SUBMISSION 19
Memorandum submitted by Quaker Action
on Alcohol and Drugs
SUMMARY
This submission is made on behalf of QAAD—Quaker
Action on Alcohol and Drugs.
We welcome the concept of social responsibility
in the industry and the moves that have already been made to achieve
it.
We have some concerns about the social impact
of government proposals, particularly on children, vulnerable
people, and those who experience problems with gambling.
We have particular and specific concerns about:
(a) the fact that certain slot machines are
being categorised as acceptable for children's use;
(b) the fact that this approach is not evidence-based
and presents a poor model for the development of social responsibility
in the gambling industry;
(c ) the apparent plans to increase opportunities
for drinking alcohol and gambling;
(d) the specific proposals to allow the ordering
of alcohol on the gaming floor of casinos;
(e) the proposed increase in ambient gambling
and its effect on vulnerable groups;
(f) the lack of provision and appropriate
planning/allocation of resources for problem gamblers; and
(g) the proposal to act on important "interim
measures" in advance of the legislative process.
INTRODUCTION
Quaker Action on Alcohol and Drugs (QAAD) is
a listed group of the Religious Society of Friends—Quakers.
We are an independent national charity concerned with the use
and misuse of legal and illegal drugs, and we also have a particular
concern with gambling. We offer information services within the
Religious Society of Friends and aim to support organisations
with similar aims and objectives. Trustees give their time to
QAAD voluntarily. All have professional or voluntary experience
in the fields of the prevention or treatment of dependent behaviours.
Quakers have a long-standing testimony against
gambling, because we believe that it involves unfair gain without
effort, it fosters the idea that happiness is gained through material
possession, and because the profits of gambling are acquired at
the expense of others' loss. We endeavour to "Resist the
desire to acquire possessions or income through unethical investment,
speculation or games of chance." (Quaker Faith and Practice,
1.02.39) Quakers also testify for moderation or abstinence from
those behaviours that can cause addiction.
As Quakers we hold these principles about gambling,
but we would not wish to impose these personal choices on others.
However, we are concerned that some of the proposed changes will
fail to give sufficient protection to vulnerable groups or to
minimise problem play. We make this submission, therefore, mainly
under the fourth term of reference of the Committee—"the
social impact of the changes proposed and safeguarding of the
young and otherwise vulnerable".
SOCIAL RESPONSIBILITY
We welcome the idea of social responsibility
in the gambling industry and the moves that have already been
made towards it. We believe that at this formative stage, the
concept of social responsibility needs to be clearly outlined
and modelled, both within legislation and policy. The philosophy
and terms of reference that are developed now will largely determine
the operation of the Gambling Commission and the Gambling Trust—and
therefore of the industry as a whole. It is vital, therefore,
that the protection of the young and vulnerable is conceived clearly
and not fudged. In our view, there are three significant ways
in which the evidence-base relating to problematic gambling has
been insufficiently incorporated into government proposals. These
relate to children and gaming machines; alcohol and gambling;
and ambient gambling and vulnerable groups.
CHILDREN AND
GAMING MACHINES
There is ample evidence of the propensity of
gaming machines to cause problem play, particularly amongst children
and young people. Professor Gray's evidence to the Budd Review
explained the dependency-promoting features of slot machines and
the theoretical basis for them. He notes that certain factors
"reinforce" gambling and increase the chances of re-play
and problem play. The reinforcers for slot machines include a
short interval between bet and result, immediate opportunities
for replay, visible "near misses", and stimulating noises/lights
during play. Thus, the monetary prize is only one reinforcer amongst
several. Professor Gray states:
". . . the mode of delivery of a reinforcer
is of much greater importance in determining its power as a reinforcer
than its intrinsic nature? The razzamatazz of the fruit machine
is a brilliant piece of behavioural engineering for this purpose?
The size and quality of the reinforcer (a bigger or better piece
of food, say) is of much less importance than these design features
in determining the vigour and persistence of the reinforced behaviour?"
(Professor Jeffrey Gray's evidence, Annex G of The Budd Review,
pp 231-232).
