Live from Cardiff

As the BBC rather unexpectedly reported, I attended the Welsh Assembly this morning to give evidence on minimum pricing.

A minimum price for alcohol in Wales could hit drinkers on low incomes and lead to some young people turning to drugs, a think-tank will tell AMs.

The Institute of Economic Affairs (IEA) will also claim it is "impossible" to predict how consumers will react.

The Welsh Assembly's health and social care committee is taking evidence on the proposed minimum 50p unit price.

... "It will simply wipe out the bottom end of the market and force consumers who have a preference for budget brands to buy mid-range brands," said Chris Snowdon, the IEA's head of lifestyle economics.

"It is likely to lead to a shift from cider to spirits for dependent drinkers. A shift to the cheapest illegal drugs is also highly plausible among some groups, including young people."

He also claimed it could increase the cost of living for those who do not wish to drink less and is likely to lead to those on low incomes cutting other parts of the household budget, such as food and heating.

If you are minded to, you can read my written submission here and you can view my appearance here. I'm on after the lads from the Sheffield Modelling Club.

The committee generally seemed to be sceptical about the idea that increasing the price of most off-trade booze was only going to cost moderate drinkers two quid a year (as the Sheffield lot claim). And rightly so, it would be a very unusual drinker who was affected so little. One of their number was less sure about alcohol and drugs being substitutes (a 'public health' trougher had denied this in an earlier session). I promised to forward some evidence and have now done so, including this, this, this and this.

Banning fast food outlets in London

The major of London, Sadiq Khan, is the latest gullible chump to fall for an idiotic idea from 'public health' busybodies.

Fast-food takeaways will be banned from opening within 400 metres of schools in a bid to tackle the capital’s child obesity epidemic.

... [Khan] said: “Takeaway restaurants are a vibrant part of London life, but it’s important that they are not encouraging our children to make poor food choices.

“I am using all of my powers through my new London Plan to prevent new takeaways from being built just down the road from schools as part of a package of measures to tackle the ticking time bomb of childhood obesity and help us all lead healthier lives.”

Great news for the incumbent chicken shop industry, not such good news for consumers. When did protecting existing fast food outlets from competition become part of the mayor's job?

But the ban only applies to streets within 400 metres of a school, right? How bad can it be?

Let's have a look at just some of the schools in London, shall we?

That map doesn't show the scale so let's zoom in on one area at random and compare it with a Google map of the same area which shows what 500 metres is in the bottom right.

Imagine a 400 metres exclusion zone around each of those schools and you get an idea of how far-reaching this ban is.

And thanks to some solid work by Dan Cookson, you don't need to use your imagination. Here's how it will look...

 
In the future, if you want to open a Chinese takeaway or a sandwich shop in a part of London where people actually live - ie. not in a river or a park - you might as well forget it. In the future, a licence to sell tasty food will be like gold dust. The only way to get one will be to beg, borrow or steal from one of today's lucky owners.

So much for London being a dynamic, business-friendly metropolis.

David Spiegelhater on the drinking guidelines

The statistician David Spiegelhalter gave a speech to the Public Health England conference in September. You can see it on Youtube. His main point is that the health lobby could do a much better job of communicating risk. In his polite and cheerful way, he gently alludes the fact that many in 'public health' do not want to communicate risk properly. Instead they want to communicate risk in a scary way because their objective is not to have an informed population. It is to have a compliant population.

(There are some exceptions. For example, doctors do not want to scare people off having X-Rays so the (very small) risk of having one is carefully explained in terms of absolute risk rather than relative risk. Cancer Research UK also explain the risk of eating processed meat in absolute terms because they are not yet ready to fight a war on sausages. Contrast this with the way the risk of getting cancer from drinking or breathing secondhand smoke are presented.)

Of particular interest is Spiegelhalter's discussion of the drinking guidelines. He skips over the problems with the Sheffield model (although he was partially aware of the effect that changing the methodology had) and focuses on the way the 'evidence' was reported to the public. He mainly blames the government's communications people, thereby overlooking the role of the guidelines committee and Sally Davies herself, but he rightly says that the communication of drinking risk was very miselading.




You can watch that section of the speech above. My favourite moment is when he subtly puts the knife into Mark Petticrew, one of the leading members of the guidelines group who recently published a silly article claiming that the booze industry denies the link between alcohol and cancer. Petticrew's article was based on a review of alcohol company's websites and Spiegelhalter responds with this slide...

Ouch.

Public Health England and the drinking guidelines scandal

At the end of last month, I revealed the e-mails that show Public Health England telling the Sheffield Alcohol Research Group to change the methodology of their computer model despite the obvious reservations of the latter. The change in methodology had no sound scientific justification but it had the effect of lowering the model's implied drinking guidelines for men from around 21 units to around 13 units. The Chief Medical Officer subsequently announced that the male drinking guidelines would be reduced from 21 units to 14 units.

If you haven't read my article, please do so before you go any further.

Public Health England's Duncan Selbie has since written a letter to the Spectator in which he disclaims responsibility for this and gives the credit/blame to the guidelines group. I reproduce it below, along with my response.

Christopher Snowdon’s piece, ‘The new drinking guidelines are based on massaged evidence’, is grossly incorrect and misrepresents Public Health England’s (PHE) role in the guidelines’ development.

PHE emphatically refutes any suggestion that we intervened in some way to influence the evidence made available by Sheffield University to an independent expert group, the Guideline Development Group (GDG), which was set up by the UK Chief Medical Officers to help develop the alcohol guidelines.

As part of the secretariat to the group, we commissioned the analysis, as requested by the GDG, from Sheffield University. Any emails from PHE to Sheffield commissioning additional modelling and evidence were based on the GDG’s decisions and at their request, as is clearly shown by the publicly available minutes of their meetings.

This has been confirmed by Sheffield University’s Alcohol Research Group, which has said:

“Minutes from the subsequent GDG meeting on 21 January 2015 state that, after hearing Sheffield’s presentation of their work, the GDG concluded: ‘A holistic, expert judgement on guideline levels would be needed, taking account of uncertainties and issues not fully modelled’. This demonstrates that the group recognised there was considerable scientific uncertainty present and that no single piece of evidence or modelling decision used in isolation would determine the final guideline.

