What's the evidence for destroying the pub trade?

In its efforts to justify carpet-bombing the nation’s pubs, Sage have cobbled together a handful of studies to give it the veneer of science. None of the studies suggest that pubs or bars are uniquely dangerous, many of them don’t mention pubs or bars at all, and most of them involve outbreaks in Asia in the early days of the pandemic when there was little or no social distancing. 

Sage refuse to acknowledge the drop in infections in places like Manchester and Newcastle under the old Tier 2 rules. They do not even attempt to justify the plan to require meals to be served with drinks. This policy alone will lead to the unnecessary closure of thousands of ‘wet pubs’ and other licensed venues, such as snooker halls and casinos. Businesses which could be operating safely will be forced to furlough their workforce and accept government grants to stand idle. Who benefits from such wilful destruction? 

I've been looking at the evidence...   

The new tier system will close or severely incapacitate pubs in the 99% of the country that will be in Tiers 2 and 3. This amounts to carpet bombing the pub trade. Some 25,000 hospitality venues have closed permanently this year and 30,000 have yet to reopen. Although grants are available to businesses that are rendered temporarily unviable by the tier restrictions, these often fall short of what is needed to pay rent, debt, taxes and other costs.

Since the hospitality industry is Britain’s third biggest employer, with 3.2 million workers before the pandemic hit, you might expect the Government’s evidence to be strong. It is anything but. On Friday, the Government published a short policy paper titled ‘Transmission risk in the hospitality sector’ which ignores all the counter-measures introduced to make hospitality venues low-risk, and relies on a handful of studies cobbled together by SAGE which have no relevance to the British pub trade as it currently operates.

 

Read the rest at CAP{X (no paywall) and read my updated IEA briefing paper about pubs and COVID-19.

An awkward study about minimum pricing

There's a study about minimum pricing in pre-print at the Lancet looking at the impact of minimum pricing on alcohol-related A & E attendances. A glance at its (many) authors suggests that they were hoping to find a drop in attendances after minimum pricing was introduced.

Alas for them, they didn't.

The study looks at 8,746 people who attended A & E in Glasgow, Edinburgh, Liverpool and Sheffield, the latter two being the control groups. All the subjects were interviewed by nurses and the study looks at the 'changes in the proportion of attendees with alcohol-related attendance in Scotland and England before and after the introduction of the MUP'.   

They found that the trend was stable in Scotland but fell in England. Awkward. They also found that binge-drinking among A & E attendees rose in Scotland but decreased in England. Oops. Furthermore...

Based on marginal analysis, it is estimated that an additional 1.0% (95% CI -0.7% to 2.7%) of the ED [emergency department] attendances were alcohol-related than would have been the case in the absence of MUP.

We estimated that approximately 258 attendances at ED were alcohol-related as a result of the introduction of MUP (95% CI -191 to 707).

 

Here's how this looks in graphs:

 

The real fun comes when the authors try to dismiss and downplay their own findings.

 

In summary, we did not find evidence for the introduction of MUP in Scotland impacting on alcohol-related harms within the ED setting. 

 

You did though, didn't you? Just nor in the direction you expected.

However, the broader evidence base is more consistent with an effect of MUP on both alcohol consumption and harms.

 

Ah, the broader evidence base! The one that consists of theoretical models and wishful thinking. 

This study is part of a wider evaluation programme coordinated by Public Health Scotland to inform the decision by the Scottish Parliament as to whether they will vote for MUP to continue following the sixth year of implementation. Therefore, we should interpret the results with caution and should not draw conclusions regarding the wider societal impact of MUP on alcohol harm purely based on this study.

 

Can you imagine them saying this if the study had found that minimum pricing was associated with a decline in alcohol-related A & E attendances? Such uncharacteristic humility! But at least they're honest about why they're being so modest - it's pure politics.

It will be interesting to see how this study looks once the reviewers have stuck their oar in - or if the Lancet decides not to publish such an inconvenient piece of research after all.

Alcohol-related deaths fall in Scotland

Last week, I reported that Scotland's alcohol-related hospital admissions rose in 2018 and barely moved in 2019. This is noteworthy because minimum pricing was introduced in May 2018 and was supposed to reduce them. 