Field research bears out the theoretical approach:
slot machines are one of the major causes of problem play, and
studies have shown that this general finding is also true for
children (Fisher, 1998; Gamcare information). Research further
shows that children have proportionately higher levels of problem
play with gambling generally than do adults—at five per
cent or six per cent as opposed to two per cent to three per cent
(Fisher, 1993; Griffiths, 1995). Studies have also shown that
the earliness of gambling onset is related to later problem use
(Ide-Smith and Lea, 1998; Fisher, 1993; Sinters, Stinchfield and
Fulkerson, 1993).
The Government proposals in "A Safe
Bet for Success" suggest separating low-stake/low prize
machines from other gaming machines into a new and distinct category.
These machines would be termed Amusement Without Prizes (AWP)—though
a £5 prize is winnable—and children would be allowed
to play them. The separation of AWPs from other gaming machines
has no validity in theoretical terms, since low prizes only modify
one "reinforcer". The conjunction of all other dependency-promoting
features is left intact. There is no theoretical basis or practical
study evidence to support the supposition that lower prizes will
reduce the problem potential of these machines for children (particularly
since £5 is not an insignificant sum to a child.) On the
contrary, the information so far runs quite counter to this supposition.
To place AWPs in a category separate from other gaming machines
is to make an artificial distinction that has no justification
in evidence. We feel extremely concerned that this strong body
of research is thus set aside by government proposals. QAAD would
like to see an evidence-based approach to policy. If children
are to be safeguarded effectively, this means that they should
not have access to any slot machines.
We appreciate that such a measure may have economic
consequences for some involved in the gaming industry, and at
worst it might cause hardship for people whose livelihoods depend
on small businesses of this nature. These matters have to be considered
with respect and care, as the terms of the Select Committee reflect.
However, it is important that these considerations are conceived
separately from the evidence-base regarding protection of the
young and vulnerable, and not confused with it. We believe, therefore,
that if immediate prevention of child access does not occur, it
would be healthier to acknowledge that evidence is not yet being
acted upon, and to make plans made for this to happen in the future.
(Effectively, this was the approach of The Budd Review in proposing
that the issue be revisited in five years—which gave the
industry notice that further protection for children was likely,
and gave it time to prepare.)
The Government's present proposals for AWP's
represent an unhelpful paradigm if the idea of social responsibility
is genuinely to be incorporated into the gambling industry. In
creating a non evidence-based distinction between AWPs and other
gaming machines, and in sanctioning such machines for children's
use, it gives out an unjustified message of safety and acceptability
to the community at large. In acting inconsistently with theory
and evidence, it sets a low and incoherent standard of social
responsibility for the Gambling Commission to follow.
There are some other proposals in "A
Safe Bet for Success" that also concern us as regards
the protection of children. The Budd Review remarked, "We
are persuaded by the weight of evidence that children and young
people are especially vulnerable to the risks of becoming problem
gamblers. This has led us to make recommendations that would reduce
their opportunities to gamble or to see others gambling."(p
90) The Government appears to endorse this stance by stating that,
"Gaming machines and children should not mix" (section
4.16, page 16). However, some proposals increase the amount of
ambient gambling to which children would be exposed. The liberal
arrangements for the siting of AWP machines is one example of
this.
The ambient gambling to which children are exposed
is also likely to be increased by "family entertainment centres"
and increased gambling in licensed venues such as pubs. It is
not entirely clear how these settings would work, but it seems
that children would be allowed on these premises, and that there
would be separate areas for adult gambling. It is hard to see
exactly how this would work in practice (whether by visual screening
or physical barriers), but in general, children would undoubtedly
become directly aware of adult gambling activity—and therefore
influenced by it. Research also indicates that the children of
problem gamblers are already more likely to develop problems themselves—and
such arrangements would tend to increase this risk. Arrangements
to prevent the access of teenagers would also be difficult to
organise effectively, since under-age drinking is already an issue.
Effective monitoring of such a system would therefore require
the allocation of long-term resources rather than sporadic "spot-checks".
Though screening might afford some protection, arrangements such
as these effectively increase ambient gambling both for children
and adults.
4.8. In the light of all these factors,
we recommend that:
— Slot machines are all classified
into a single, four category system, with the fourth category
consisting of those classed as AWPs under existing proposals.
— That none of these be available to
children.