“As noted in the Royal Statistical Society’s consultation response: “This is a contested area of science with considerable uncertainties” (paragraph 1.1). The change to the base case analyses related to a point of scientific uncertainty. The Sheffield Alcohol Research Group were happy with the decision taken whereby the base case analysis was revised but the original modelling assumptions were retained as one of a series of sensitivity analyses.

“Those analyses explored major areas of uncertainty within the underlying evidence and their implications for the Guideline Development Group’s work. The group considered those sensitivity analyses in detail and took them into account in their decision-making.”

Mr Snowden [sic] also refers to The Public Health Burden of Alcohol and the Effectiveness and Cost-Effectiveness of Alcohol Control Policies: An evidence review, which PHE published in 2016. The facts speak for themselves; this unprecedented and comprehensive evaluation of the evidence had an extensive three-stage peer-review involving UK and international academics. The abridged version was also subject to further peer-review processes before its publication by The Lancet.

My reply:

If, as Public Health England claims, my exposé of the alcohol guidelines review was 'grossly inaccurate', one would expect the agency to flag up some factual errors. Their sole complaint appears to be that I suggested that it was they, rather than the Guideline Development Group, who came up with the idea of changing the methodology. I suggested no such thing. I explicitly said in the original article:

"On 21 January, the GDG held a meeting at which SARG’s John Holmes and Colin Angus presented their findings. The minutes of this meeting contain the first mention of an idea that would have a profound impact on the whole project. It was suggested that SARG researchers should ‘estimate risk curves without threshold effects for wholly alcohol-attributable chronic conditions’."

As the commissioner of the research, PHE followed up with a series of e-mails to the Sheffield Alcohol Research Group (SARG) in February 2015. These e-mails show the Sheffield researchers trying to talk PHE out of the idea of replacing their base case scenario with a sensitivity analysis that was built on patently unrealistic assumptions.

The crucial e-mail exchange came on 10 February when SARG said that they were 'unclear exactly what was being requested' and that 'it does not seem right to assign people drinking at very low levels a risk of acquiring alcoholic liver disease and similar conditions.' They added that: 'Unless there are strong opposing views, we think it better to keep the threshold in the base case.'

That e-mail was sent at 4.37pm. PHE replied at 10.40pm with a short e-mail ignoring the compromise suggested by the Sheffield team and asking how much it would cost to drop the threshold from their main findings (the 'base case'). From this, there was no looking back. 

Had the GDG offered 'strong opposing views' in the few hours between these two e-mails or was PHE acting on its own initiative? There was no meeting of the GDG that evening, but it is possible that PHE had made phone calls to some of its members. We know from separate e-mail exchanges that PHE is in regular contact with the anti-alcohol groups that were represented in the GDG.

It is also possible that the GDG had explicitly ordered the base case to be changed in its meeting of 21 January. If so, it was not recorded in the minutes. The minutes merely state that the GDG had suggested that PHE 'commission further sensitivity analyses or new modelling where feasible' including an estimate of 'risk curves without threshold effects for wholly alcohol-attributable chronic conditions'. As I explained in my article, there is a huge difference between running a sensitivity analysis and changing the base case that will dictate the headline findings.

The reaction of the Sheffield researchers to PHE's request for a change in methodology suggests that such a fundamental change was not agreed at the GDG meeting. Two of the Sheffield team were at that meeting. If the GDG had explicitly called for the base case to be changed, why were they so surprised and dismayed when PHE asked them to do it?

We will probably never know what was going on between PHE and members of the GDG behind the scenes. PHE's complaint against me seems to be that I gave the impression that the agency somehow overrode the will of the GDG. I don't think any fair-minded reader would infer that from my article but, for the avoidance of doubt, let me say again that the GDG was packed with campaigners from the temperance and 'public health' lobby who would have been delighted to see the guidelines lowered. There is enough blame and shame to be shared by all three of the groups involved: the guidelines committee, Public Health England and the Sheffield Alcohol Research Group. I have never suggested that PHE bear all, of even most, of the responsibility.

The fact remains, however, that Public Health England commissioned and funded the Sheffield research and it was they who set the parameters, whether acting as intermediaries or on their own initiative. Having funded the research, they now seem keen to pass the buck to the GDG. For their part, the Sheffield team has always been keen to pass the buck to PHE. Twice in their report, SARG stress that the dropping of thresholds was done at the agency's request. On page 28 they say: 'At the request of the commissioners (Public Health England), this threshold effect removed for the base case analysis...' Note that they do not say that it was done at the request of the GDG. Elsewhere in the report they make it clear that they would not normally run their model in the way they did and, at times, they seem to be distancing themselves from their own findings.

If this research was so strong, why does nobody want to take responsibility for it? Why is PHE so keen to point the finger at the GDG? Why is SARG so keen to play down the importance of their report? It is not a good look for PHE to be saying that they were only following orders. The best defence the Sheffield team has been able to mount is to claim that the change in methodology related to 'a point of scientific uncertainty' and that they were 'happy with the decision taken'. Anyone who reads the e-mails can be the judge of how 'happy' they were about it, but there is really no 'scientific uncertainty' about whether moderate drinkers are at an increased risk of developing diseases of alcoholism. They are not. There is plenty of uncertainty about how much an individual needs to drink before the benefits of alcohol are outweighed by the risks, but there is no uncertainty about there being a threshold for the ten chronic diseases that SARG dropped 'at the request of the commissioners'.

SARG are keen to point out that the change in the guidelines was not due to any single piece of evidence. I have never suggested otherwise, but their report cannot be dismissed as unimportant. It was explicitly designed 'to inform the Chief Medical Officer's review of the UK low risk drinking guidelines', as its title says. The first draft noted that the 'implied guideline thresholds are generally similar to those in the current UK lower drinking guidelines’. An anonymous reviewer of that draft wrote: 'I predict that there will be very little, if any, change to the Guidelines'. That all changed once PHE got SARG to change their methodology. It would have been possible to lower the guidelines without changing the Sheffield model, but it would have been a hard sell. The credibility of Sheffield's work is therefore of significant public interest. Is there anybody willing to stand up for it?