Yesterday, the National Records of Scotland published the alcohol-related mortality statistics for 2019 and it's better news for minimum pricing advocates. After rising in 2018, the number of deaths fell in 2019, from 1,136 to 1,020. Naturally, the Scottish Government and its pressure groups are chalking this up as a win, and 2019 has been hastily redefined as 'the first year of minimum pricing'. 

 

The decline represents a 9% fall since 2017 or a 10% fall since 2018, depending on how you look at it. This is by no means unprecedented. Numbers fell by 10% in 2006-07 and in 2008-09, and by 15% in 2011-12. Nevertheless, it at least consistent with the view that minimum pricing reduces alcohol-related mortality. If the numbers had risen again, it would have been difficult for the temperance lobby to claim success.

Pete Whitehouse, director of Statistical Services says...

 

"...although an annual decrease of this magnitude is notable, further data will be required to see if this reduction continues and whether we will see a sustained shift in alcohol-specific deaths in Scotland.”

The Sheffield model predicts that alcohol-related deaths will keep falling and Peter Rice, chair of Scottish Health Action on Alcohol Problems, is quite sure that there will. He says "we would expect even bigger decreases in years two and three."

 

We'll see about that. We'll also see what happened in England in 2019 when the figures for the rest of Britain are published next month. When I got hold of the monthly figures for 2018, I found that there was a 7% decline in alcohol-related deaths in Scotland between May and December. On the face of it, it looked like minimum pricing was having an impact, but it turned out that England and Wales also saw a 7% decline in the same period.   

Watch this space.

Silly Sally Davies

Former Chief Medical Officer Sally Davies reared her head again last week (she ha a book out). She's still obsessed with food portion sizes. I wrote about it for Cap-X...

 

Public trust in the Chief Medical Officer, Chris Whitty, may have taken a knock during the pandemic, but the Government was fortunate to have a relative unknown in the post when the daily briefings began in March. How much worse it would have been for the credibility of official health advice if his predecessor, Professor Dame Sally Davies, had still been in charge.

 

Have a read.

The future of pubs, if they have one

I'm chairing an online panel discussion tonight about how to get the hospitality industry reopened and how to keep it open. The government seems to have taken the view that COVID-19 is an alcohol-related disease and pubs are the vector. 

The psychotic charlatans at SAGE appear to want a permanent lockdown so Boris Johnson's solemn promise to reopen the economy on 2 December can't be taken too seriously. How many pubs, hotels and restaurants will the government sacrifice in the next months?

We've got a great panel, including Dehenna Davison MP (Conservative Member of Parliament for Bishop Auckland), Tim Martin (Chairman, JD Wetherspoon), Dan Mobley (Corporate Relations Director, Diageo) and Kate Nicholls (Chief Executive Officer, UK Hospitality).

Tune in on YouTube at 6.30pm. If you miss it, the video should be below later.

Another minimum pricing fail

Lockdowns and pub closures are going to play havoc with the minimum pricing evaluation in 2020/21, but we will still have two years of data with which to assess the policy. Today saw the publication of alcohol-related hospital admission figures for 2019/20 in Scotland. As with the previous year's figures, they give supporters of minimum pricing nothing to cheer.

 

 

 

The most recent edition of the Sheffield model predicted 1,299 fewer admissions in the first year (a decline of around 4%), rising year-on-year thereafter.

 

The prediction for the first year fell flat, with the number of admissions rising from 35,544 to 35,712 between 2017/18 and 2018/19. To be fair, minimum pricing was introduced in May so one of the 2018/19 months was pre-MUP, but the number of admissions rose again - to 35,781 - in 2019/20, so that is no excuse. 

Adjusted for population, the rate has dropped very slightly, from 668.8 per 100,000 people in 2017/18 to 666.6 per 100,000 people in 2019/20; a decline of 0.3% in two years.

Not quite the game-changing policy we were led to believe, then. And it is costing Scottish consumers tens of millions of pounds a year.

Boris's bonkers food advertising ban

The government has published its consultation on banning online advertising for so-called 'junk food'. Once again, civil servants have been put in the position of having to turn a simplistic idea from the 'public health' lobby into a workable policy. It's an impossible job. The idea was sold to politicians as a way of reducing children's 'exposure' to KFC and McDonald's adverts, but there is no way of clamping down on food that snobs don't like without impacting food that most people consider normal, even healthy. Nor is there a way of sticking it to big business without sticking it to small business (as the hilarious Farmdrop episode showed).