— Failing that, that plans are made
to stop children's access within a specified period of time.
— "Ambient gambling" is not
increased, and particularly that no slot machines are sited in
non-gambling premises, or those to which children have access.
— Before there is a large expansion
in gambling in particular areas (eg Blackpool) resources are allocated
to pilot and to research effective education campaigns for children
and young people. (Learning from Dutch educational approaches
would be relevant here).
ALCOHOL AND
GAMBLING
The Budd Review accepted evidence that alcohol
increases problem play, and that heavy alcohol use is associated
with increased gambling spending and multiple gambling problems
(evidence cited on p 90 of the Budd Review). There is some research
evidence to show that even low levels of alcohol intake adversely
affect self-control in gambling (Kyngdon et al, Addiction 94 (5):
697-707, 1999). The Budd Review concluded that, "the opportunities
to mix gambling and alcohol should not be increased."
Several government proposals do not act on this
recommendation and the evidence-base that underlies it. The idea
of "family centres" and increased gambling in pubs represents
one such suggestion. Of more immediate concern is the recommendation
that alcohol be allowed on the gaming floor of casinos. Casino
playing is one of the higher risk forms of gambling. Leaving the
floor to purchase drinks is a safety measure because (i) it is
likely to slow the rate of alcohol consumption, and therefore
allow better risk assessment (ii) it allows greater opportunities
to minimise problem play by physical and emotional distancing
("reality checks") and (iii) it reduces the speed of
gambling event frequency. We are particularly concerned that the
allowing of alcohol on the gaming floor will not require a change
in legislation, and may be activated quickly without Parliamentary
debate.
We recommend that:
— The principle suggested by the Budd
Review be adopted (that is, that there be no increase in opportunities
to drink alcohol and gamble).
— The current prevention of the drinking
of alcohol on the gaming floor continues
— The possession of a licence to sell
alcohol does not lead to the entitlement to provide gambling services
(eg AWP machines; Category C gaming machines in restricted areas)
the idea of "premises within premises" for gambling
on licensed grounds is spelled out more clearly and does not proceed
except in accordance with these principles.
— Lottery terminals are not sited on
licensed premises.
VULNERABLE PEOPLE
AND "AMBIENT
GAMBLING"
There is a considerable research base that suggests
that those experiencing personal and social disadvantage are particularly
vulnerable to problem gambling. Those who show other risk behaviours
(eg illicit drug use, drinking, smoking, low school grades and
delinquency) are particularly likely to gamble, and to gamble
problematically (Proimos et al, Pediatrics 102(2): E231-E236,
1998; Ladouceur et al., Journal of Child and Adolescent Substance
Abuse 8 (4): 55-68, 1999). Studies also show that those suffering
from mental health difficulties are vulnerable (Black et al, Psychiatric
Services 49 (11): 1434-1439, 1998). Those suffering from other
forms of social deprivation/exclusion are vulnerable, and there
is some evidence that genetic or family factors predispose individuals
to problem play, and one such study concluded that, "The
increasing access to legalized gambling is likely to result in
a higher prevalence of pathological gambling behaviour among individuals
who are more vulnerable because of familial factors." (Eisen
et al, Addiction 93(9): 1375-1384, 1998).
The Budd Review accepted that an increase in
"ambient gambling"—widespread opportunities for
gambling—would be likely to increase the incidence of problem
play. It stated, "The little evidence we have indicates that
the rate of problem gambling tends to vary with the type of gambling
opportunities available and their proliferation, rather than with
the percentage of the population who participate in gambling"
(p 93).
We therefore recommend that the principle discussed
in the Budd Review be adopted, and that:
— gambling takes place in premises
for which this is the primary purpose; and
— opportunities are not increased in
other venues.
DEFICITS IN
PROVISION AND
PLANNING FOR
PROBLEM GAMBLERS
The Budd Report commented on the severe lack
of provision for problem gamblers, and noted that, "The Departments
of Health and Social Security? do not appear to recognise problem
gambling as a health issue." (The Budd Review, p 94) The
proposals of "A Safe Bet for Success" effectively
follow this institutionalised neglect. The decision not to set
targets for reducing problem use suggests that the Government
continues to view this as a very low priority. We regret that
no mention is made of any extra service provision under NHS funding,
and believe that gambling problems will continue to be allocated
few resources if they have to compete with other mental health
needs. Gambling problems are unlikely to qualify as a "mental
disorder", and "A Safe Bet for Success" only
makes mention of "the most serious cases". The vast
majority of serious gambling problems for individuals and families
would be unlikely to receive any help under this definition and
approach.