PHE defends its 2016 alcohol policy report on the basis that it was peer-reviewed. Peer review can make a document fit for publication but it does not make it true. If the aim of peer review is to fact-check, PHE was let down by its reviewers on that occasion. The 2016 report contains numerous basic errors, such as the claim that ‘real-term alcohol prices have decreased’ since 1980 (they have risen by 23 per cent). The report was released to the public with the claim that people in Britain are drinking twice as much as we did in 1980. We are actually drinking exactly the same amount (9.4 litres per adult). 'The facts speak for themselves', says Mr Selbie. Indeed they do, if you can find them.

When a report is littered with obvious errors, defending it on the basis that it has been peer reviewed is more of an indictment of your peer review process than a defence of the publication. But I am glad they have brought it up since it allows me to mention something about the guidelines process that space did not permit in my original article.

When I have had work peer reviewed at the Institute of Economic Affairs and elsewhere, the editor gives the manuscript to a third party of his or her choosing who doesn't know that I wrote it. When I receive their comments I don't know who they are. This double-blind system prevents any bias towards or against the author. By convention, reviewers are not paid.

This is not how it worked when the Sheffield team submitted their final report. On 6 May 2015, PHE sent an e-mail asking if they had had it externally peer reviewed. Sheffield said that they hadn't but they were 'happy to arrange for this to happen'. On 12 June - more than a month later - someone from PHE replied to say that 'I'm happy for you to suggest reviewers'. Sheffield then provided two names (which are redacted in the e-mails released under FOI) and asked PHE: 'Do you want the reviews to come through you or are you happy for us to just share the comments and revisions?' PHE replied: 'Happy for you to sort out the peer review directly and share comments/revisions with me.'

On 25 June, Sheffield e-mailed PHE saying that they had approached two potential reviewers, one of whom wanted £650 to do it because 'this is the rate he is being paid by PHE to review another lengthy report'. PHE said that they 'don't have any funds set aside for peer review' but were 'looking into' whether they could access some.

By mid-September, no funds had been released and only one reviewer had been found - an unnamed PHE employee. SARG e-mailed to say that 'I think we're just looking at XXX(PHE) unless you would like me to try to find someone else at short notice?' It is not clear from the released e-mails whether a second person was ever found. All we know for sure is that PHE handed the task of finding reviewers for the SARG report to the people at SARG who then approached somebody at PHE to do it! This is a far cry from blind external peer review.

Finally, Mr Selbie quotes SARG quoting the Royal Statistical Society and their reference to a 'contested area of science'. SARG say that the 'change to the base case analyses related to a point of scientific uncertainty'. This is misleading. The contested area of science to which the Royal Statistical Society referred was the general issue of defining a low-risk guideline, which is indeed difficult to pinpoint with precision. They were not referring to the specific question of whether there is a consumption threshold for some diseases.

SARG did not quote what the Royal Statistical Society actually said about that question. On page two of their consultation response, the Society notes that getting rid of the threshold leads to a 'statistically implausible assumption of a linear relationship' and that 'without this enforced assumption, the threshold for males to reach a 1% lifetime risk would have been 21 rather than 14 units, exactly the previous Guideline'.

Mandatory cycle helmets are a bad idea

The British government is considering importing another foolish idea from Australia. From The Times...

Cyclists could be made to wear helmets for the first time in a review of bike safety.

A government consultation in the new year will consider whether helmets and high-visibility vests should be mandatory on British roads, the transport minister Jesse Norman said.

There are several problems with this, as I said in Killjoys...

Helmets certainly reduce the risk of serious head injury if the cyclist is in an accident, but it has been suggested that cyclists take more risks when wearing a helmet and motorists drive closer to those who are wearing them. This is difficult to prove either way, but there is no doubt that laws mandating cycle helmets reduce the number of cyclists on the road because not all bicycle-owners are prepared to buy or wear one. 

This leaves those who remain more vulnerable to motor vehicles, since there is safety in numbers when it comes to cycling, and it takes an important physical activity away from those who are deterred.

The Times article mentions that the Australian ban on cycling without a helmet has led to a reduction on the number of cyclists on the road. Mexico City scrapped a similar law in 2010 for this reason. It effectively deters people from using their bikes.

There is also the question of what would happen to bike sharing schemes such as London's 'Boris Bikes'. Would people be expected to carry a cycle helmet (and a high-vis jacket!) on the off-chance that they might want to hire a bike?

Compulsory cycle helmets are a bad idea for both individual freedom and 'public health'. It should be taken no further - and, judging by this tweet from the transport minister, it won't...

To be clear: there is no “plan” re: compulsory helmets or hi-vis for cyclists as suggested in @thetimes. As @BikeBizOnline reported, I don’t take a position on this. It’s sure to be raised in the consultation, and we will consider it based on the evidence. https://t.co/FppxgRXHPA

— Jesse Norman (@Jesse_Norman) November 24, 2017

Five reasons why mandatory food reformulation is a terrible idea

I've written a short briefing paper for Epicenter about why state-sanctioned food reformulation, as currently being practised by Public Health England, is a bad idea. You can download it here or read it below....

Health by stealth

The food industry is highly competitive and innovative. Its products are being constantly reviewed and reformulated to maintain or gain market share. As with other fast moving consumer goods, the vast majority of new food products are withdrawn from the market within a year while some leading brands have been popular for decades. Manufacturers are naturally reluctant to modify their most trusted brands, but are generally happy to create ‘spin-off’ products, such as low-sugar or organic alternatives.

Food and soft drinks appeal to consumers on the basis of four key factors: taste, price, convenience and health. Historically, consumers have wanted energy-dense food at the lowest price but as countries become more affluent the problems of scarcity and hunger are replaced by the problem of obesity. Many consumers want to consume fewer calories but - crucially - they do not want to sacrifice flavour. This poses a challenge to the food industry because human beings have evolved to find calorific ingredients such as fat and sugar tasty.

In recent decades, the food and soft drinks industries have spent vast sums of money producing and marketing products which can be branded as ‘healthy’ or ‘healthier’. Taking their cue from nutritional science, they have reformulated products with less fat, salt and sugar to appeal to more health conscious consumers. In most cases, they have created alternative brands to give consumers more choice but some flagship brands have also been subtly altered.

