 August 2019

Panorama on gambling - wrong again

It looks like Panorama is going to have yet another pop at gambling tonight. Having dealt with fixed odds betting terminals, it now reports that people can bet much larger sums of money online - as I repeatedly pointed out when I was virtually the lone voice opposing the anti-FOBT crusade.

A BBC article promoting the show ('Addicted to Gambling') says...

High stakes betting machines have been banned from the High Street, but there are no legal limits for online games. That means customers can lose thousands of pounds in just a few minutes.

No kidding. If only someone had mentioned this earlier, eh?

The article - and I presume also the programme - makes a striking claim about the amount of money spent (or 'lost' as the BBC sees it) on gambling. It says that there has been 'a sharp increase in UK gambling over the past decade' and that...

The industry has expanded rapidly since the government relaxed restrictions on betting and advertising in 2007.

It also claims that...

Gamblers are now losing almost twice as much to the betting companies as they were a decade ago. Last year, punters lost a record £14.5bn.

How 'sharp' has the increase been since in the last decade? The Gambling Commission records a gross gambling yield (ie. money taken minus winnings paid out) of £8,365 million in 2008/09 which, adjusted for inflation, is £11,400 million in today's money. The figure for 2017/18 was £14,529 million.

That's a rise of 27 per cent in real terms. An increase, but not an especially sharp one and certainly not 'almost twice as much', as the BBC claims.

However, as anyone who is familiar with these figures knows, the totals from the last few years are simply not comparable with those from a decade ago. Until 2015/16, most online gambling revenue was not included in the figures. It wasn't until the Gambling (Licensing and Advertising) Act of 2014 that remote gambling by UK consumers was regulated (and taxed) at the point of consumption, with any company trading on the British market having to hold a Gambling Commission licence.

This was George Osborne's way of taxing the offshore industry. Once introduced, billions of revenue that had not previously been recorded suddenly appeared on the books. In 2013/14, remote gambling spend was recorded at £1.1 billion. Two years later, it jumped to £4.2 billion.

Needless to say, this did not reflect a quadrupling of online gambling in Britain. All it showed was that a lot of offshore gambling spend had previously gone unrecorded because the companies were not based in the UK, did not pay tax in the UK and did not hold a UK gambling licence.

If you look at the Gambling Commission's figures, the step change between 2013/14 and 2015/16 is obvious. Click to enlarge.


For some reason, the Commission has switched from financial years to October-September years in the most recent year, but that's not important. The big picture is that gambling spend has fallen in real terms in arcades, betting shops, bingo halls in the last ten years. (Yes, you read that correctly - it has fallen in betting shops). Spending on the National Lottery has also fallen.

Gross gambling yields have remained about the same in casinos and have risen in the relatively small non-state lottery sector.

The only substantial sector that has seen an increase in real terms spending is online. That should come as no surprise, but we don't know the scale of the increase in the last decade because the figures are not comparable.

Has gambling spend increased in real terms in the last decade? Probably, but not by much, and if there has been a rise, it has come almost exclusively from online and we know that most online gambling spend was not recorded until 2015/16. The claim that overall gambling spend has nearly doubled is absurd. Panorama really needs to be put out of its misery.