This leaves intervention to the fund provided
by the gambling industry though the proposed "Gambling Trust."
The total national annual budget suggested for this body is £3
million per annum, to cover both research and intervention. The
£3 million figure suggested by the Budd Review was based
on the provision of £10 per problem gambler—well below
the £44, £40, and £26 spent in New Zealand, Canada,
and Australia respectively (The Budd Review, p 176.) Such a figure
is highly unlikely to be adequate, and is small in relation to
the likely profits of the industry. "A Safe Bet for Success"
anticipates "an increase in net consumer expenditure
on commercial gambling of £500 million a year over a five
year period beginning in 2004-5".
We certainly welcome the initiatives the gambling
industry has shown in already raising money voluntarily for the
Gambling Commission and the Gambling Trust. However, since existing
provision is wholly inadequate and rises in problem use are almost
inevitable, far greater sums than those already suggested or allocated
will be necessary for both research and treatment. We hope the
Government will reconsider and find this a pressing consideration,
since socially disadvantaged and excluded people are likely to
experience the greatest impacts of problem use.
We therefore recommend that:
Extra, dedicated provision be available through
NHS and other relevant treatment channels (including some provided
by the voluntary sector; other dependency treatment is relevant
to service development):
— A levy-rate is set for the gambling
industry that relates to profit levels (since these are likely
to correlate broadly with prevalence and therefore with rates
of problem play).
— Combined government and gambling
industry spending equates to the amounts spent on treatment by
comparable western nations (ie at least £25 per problem gambler).
— A Research Programme is put in place
immediately (either from the £0.8 million available for the
Gambling Trust or through direct government commission). Such
a programme would monitor the changes in patterns of gambling
and problem gambling, and be used to inform policy and practice—including
the setting of appropriate targets.
— The Gambling Trust research is given
an explicit brief to monitor and report on unmet need as regards
treatment/intervention and education.
We reiterate our welcome for the promotion of
social responsibility by the gambling industry. This is a new
and developing paradigm, and it has to be acknowledged that there
may be some tension between the legitimate desire of an industry
to increase profits, and the agenda for problem prevention and
health. In order to safeguard the appearance and reality of independence,
we recommend:
— Scrutiny/review of the functioning
of the Gambling Commission and the Gambling Trust through published
government processes.
— Particular care is taken/mechanisms
exist to address the possibility of "affiliation bias"
in the research agenda of the Gambling Trust.
ADDITIONAL POINTS
The proposals as a whole leave little room for
the operation of local democracy. We believe that decisions are
best made at the most local level possible, and would prefer to
see Magistrates involved. The criteria for licensing seem likely
to be tightly controlled by centrally made guidelines: even decisions
about hours of opening would be thus restricted. We recommend
that criteria are not so tightly drawn, and allow the operation
of responsive local decisions.
We have some concerns that some of the proposed
"interim measures" involve important changes of principle,
and may pre-empt subsequent parliamentary consideration. The clearest
example relates to drinking alcohol and gambling. If alcohol were
allowed on the gaming floor of casinos, it would be difficult
for Parliament later to debate the principle of increased opportunities
for mixing drinking and gambling when the issue had already been
conceded in one important kind of venue. We are appreciative of
the fact that the approach to reform so far has been to rationalise
and integrate gambling legislation and policy into a coherent
and consistent framework. We believe, therefore, that these changes
are best considered as a whole, through the normal parliamentary
process.
REFERENCE TERM
5 OF THE
COMMITTEE: THE
NATIONAL LOTTERY
The proposal to allow Pools to offer similar
prizes and outlets to the National Lottery seems anomalous with
the philosophy of preserving its privileged status, and is likely
to undermine NL revenues. Whilst as Quakers we are not in favour
of a National Lottery, if it exists we feel that its particular
charitable status should be preserved and protected.
3 May 2002
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