Many of the alternative varieties have flopped, but some have succeeded. Diet soft drinks were niche products 40 years ago but are now extremely popular. Various sweeteners, including Stevia, aspartame and saccharine, have been used to mimic the taste of sugar. Full fat milk used to be the norm but skimmed and semi-skimmed milk now make up 80 per cent of milk sales in the UK (semi-skimmed has less than half the fat content and two-thirds of the calories) (Munday and Bagley 2017). Processed food with less salt, sugar and/or fat has proliferated and many low calorie products are successfully marketed as ‘light’ or ‘diet’ variants.

The supermarket chain Tesco claims to have ‘removed over 8,000 tonnes of sugar, fat and salt from over 2,000 products’ since January 2016 (Ewart 2017). In a survey of 102 global food companies, the Consumer Goods Forum (2017: 8) found that 180,000 products on shop shelves in 2016 had been ‘formulated to support healthier diets and lifestyles’. Clearly, it is possible to reformulate food products without losing customers. So far, these innovations have been mostly driven by consumer preferences and without government intervention, but there is growing interest in mandatory targets being set to ensure that reformulation continues.

State-sanctioned reformulation is not without historical precedent. A few countries, such as Denmark, have placed a legal limit on trans fat levels in food (although most countries have seen a sharp decline in trans fat consumption without state intervention). Several countries, such as Australia, require minimum levels of folic acid in bread to prevent children being born with spina bifida. British law requires calcium carbonate, thiamin and nicotinic acid to be added to most flour. Ireland and a number of US states have laws requiring drinking water to be fluoridated to prevent tooth decay.

But using the law to restrict the use of core ingredients for the purpose of reducing the calorie content of food is a new development. As yet, no government has legislated in this area. In Britain, a salt reduction scheme began in 2006 as a voluntary initiative between government and industry. This is believed to have resulted in a 5.1 per cent reduction in salt consumption by 2011 (Griffith et al. 2016: 2). The EU’s Framework for National Salt Initiatives set a target of reducing salt content in food by 16 per cent between 2008 and 2012, and its Framework for National Initiatives on Selected Nutrients proposed a 10 per cent reduction in sugar and saturated fat content by 2020. Participation in both EU projects by member states was entirely optional.

Although the European Commission reported in 2012 that all member states had some form of salt reduction scheme at work, it said that ‘the only country that had reported systematically engaging with and tracking the actions of individual companies through commitments and action plans’ was the UK. The British government has since followed up its anti-salt activity with an ambitious sugar reduction plan that aims for a decline in sugar content in food by 20 per cent by 2020. This scheme, which involves similar targets for fat and calories in its next phase, is technically voluntary but the government has threatened legislation if its targets are not met and has promised to ‘name and shame’ companies which fail to meet them. A sugar levy is also being introduced (in April 2018) with the specific aim of making companies reduce sugar content in soft drinks. The programme is therefore somewhat coercive.

Co-ordinated by Public Health England, this ‘health by stealth’ approach has only been underway since 2016 but it has already highlighted some of the problems with mandatory reformulation:

1. It can penalise companies that have already made significant changes to their products

As mentioned above, food companies have been reformulating products to reduce sugar, fat and calories for years, without pressure from government. Some degree of reformulation is often possible without having a noticeable effect on taste, but beyond a certain point the product becomes unpalatable. By requiring all companies to meet the 20 per cent target, Public Health England is effectively punishing firms that have already reduced sugar content. Those which have not modified their products will find their task easier, leaving them with the commercial advantage of having a tastier product by 2020.

2. It can lead to smaller products

In 2014, a newly formed pressure group called Action on Sugar began whipping up concern about the amount of sugar in savoury products such as ready meals, bread and pasta sauce. The sugar reduction programme includes these products but has also been extended to include items such as chocolate, cakes, biscuits and confectionery for which sugar is absolutely integral. Consumers do not generally find artificial sweeteners to be satisfactory substitutes for sugar in such products and so the only way sugar content can be reduced is to make the product smaller, leading to ‘shrinkflation’. Since prices are usually not reduced when the products is shrunk, consumers naturally feel exploited. The assumption that companies are making excess profits is not necessarily fair - reducing portion sizes requires capital investment in new machinery and packaging - but consumers get a worse deal nonetheless.  

3. It restricts choice by effectively banning the original product

Under consumer-driven reformulation, companies typically add a new low-sugar, low-fat or low-salt product to the market in addition to the original brand. This allows consumers freedom of choice. State-driven reformulation, by contrast, requires modification of the entire product range and effectively removes the original recipe from the market. This is a restriction of choice and is unfair to consumers, many of whom neither want nor need to restrict their calorie intake.

4. It can be unpopular

Because of the restriction of choice and shrinkflation (see above), reformulation can be unpopular with the public. Advocates of reformulation point to various products which were modified to reduce salt content without the public noticing or objecting. But reducing salt from savoury products is a relatively simple process compared with the task of removing sugar from sweet products. People tend to notice when sugar is removed from their trusted brands. The soft drink Lucozade, for example, had its sugar content slashed in April 2017, leading to thousands of complaints and a drop in sales (Fletcher 2017).

5. The targets can unrealistic and arbitrary

The UK’s target of reducing sugar by 20 per cent by 2020 seems to be based on nothing more than numerology. It is twice as challenging as that proposed by the EU and is equally arbitrary. Rather than make a realistic assessment of what can be achieved, the UK government seems to have picked a figure that fits in with the date of the deadline. Public Health England has no expertise in food manufacturing and seems to have been overly optimistic about what can be achieved in such a short timeframe. The 20 per cent target is a classic top-down, command and control diktat.

Conclusion

Food can be reformulated to be made less calorific but the process is by no means simple it can be practically impossible for some products. Governments can force companies to change their products but they cannot force consumers to buy them. Gradual reductions in salt, fat and sugar can sometimes be made, but there is a limit to how far reformulation can go before consumers reject it.

Many consumers do not enjoy the taste of artificial sweeteners are are not interested in reducing their sugar intake. Mandatory reformulation is a way for governments to bypass consumer preferences by putting pressure on manufacturers. The pioneering British scheme will show how far this coercive approach can be pushed before it creates a public backlash. It remains at an early stage and many of the newly reformulated products have not yet reached the market, but it would not be surprising if consumers respond negatively to the changes. 