 

Since the Farmdrop farce, the government has slightly amended its definition of 'junk food' for the purpose of its new bans. Instead of including all HFSS (high in fat, sugar or salt) food, it now intends to include all foods that are classified as HFSS and are part of Public Health England's food reformulation programmes. This excludes a few products that cannot possibly be reformulated, such as olive oil and raisins, but not many.

 

The sugar reduction programme includes pretty much anything with added sugar in it: cakes, biscuits, jam, pastries, ice cream, yoghurts, cereals, desserts, etc. while the calorie reduction programme includes:

 

•bread with additions (eg olives, cheese etc.)

•crisps and savoury snacks

•savoury biscuits, crackers and crispbreads

•potato products (eg chips, croquettes, mashed potato etc.)

•sausages (raw and cooked) and sausage meat products, frankfurters and hotdogs, burgers

•meat, fish and vegetarian pastry pies and other pastry products

•cooking sauces and pastes

•table sauces and dressings

•pasta/rice/noodles with added ingredients and flavours

•ready meals with carbohydrate accompaniment (potato, rice, noodles, pasta, etc.) – fish, meat and meat alternatives

•meal centres without carbohydrate accompaniment (potato, rice, noodles, pasta, etc.) – fish, meat and meat alternatives

•prepared dips and composite salads as meal accompaniments (eg. coleslaw, potato salad, guacamole, salsa etc.)

•pizza

•egg products/dishes (eg quiche)

• food to go eg sandwiches, boxed main meal salads etc

 

Quite extensive, then. 

The government originally planned to ban the promotion of these products online before 9pm, but it has now decided to ban it entirely. So if you make sausages, pies, jam or cakes for a living, how do you market your wares on the primary advertising medium of the 21st century?

You won't be able to, basically. The ad ban being proposed is more extensive than anything tried elsewhere in the world. It covers all social media, all commercial websites and even your own website, emails and text messages.

 

The scope of the restriction would include, but is not limited to, for example:

• commercial email, commercial text messaging and other messaging services
• marketers' activities in non-paid for space, for example on their website and on social media, where the marketer has editorial and/or financial control over the content
• online display ads in paid-for space (including banner ads and pre/mid-roll video ads)
• paid-for search listings; preferential listings on price comparison sites
• viral advertisements (where content is considered to have been created by the marketer or a third party paid by the marketer or acting under the editorial control of the marketer, with the specific intention of being widely shared. Not content solely on the grounds it has gone viral)
• paid-for advertisements on social media channels - native content, influencers etc
• in-game advertisements
• commercial classified advertisements
• advertisements which are pushed electronically to devices
• advertisements distributed through web widgets
• in-app advertising or apps intended to advertise
• advergames
• advertorials

If you're in the wedding cake business, for example, you can forget about putting a banner ad on the website of your local newspaper. If you run a café and want to email your customers about your tasty desserts, you won't be able to. If you own a bakery and want to climb the Google search results for 'cakes' in your area, you'll be breaking the law.

It is extraordinary that the government is proposing a ban on companies advertising on their own websites and in their own emails. However, it has benevolently offered an exemption for 'factual claims'.

We recognise that companies should be able to make available factual information about their products. Therefore we propose that advertisers remain able to feature such information on their own websites or other non-paid-for space online under their control, including their own social media channels.

We consider that factual claims include but are not limited to:

• the names of products
• nutritional information
• price statements
• product ingredients
• name and contact details of the advertiser
• provenance of ingredients
• health warnings and serving recommendations
• availability or location of products
• corporate information on, for example, the sales performance of a product

 

This is rather like France's alcohol advertising ban which allows a certain amount of advertising so long as the copy is limited to the name, price and origin of the product. A factual claim, such as a list of ingredients, is distinct from a promotional claim, such as 'delicious' or 'bargain'. The latter will be banned under the Conservatives, the alleged party of business. On commercial platforms, even factual claims will be banned.

