Friday 2 December 2016

PHE's alcohol review: part 1 - the lies

Public Health England (PHE) published their review of alcohol control policies today. It is a hodge-podge of wishful thinking, blinkered analysis and outright deception. As you might expect, it takes the 'public health' view that all human behaviour is dictated by advertising, affordability and availability, and that the correct response is therefore to tax and ban.

Alas, the world refuses to bend to neo-temperance dogma and so when observable evidence does not fit the narrative, PHE rely on modelling, modelling and more modelling, mostly from the prolific Sheffield University alcohol team, supplemented by opinions from a handful of anti-alcohol fanatics.

A blog post covering all the tricks used in the PHE report would be too long so I'm going to split it into several sections, starting today with some of the outright lies.

Part one: the lies

1. Lying about the price of alcohol

Over the last 30 years, the affordability of alcohol in the UK has steadily increased and alcohol is now 60% more affordable today than it was in 1980 (182). Relatively speaking, disposable incomes have increased and real-term alcohol prices have decreased.

The real-term price is the price adjusted for inflation. Since 1980, the price of alcohol has risen by 23 per cent more than the rate of inflation, therefore the real price of alcohol has increased, not decreased.

2. Lying about the effect of minimum pricing

Unlike tax increases, where the price increase may not necessarily be passed through to the point-of-sale, this policy ensures that a minimum price is paid by the consumer. In principle, this applies to all alcohol, however this policy typically affects the high-strength, cheap products that are predominantly sold in the off-trade.

Minimum pricing may have a greater effect on the price of high-strength, cheap products but it does not 'typically' affect them. Recent evidence from Scotland shows that, at 50p per unit, minimum pricing will affect half of all the alcohol sold in off licences, including two-thirds of the beer. That is not a targeted measure.

3. Lying about Canada

A 10% increase in average minimum price for all alcoholic beverages in British Columbia was associated with a 32% (95% confidence interval [CI]: ±25.7%) reduction in wholly alcohol-related deaths within nine months, a 9% reduction in acute alcohol-related hospital admissions and a 9% reduction in chronic alcohol-related hospital admissions two to three years after the policy was implemented.

Regular readers will know that this is flagrant lie. Alcohol-related deaths did not fall during this period and alcohol-related hospital admissions continued to rise.

The best that can be said about Public Health England here is that they didn't make this factoid up themselves but got it from the minimum pricing crusader Tim Stockwell.

4. Lying about advertising

Marketing is a commercial strategy with the goal of increasing sales of alcohol by increasing market size (new sales from consumers who would not have purchased or purchased less of a product) and market share (new sales from consumers who would have purchased rival products). 

The goal of advertising, whether for alcohol or anything else, is not necessarily to increase market size. In fact, that is seldom the goal and certainly not the effect. If it were, most advertising would be considered a failure. Beer sales have been in decline for many years, for example, but millions of pounds are spent advertising beer. The overwhelming goal of advertising for any established product is market share, not market share and market size, as PHE claim.

5. Lying about costs

The economic burden of alcohol use is substantial, with estimates placing the annual cost to be between 1.3% and 2.7% of annual GDP. Few studies report costs on the magnitude of harm to people other than the drinker, so the economic burden of alcohol consumption is generally underestimated. 

Bunkum. All the studies PHE refer to look at harm to other people (ie. negative externalities). Not only do they include negative externalities, but they inflate their figures by portraying many internal costs as external costs. It would be impossible to claim that the cost of alcohol is between 1.3% and 2.7% of annual GDP without including a vast range of alleged externalities.

The 1.3% actually comes from the most-cited English study which claimed the costs of alcohol were £21 billion per annum. That study explicitly set out to look only at negative externalities, including physical and financial harm to others. In practice, however, it included various internal costs such as lost productivity which should not have been included but which inflated the estimate. Either way, it is a lie to claim that it didn't 'report costs on the magnitude of harm to people other than the drinker'. On the contrary, it exaggerated them. 

6. Lying about costs again

Crucially, the financial burden which alcohol-related harm places on society is not reflected in its market price, with taxpayers picking up a larger amount of the overall cost of harm compared to the individual drinkers.

This may be sheer ignorance rather than a deliberate lie, but it is certainly untrue. By any measure, the costs to non-drinking taxpayers are far lower than the £10.4 billion drinkers in England pay in alcohol duty. The most charitable way to interpret PHE's statement is that the authors don't know the difference between societal/intangible costs and financial costs to the state.

7. Lying about alcohol consumption

This is a bonus lie that appeared in Public Health England's press release and in Duncan Selbie's weekly e-mail...

As a nation we are drinking twice as much as we did 40 years ago

No, we're not.

8. The big lie

The dishonesty in (7) points to a wider lie that runs through the whole PHE document. When looking at alcohol consumption over time it never refers to per capita consumption. Instead it talks about overall consumption. That might not seem very important, but the population of England and Wales has grown significantly in the last 40 years, with a large share of the increase taking place in the last ten years. The graph above shows alcohol consumption per capita, but PHE choose to show overall consumption like this...

Even if you ignore population growth and look at gross alcohol sales, PHE are still lying when they claim that we are drinking twice as much as we did 40 years ago, but there is a very specific reason why they have picked this inappropriate measure of consumption.

If you look at per capita consumption, the recent peak occurred in 2004, but if you look at overall consumption the peak occurred in 2008. This seemingly minor discrepancy has major implications for PHE's tax-and-ban approach to alcohol because if you accept that consumption started falling after 2004, there is no obvious explanation in the neo-temperance handbook. In 2005, incomes were still rising, alcohol was still becoming more 'affordable' and the licensing laws had just been relaxed. According to the beliefs of the 'public health' lobby, alcohol consumption should have kept rising.

But if you pretend that alcohol consumption was still rising during this period and only began to fall after 2008, you can claim that it was the result of alcohol becoming less affordable thanks to the alcohol duty escalator and the global economic downturn (both of which began in 2008). Nick Sheron and Ian Gilmore tried this trick out in a BMJ article earlier this year and it has now been embraced by PHE (unsurprisingly, since Sheron is one of the authors of the PHE report).

Measuring consumption by overall volume rather by per capita also has the effect of making the drop in consumption look smaller than it is. The decline per person in the last twelve years has been nearly 20 per cent, but by ignoring population growth PHE can portray the drop as being relatively insignificant. This gets them off the hook because it means they don't have to give an explanation for why alcohol-related hospital admissions and deaths have failed to decline (as they should under the total consumption model).

Despite the recent small declines in overall alcohol consumption, many indicators of alcohol-related harm continue to rise.

A twenty per cent reduction in drinking since 2004 is not as recent as PHE are claiming and it is certainly not small. I call that a lie.


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