Consumer Goods Forum (2017) Health and Wellness Progress Report. Deloitte Global

Ewart, K. (2017) Tesco continues work to reduce sugar, salt and fat in own label products. Tesco. https://www.tescoplc.com/news/blogs/topics/health-reformulated-tesco-products/

Fletcher, I. (2017) Lucozade sales plummet after brand dramatically cuts amount of sugar in drinks following tax levy. Mirror 4 November

Griffiths, R., O’Connell, M. and Smith, K. (2016) The importance of product reformulation versus consumer choice in improving diet quality. Economica 84(333): 34-53

Munday, H. and Bagley, L. (2017) The history of food reformulation. Food Science and Technology: http://fstjournal.org/features/31-3/food-reformulation

Plain packaging for alcohol (again)

The week's Lancet has an editorial about alcohol. It doesn't even bother to acknowledge the temperance lobby's victory in the minimum pricing court case. They are already moving on to the 'next logical step'.

Here are the closing sentences...

There is no excuse to ignore regulatory interventions for access, advertisements, and unit cost that are shown to reduce alcohol consumption. Like tobacco, the longer the delay in effective control, the more severe future interventions for alcohol will need to be. It is not unimaginable that bottles of Château Mouton Rothschild, which once bore the artwork of Salvador Dali and Pablo Picasso, might one day be required to have plain packaging and images of oesophageal cancer or a cirrhotic liver.

It only seems like yesterday when those of us who predicted this slippery slope were portrayed as paranoid libertarians who had fallen for a deceptive tobacco industry argument.

Freedom is indivisible and killjoys never sleep.

Europuppets defunded

A few years ago I wrote a report called Europuppets about the EU's exceptional largesse towards 'civil society' organisations of which it approves. Quite a few of them are in the business of punishing consumers under the pretext of 'public health', including the European Public Health Alliance (EPHA).

Over the years, EPHA has lobbied for minimum pricing, taxes on food and the Tobacco Products Directive, so I was delighted to hear that the European Commission is going to stop funding it next year.

In late October 2017, EPHA was informed that it had not been selected to receive an operating grant from the European Commission’s Health Programme, as from January 2018.

Such an occurrence has always been a possibility and the EPHA Board has undertaken contingency planning for several years. While this has some immediate implications for the organisation, the board and secretariat team are implementing plans to ensure EPHA’s long-term sustainability.

EU funding accounts for two-thirds of their income so hopefully their long-term sustainability is out of the question, unless Pharma steps in.

And the good news doesn't end there. The European Network for Smoking and Tobacco Prevention (ENSP) has been unsuccessful in applying for EU cash and the neo-prohibitionists at Eurocare have been defunded. The former relied on EU taxpayers for more than half of its budget so hopefully it will wither and die before it can bring about its 'tobacco endgame strategy'.

Not a bad start. The full list of unsuccessful grant applications can be read here. I don't recognise them all by the abbreviations so if you spot any gems, let me know in the comments.

Have a great weekend!

Looking forward to minimum pricing

Now that the SNP are free to introduce minimum pricing, it's worth looking at what we're supposed to expect.

Back in 2009, when minimum pricing became a live issue, the Sheffield modellers predicted that a minimum price (of 40p in those days) would result in a drop in alcohol consumption of 2.7 per cent and a decline in alcohol-related deaths of 40 in the first year, rising to 210 per annum after ten years.

Given the 'public health' lobby's absolute obsession with this policy in the years since, we must assume that they regarded these as game-changing numbers. Imagine if alcohol consumption fell by 2.7 per cent! What a victory for health that would be.

We don't need to imagine because consumption fell by much more than that after 2009 without any notable policy change. In 2007, Scots were drinking 11.8 litres of alcohol a year. By 2016, this had fallen to 10.5 litres. This is a drop of 11 per cent - four times as great as the decline Sheffield said would occur if minimum pricing was introduced.

You probably haven't heard much about this, but if minimum pricing had been introduced in 2009 you would have never heard the end of it. Not only did alcohol consumption fall by 11 per cent, but the alcohol-related mortality rate fell from 34.6 per 100,000 to 30.0 per 100,000 for men and from 16.7 per 100,000 to 9.0 per 100,000 for women. This is a drop of 13% and 46% respectively.

It is interesting to see the decline in both drinking and alcohol-related deaths in Scotland in recent years and yet I do not see much interest in it from the denizens of 'public health', presumably because they can't take credit for it. 

Here are the alcohol-related deaths for men and women. Scotland is the top (light blue) line.

It's worth noting that the UK as a whole has seen a decline alcohol consumption of around 18 per cent since 2004 and yet Scotland is the only part of it to have seen a significant fall in alcohol-related deaths. This implies that the fall in alcohol consumption in Scotland has been driven by heavy drinkers consuming less whereas the fall in England, Wales and Northern Ireland has been driven by moderate drinkers consuming less and more people becoming teetotal.

Looking at the actual number of deaths below, you can see that mortality increased sharply between 1993 and 2003 before falling by about 20 per cent. It has not followed drinking trends perfectly, however. Note that there was a relatively large number of deaths in 2016 despite per capita consumption being at a twenty year low.

The latest Sheffield predictions for Scotland predict that a 50p unit price will reduce consumption by 3.5% and will reduce the number of deaths by 58 in the first year and by 102 per annum after ten years. This is what the SNP and its allies have been fighting for all this time. This is the promised land.

But despite all the wild celebrations from the neo-temperance lobby yesterday, these projected outcomes are so trivial that they would get lost in the noise of the data. If there is a 3 or 4 per cent downturn in per capita consumption in the first year of minimum pricing, you could plausibly attribute it to minimum pricing, but (a) it could just as easily be part of the longer term decline, and (b) so what?

The aim of the policy is to reduce alcohol-related deaths, but if minimum pricing did 'save' 58 lives, it would be impossible to tell from looking at the numbers because they fluctuate by more than that on a regular basis. Between 2015 and 2016, for example, they rose by 115 for no obvious reason. Between 2011 and 2012 they fell by 167.

Regardless of whether the figures rise, fall or stay the same over the next few years, it is inevitable that a regression model will be published - probably by the monopoly providers at Sheffield University - claiming that there were fewer deaths than there would have been in the absence of the policy. Such a regression model will be politically driven rubbish, but even if someone made a serious attempt to create a regression model, it would be impossible because they would not be able to project future trends. Why? Because they don't know the reason for the recent trend.