 

The government seems to have been inspired by the EU's ban on e-cigarette advertising under which "factual claims about products [are] permitted on marketers’ own websites and, in certain circumstances, in other non-paid-for space online under the marketer’s control." The consultation document acknowledges the "regulatory challenges arising from having to make a distinction between factual claims and promotional claims" and explicitly mentions the e-cigarette ad ban and several Advertising Standards Authority rulings that have resulted from it. It is worth reading those rulings if you want an idea of how strict the rules on food advertising are going to be. 

 

The government is shafting broadcasters with its TV advertising ban and now it is shafting online platforms and countless food producers up and down the country. And for what? The government hasn't produced an Impact Assessment for the round-the-clock online ad ban, but its previous Impact Assessment estimated that an online ban between 5.30am and 9pm would reduce children's energy intake by 0.3 calories per day - and even that pathetic outcome is based on junk science from proponents of the ban.

 

This is madness. I don't know how the government have allowed this to snowball like it has, but it's their problem now. It is a mess of their own making. They allowed policy to be formulated by fanatical single-issue pressure groups and this is the dog's dinner they've been left with.

 

 

UPDATE

Contrary to what I said above, the government has produced a new Impact Assessment. Conveniently, the Department of Health claims to have dramatically underestimated the amount of HFSS advertising seen by kids in its previous Impact Assessment. 

We now estimate around 15.1 billion child HFSS impressions online in the UK in 2019, up from our original estimate of 0.7 billion in 2017. This significant uplift is due to methodological changes in how the size of the online is estimated.

 

This allows the government to increase the putative benefit of the policy. Whereas before it claimed that children would reduce their energy intake by a risible 0.3 calories a day, it now claims the online ban will reduce it by a negligible 2.8 calories a day.

Whether they underestimated this 'exposure' by 90 per cent last time of have inflated it twenty-fold this time, it doesn't inspire much confidence in the Department of Health's competence.

(The government has also slightly increased its estimate of how many calories kids consume as a result of seeing HFSS ads, even though there is no decent evidence that they consume any more and the studies that they do are low quality. The meta-analysis the government is relying on is garbage.)

Last Orders with Dan Hannan

The new episode of Last Orders features Daniel Hannan. We discuss the evidence-free second lockdown, Scotland's clampdown on free speech and Brexit.

Listen here.

Why does the government hate pubs?

For some reason, the government has decided to ban pubs from selling takeaway alcohol in Lockdown 2. When asked about this is parliament yesterday, Boris Johnson gave a weak answer that suggests he was winging it. 

 

Boris Johnson says a number of measures are needed to reduce the infection rate and adds "when you start unpicking one bit a lot of the rest of it comes out".

 

It's another senseless attacks on pubs. I've written about it for the Morning Advertiser and argue that it's time for MPs to be barred. Have a read.

Some sensible and realistic Brexit reforms

The New Nicotine Alliance has written to Jo Churchill (public health minister) and Munira Mirza (director of the No 10 Policy Unit) calling for some sensible reforms once Britain is no longer tied to EU rules next year. They are as follows: 

1. Lift the ban on oral tobacco (snus) and properly regulate all smokeless tobacco

2. Raise the limit on nicotine concentration in vaping liquids to allow vaping products to compete more effectively with cigarettes

3. Replace bans on advertising of vaping products on TV, radio, internet and in publications with controls on themes and placement

4. Replace blanket bans on advertising of low-risk tobacco products with controls on themes and placement

5. Replace excessive and inappropriate warnings on vaping products with risk communications that encourage smokers to try switching

6. Replace excessive and inappropriate warnings on non-combustible tobacco products

7. Allow and enable candid communication of relative risk to consumers

8. Adopt a fresh approach to pack inserts for both vaping products and cigarettes to encourage switching to lower risk products

9. Remove wasteful restrictions on vaping product tank and e-liquid container size that have no discernible purpose

10. Recognise and regulate novel oral nicotine products

Nothing to disagree with there. I would only add that the government should also get rid of the (UK) legislation that bans retailers from suggesting reduced risk products to smokers. I only became aware of this law recently. Presumably, it was introduced to stop retailers encouraging people to take up 'light' cigarettes. At the very least, it could be redrafted to ensure shopkeepers don't get in trouble for recommending vapes, heated tobacco, snus etc. to confirmed smokers.

The NNA fleshes out the rationale for these reforms at length in its letter which you can read here.