The stark reality is that the projected impact of minimum pricing, exaggerated though it almost certainly is, amounts to a rounding error too small to be seen with the naked eye. Even if it does everything its advocates claim it will, the impact of this supposedly world-leading policy will be too small to measure. The policy of doing nothing and selling alcohol at 'pocket money prices' in the last decade seems to have been vastly more successful than the most optimistic projections of Sheffield's activist-academics. 

Minimum pricing can now happen before Brexit

The UK Supreme Court has said that minimum pricing is legal under the ridiculous carve out that says that free trade doesn't matter if a policy is designed to protect ‘health and life’, ’public morality’, ‘public policy’ and ‘public security’ (ie. anything). The last reason to stay in the EU has disappeared.

It doesn't really matter for the UK because we're leaving but it's a shame for other EU countries. Now all we can do is see what happens. The clowns at Sheffield University have got the commission to evaluate the policy (quelle surprise) and they will obviously say that it's been a terrific success, but some serious people should be also be able to get hold of the data.

In the meantime, I've written a quick article for Spectator Health. Do have read of it.

#AlcoholAwarenessWeek

Alcohol Awareness Week has returned for another year. It is a scheme dreamt up by the likes of Alcohol Concern to lobby for minimum pricing, tax rises and advertising bans while purporting to educate the public about drinking.

Thanks to the myriad lies of the neo-temperance movement, there is certainly room for education. Here are ten things that people deserve to know for starters...

1. The theory that underpins the neo-temperance lobby's 'whole population' approach is a demonstrably false and self-serving delusion.

2. The lowering of the drinking guidelines in the UK last year was orchestrated by a bunch of anti-alcohol zealots and relied on a model which was changed at the eleventh hour when the original model failed to support the change.

3. Moderate drinkers live longer than teetotallers, on average.

4. And that is not because of the 'sick quitter' effect.

5. Drinkers in Britain pay 40 per cent of all the alcohol duty collected in the EU.

6. Alcohol duty revenues in Britain far exceeds the costs drinking imposes on state services. Drinkers subsidise teetotallers to the tune of £8 billion a year.

7. Britain has never been a particularly heavy drinking country by the standards of other developed nations.

8. The claim that minimum pricing has worked in Canada is based entirely on one man's junk science.

9. Since 2004, per capita consumption of alcohol in the UK has fallen at its fastest rate since the 1930s and is now at the same level as in 1980.

10. Public Health England claimed last year that Britons are drinking twice as much as they were in 1980. This is because Public Health England doesn't know what it's talking about.

Plain packaging - a gift to the black market

 From Retail Express...

The first counterfeit plain packs of tobacco in the UK have been uncovered by Retail Express and trading standards departments.

Following a tip-off, Retail Express was sold a plain pack counterfeit of a premium brand by a London newsagent for £10.50. The retailer took a legitimate pack out of the gantry and swapped it out with a fake pack, while processing the card transaction.

Doug Love, Hammersmith and Fulham Trading Standards officer warned: “The quality of the counterfeits is so good, unless you know what you are looking for it is incredibly difficult to spot.”

Evidence suggests the quality and prices of the plain pack counterfeits is creating a two-tier illicit trade, with cheap smuggled and counterfeit non-plain packs, and the new plain format illicit packs often passed through at RRP.

The article mentions that the first counterfeit plain packs were uncovered by Trading Standards in July, a mere two months after the new regulations came into full effect. They were found in the north-west and are now 'heading south'. 

If organised criminals want their products on the shop shelves, they've got to be in plain packs otherwise nobody's going to buy them at full price. The great thing about plain packaging - from their perspective - is that they only need to counterfeit one pack. After that, they just need to change the name on the front (all brand names have to be displayed in the same simple font by law) and they've got a full range of brands to sell. Happy days!

Another big 'public health' win. Well done to everybody involved.

Killjoys - out now

 
I'm delighted to announce the publication of my new book, Killjoys: A Critique of Paternalism. You can download the PDF for free. Hard copies and Kindle will be available from Amazon soon. If you want it sooner the IEA are sending out free copies to anyone who donates £10 or more this month (UK and Ireland only). Incidentally, we were going to send out free Killjoy lighters out as well but it turns out that there's a law against sending lighters in the post. I rest my case.

So what's it about? You can probably work it out from the title. It's about liberty and the limits of government intervention. I start with John Stuart Mill and the mainstream economists and move on to nudge theory, coercive paternalism and 'public health' paternalism. I look at the moral and economic arguments used by the 'public health' lobby to justify interfering in people's private lives and then look at the consequences of their interventions. Finally, I provide some suggestions about how a government that respected individual liberty would regulate risky lifestyle products and behaviours.

I've written a blog post about it for the IEA and Dick Puddlecote has kindly written a rapid response after picking up the book at the launch party on Wednesday night.

Download Killjoys.

Alcohol deaths and the folly of the whole population approach

It is often claimed that there is a direct correlation between per capita alcohol consumption and alcohol-related mortality. It is also claimed that this association is causal and that rates of alcohol-related death are directly tied to overall levels of consumption.

This theory, known as the total consumption model, is said to require a 'whole population' approach to alcohol policy aimed at reducing per capita consumption as an end in itself.

This view is explicitly endorsed by the World Health Organisation:

... lowering the population mean for alcohol consumption will also predictably reduce the number of people suffering from alcohol abuse.

And it is the official policy in Scotland and Ireland. As Alcohol Focus Scotland say (emphasis in the original):

The specific outcome of the Scottish Government’s alcohol strategy is to achieve a reduction in overall alcohol consumption.

If you want to know about the history of this idea, read the IEA paper John Duffy and I wrote a few years ago. In short, the theory is only supported by correlations seen in some countries between overall consumption and alcohol-related harm. Here is a graph from Finland, for example...

And here is the USA in a paper published in 1967...

These correlations are pretty tight. Notice that there is hardly any time lag. This is true even of chronic diseases such as alcoholic liver cirrhosis because, as Terris says...

In many cases the cirrhotic process can be halted and decompensation prevented by avoiding further use of alcohol. Conversely, resumption of heavy alcohol use after a period of abstinence can decompensate a previously injured liver in a relatively short period of time.

Based on these correlations, neo-temperance campaigners such as Alcohol Focus Scotland claim that alcohol-related problems can be addressed by reducing per capita consumption. But this is like trying to make a dog happy by wagging its tail.

The fact is that alcoholics drink a disproportionately large share of the nation's alcohol. If you have fewer alcoholics, per capita consumption will decline. This alone can explain the correlation between falling alcohol consumption and falling alcohol related mortality.

But there is no reason to think that reducing per capita consumption by getting moderate drinkers to drink less or by having more teetotallers is going to have any effect on the behaviour of alcoholics. And yet, by the logic of the whole population approach, anything that reduces per capita consumption will inevitably reduce alcohol-related mortality.

Conveniently for the 'public health' lobby, this approach allows them to avoid having to get their hands dirty dealing with people who have alcohol problems. Instead, they can tinker with the guidelines and lobby for tax rises and advertising bans, none of which are likely to have any impact on dependent drinkers. Alcoholism is a complex problem and their cretinously simple 'solutions' misdiagnose the problem and are therefore doomed to failure.

One only needs to look at the relationship between alcohol consumption and alcohol deaths in different countries to see that things are far more complex than the total consumption model assumes. Here is what happened in the USA after the study mentioned above was published...

Notice how the rise in cirrhosis peaked ten years before the rise in alcohol consumption. By the time alcohol consumption started falling in the mid 1980s, rates of cirrhosis had already fallen by around 20% from their mid-70s peak.

The United Kingdom is another example. Alcohol consumption peaked in 2004 and has since fallen by 18 per cent, as this graph from the IAS shows...

By the logic of the whole population approach, alcohol-related deaths should have fallen by roughly 18 per cent since 2004 but, as data published by the ONS today show, they simply haven't. The rate of alcohol-related mortality was 11.7 per 100,000 in 2016. In 2004, it was 11.5 per 100,000. Twelve years after the peak in alcohol consumption, mortality rates are essentially unchanged.

If you take the NHS's hospital admissions data at face value (which you shouldn't), there has also been a very large increase in the number of alcohol-related hospital admissions since 2004.

Leaving the hospital data to one side, the number of deaths is essentially the same as it was before consumption starting falling. As mentioned, this lack of association cannot be put down to a time lag. There is no time lag for acute alcohol-related harm (eg. drink driving deaths) and the time lag for alcohol-related diseases is remarkably short (within a few years, as most). It is not like smoking.

There has been no relationship between consumption and mortality in Britain since 2004. Death rates went down slightly and then went up slightly while consumption fell consistently.

The correlation that is sometimes observed between these two variables is not causal. Both consumption and mortality can be dictated by a third variable. That third variable is heavy drinking and/or alcoholism. But other things can affect per capita consumption and there is no reason to believe that per capita consumption (ie. other people's drinking) will affect alcoholism.

The story in Britain since 2004 seems to be that per capita consumption has fallen without levels of alcoholism falling. There are more teetotallers, young people are drinking much less, and non-heavy drinkers seem to be drinking less. Moreover, the fall in alcohol consumption has been largely driven by a fall in beer consumption. This is potentially significant because beer is less associated with alcoholism (when epidemiologists looked at the 'paradigmatic' data for the USA shown above, they found a somewhat more convincing association when they looked only at spirits).

All of this has caused per capita consumption to fall sharply, but unfortunately it has not led to a fall in the number of alcohol-related deaths. The most obvious explanation for this is that the small minority of people who are genuinely at risk of alcohol-related mortality has not got any smaller.

Targeted interventions, rather than policies aimed at the entire population, are what is required.

Self-serving sockpuppets

Who's fault is that, I wonder?

It should be a surprise to no one that the illicit trade in tobacco is booming after several years of above-inflation tax rises and the implementation of plain packaging. Shameless as ever, state-funded anti-smoking groups are attempting to exploit the failure of their policies to feather their own nests.

The graphic above comes from Fresh North-East (100% funded by the unwitting taxpayer) who have conducted a survey showing that the majority of underage smokers acquire their tobacco from illicit sources.

55% of children aged 14 and 15 who smoke say they buy illegal tobacco from sources like "tab houses" and shops - while 73% say they have been offered illegal tobacco.

Despite the survey finding that underage smokers are far more likely to be buying tobacco from 'private addresses' (ie. tab houses) than shops, Fresh are pushing for more regulation of the legal trade in the form of licensing. They want every shop that sells tobacco to apply for a licence to do so. Crucially, they want these shops to pay for the privilege. This is entirely unnecessary. Shopkeepers who sell illicit tobacco already face large fines and can lose their alcohol license if they sell tobacco to underage consumers.

The anti-smoking lobby wants tobacco licensing for two reasons only. First, to deter shops from selling tobacco at all (which, of course, would lead to even more illicit tobacco being sold). Second, to raise revenue for themselves.

The second of these reasons has not been made explicit until today, but Fresh have now come out and said it:

Fresh is calling on the Government to introduce a licensing system for tobacco manufacturers and retailers to provide funding for improved enforcement and other measures to reduce smoking prevalence. 

By this, they mean giving money to groups such as Fresh to lobby for measures to (supposedly) reduce smoking prevalence. 

The anti-smoking lobby in Britain now exists entirely for its own sake. All of its ridiculous policies have been tried and failed. It has nothing else to offer and it is now focused on keeping the money rolling in. Other than licensing, its only other policy proposal of any note is the unworkable idea of putting a windfall tax on tobacco companies. This, again, is designed to create a trough of money for ASH et al. to get their snouts into.

This is public choice theory in action. Groups such as Fresh have made themselves obsolete and the rise of e-cigarettes has set their obsolescence in stone. They are an irrelevance. The rise of black market tobacco - which they always denied would happen - is their legacy. They have done enough damage and their self-serving industry should be shut down.

Set vaping free

Disentangling ourselves from the EU after four decades will be fiendishly complicated but some elements of Brexit are refreshingly simple and uncontroversial. The recently enforced EU regulations on e-cigarettes are a case in point. Nobody seems to know what purpose is served by limiting vapers to tiny (10ml) bottles of fluid, limiting nicotine concentrations and banning advertising in most media - to name just a few of the new laws.

Recent years have seen a mass switchover from smoking to vaping that has been a boon for consumers, small businesses and 'public health'. Britain now has the second lowest smoking rate in Europe. This all happened under a free market for e-cigarettes which no longer exists thanks to over-eager bureaucrats in Brussels. Pointless EU regulations have restricted competition, raised prices and reduced consumer choice. The advertising restrictions are so severe that it is questionable whether the government's own stop smoking campaign, which promotes vaping, is legal.

Most British MEPs did not vote for these laws. The minister in charge, Anna Soubry, was not even aware that they had been passed. When they came into effect, they were condemned in the House of Lords and an Early Day Motion was proposed in the House of Commons calling for their repeal. Public Health England says that the EU's Tobacco Products Directive - which brought the regulations into force - 'certainly raises the barrier for bringing [e-cigarette] products to market ... and will undoubtedly constrain the market'.

It is difficult to find anyone in Britain who is prepared to defend the EU on this front. If we are not prepared to repeal these unnecessary and damaging regulations after Brexit, we won't repeal anything. This is the lowest of the low-hanging fruit and plucking it is a relatively simple matter, as I explain in a new IEA report published today (Vaping Solutions: An Easy Brexit Win).

The Tobacco Products Directive should have never included regulations for non-tobacco products such as e-cigarettes in the first place. The vaping market functioned better under the relatively laissez-faire regime that preceded it than it has since. The sooner it returns to its previous state, the better for the health, prosperity and liberty of the nation.

Download the report for free.

Cross-posted at the IEA blog

Up is down in 'public health'

You may fondly recall Jill Pell, the anti-smoking campaigner who was responsible for the false claim that the rate of heart attacks fell by 17 per cent in Scotland after the smoking ban was introduced. Hospital admission statistics disprove this but that didn't stop the factoid spreading across the world. It has been cited as a fact in parliament several times.

Pell returned in 2010 with a risible attempt to prove that hospital admissions for childhood asthma fell by 18 per cent after the ban. Again, routine hospital statistics showed this to be complete nonsense.

Both studies somehow got published by the prestigious New England Journal of Medicine. Last week she returned again, this time in the rather less prestigious Tobacco Control, looking at hospital admissions for childhood respiratory tract infections (RTIs).

Awkwardly, it turns out that the number of admissions rose after the smoking ban, as this graph (from Pell's study) shows...

But this was only a minor inconvenience. In the past, Pell has managed to make it look as if admission rates were falling when they were essentially static, so it only required a bit more statistical jiggery-pokery to turn a rise into a decline. She probably enjoyed the challenge.

Here's what the data told her...

In our primary analysis, introduction of smoke-free legislation was associated with an immediate rise in acute RTI events (incidence rate ratio (IRR) 1.24, 95% CI 1.20 to 1.28) and an additional gradual increase over time (IRR 1.06 per year, 95% CI 1.05 to 1.06; table 2). This finding was consistent when upper and lower RTI events were considered separately.

Awks. At this point, Pell and her team could have decided not to publish (which, I strongly suspect, is what most 'public health' academics do when faced with such findings). Instead, they ploughed on.

We used advanced methods and followed a prespecified analytical approach—including a detailed statistical analysis plan—in an attempt to promote transparency. Despite this, our study yielded findings that were implausible and highly likely to be spurious.

Why would they be considered 'implausible'? Because...

Studies in other countries, including in the UK, previously identified consistent associations between comprehensive smoke-free legislation and subsequent reductions in paediatric RTI hospitalisations.

The problem here is that those studies are policy-based junk that directly contradict the evidence. Even if they weren't, respectable scientists don't change their conclusions to match those of other studies.

You know what is actually 'implausible'? The belief that a ban on smoking in workplaces, which mainly affected pubs, would have any effect of admissions to hospital by children under the age of 13 for a condition that is usually caused by a virus.

Building on the existing evidence base on the topic, we feel it is highly unlikely that smoke-free legislation was indeed responsible for a rise in paediatric RTI events, as our primary analyses seemed to suggest.

Nobody is arguing that the smoking ban caused RTI admissions to rise. The point is that, regardless of how Pell and her team 'feel', they did rise.

The amusing thing is that Pell et al. were clearly pleased with the rigour with which they approached this job...

Our study has a number of strengths. It was conducted according to a predefined protocol, including a detailed statistical analysis plan, which was developed a priori in an attempt to promote scientific transparency and reproducibility. We used over 10 million patient-years of high-quality data routinely collected over a 17-year period. Virtual universal availability of the CHI number minimises risks of incorrect data linkage across the datasets. We accounted for underlying temporal trends in RTI events as well as changes in population size and demographic structure. We applied a look-back period to reduce bias from RTI events occurring prior to the study period. Our modelling approach is widely applied in the evaluation of national public health interventions, including national smoke-free laws.

Then comes the punchline...

Given these strengths, the implausible findings are of considerable concern.

At which point, a sudden rethink was in order. But a further analysis still didn't come up with the goods...

In further post hoc analyses, the strength of association between timing of smoke-free legislation and acute RTI events was very similar when evaluated using a reg(S)ARIMA model of order autoregressive term multiplicative seasonal autoregressive term: IRR 1.15, 95%CI 1.02 to 1.28.

Ultimately, they resort to arguing that the smoking ban didn't cause the number of admissions to rise (which is something that nobody would seriously claim anyway)...

However, automatic break point detection suggested that the increase in acute RTI events started well before introduction of smoke-free legislation, that is, in November 2004. Using this break point rather than timing of smoke-free legislation in the primary negative binomial regression analysis indeed improved model performance as compared with the primary model. 

Phew! 

When timing of smoke-free legislation was then added to the model that included the November 2004 break point, smoke free legislation was associated with a gradual decrease in acute RTI events (IRR 0.91 per year, 95% CI 0.87 to 0.96), with no evidence of a ‘step’ change at that time.

God knows how they reached that last conclusion, but anyone who reads the abstract will see that the study shows that 'the legislation may in fact be protective', ie. that the smoking ban led to a reduction in the number of admissions for childhood respiratory infections.

I tempted to say that you couldn't make it up, but they did.

This is not the first time that 'public health' quackademics have turned a rise in hospital admissions into a decline (see the Brazilian miracle, for example), but it is the first time they have done it in such plain sight. Jill and her chums outline their methodology in detail, report their findings and then redo the whole thing because the findings go against their a priori assumptions. After redoing it, they arrive at exactly the opposite conclusion.

It is breathtaking. Is there any other field of science where researchers could do this so openly?