Supplementary memorandum from the Royal
College of Psychiatrists (DGB 128)
1. The Royal College of Psychiatrists is
the statutory body responsible for the supervision of the training
and accreditation of psychiatrists in Great Britain and for providing
guidelines and advice regarding the treatment, care and prevention
of mental and behavioural disorders.
2. The Royal College of Psychiatrists submitted
evidence to the Joint Committee on the Draft Gambling Bill in
December 2003. As requested by the Committee, The Royal College
now presents this further submission regarding the proposed changes
in the legislation controlling gambling in Britain and their likely
impact on the incidence of pathological gambling.
3. The Royal College of Psychiatrists is
concerned that the recently released documents and the evidence
presented to the Joint Committee by the Government highlight once
again the fact that the Government has failed to address a specific
issue. In so far as commercial considerations are given pre-eminence
in the formulation of public policy on gambling, social aspects
will go by default.
4. This is well illustrated by the document
dealing with the "Competition AssessmentThe Casino
Market" in paras 52 to 54 on "Effects of proposed regulation
on competitionMarket Structure". In this, an attempt
is made to justify the proposal that larger casinos will be allowed
unlimited numbers of gaming machines as follows:
"Because of the profitability (Our emphasis)
of operating machines this proposal, taken together with the question
of the planning system, will favour the establishment of large
casinos which may be part of a wider entertainment or holiday
destination offer. It is known that large foreign companies have
already expressed an interest in establishing such facilities
in Great Britain."
5. It is significant that, in relation to
this, reference is made in a footnote to MGM Mirage, an American
company that is hoping to develop casinos in Great Britain. The
CIO of this company was reported by CNN on 3 July 2001, advocating
loyalty cards and saying,
"Our target is mass-producing a high-roller
experience for the common person. We want to provide you with
the best experience imaginable, so that you'll want to come back."
6. Yet, the Minister, in comments at the
Joint Committee Hearing on 16 December 2003, commended loyalty
cards because he thought that they
". . . could be helpful in the control of
problem gambling (our emphasis); it could be helpful in identifying
the effects of gambling on individuals and communities".
7. "The profitability of operating
machines" (para 4) is directly related to the fact that gaming
machines are the most likely form of gambling to lead to excess.
Nevertheless, larger casinos are to be allowed to have unlimited
numbers of gaming machines to attract promoters. The situation
is then compounded by suggesting that loyalty cards, which are
a device to stimulate gambling, can help to control "problem
8. The Royal College of Psychiatrists is
concerned that the Government's prime considerations in these
matters are clearly commercial ones, with no serious thought for
the social consequences.
9. In reply to a question (Q111) at the
Joint Committee hearing on 16 December 2003 "about the `anomaly'
of under-age gambling on machines in Britain", the Minister
". . . most Category D amusement
(our emphasis) machines could be classified as machines in which
there is a substantial element of skill. For example, a few months
ago we agreed that crane machines could be classified as machines
with a substantial element of skill."
10. The Minister clearly chose to concentrate
on the dubious concept of "amusement-with-prizes" (AWP),
which is not used in the Draft Gambling Bill and omitted to mention
that in the "Explanatory Notes" (Cm 6014II),
in para 108, it states that,
"Children and young persons may both use
the category of gaming (our emphasis) machine with the
lowest stakes and prizes (category D)."
11. He went on to say,
"I think those who want to abolish what
has existed for many years would have to do a bit of research
and show what harm they are doing before we will be convinced
that we should cut out this business."
12. The Minister's reply therefore was quite
clearly disingenuous. As far as research showing the harm that
results from children playing any type of gaming machine is concerned,
this was established in the 1980s (Moran, E. Report on fruit
machine gambling among schoolchildren, 1987). There has been
substantial research evidence since then ro confirm this.
13. It has been firmly established that
all gaming machines, regardless of the size of the stake or the
amount of prize money, are unsuitable for children and young people.
The Royal College of Psychiatrists strongly recommends that they
should cease to be made legally available to them.
14. The Government has adopted a rather
simplistic attitude to remote gambling. Once again, its preoccupation
is with the need for commercial organisations to be allowed to
maximise their revenues, at the expense of social issues.
15. The draft legislation clearly recognises
that many of the facilities for remote gambling emanate from outside
Great Britain and, under para 16 of Policy Note 6 Advertising
of Gambling, advertising such facilities will be prohibited. However,
there is no provision for even attempting to control access to
such overseas web sites, interactive television programmes and
mobile phone promotions, many of which fleece the punters. This
seems to be based on the notion that the Internet and other similar
types of technology, such as interactive television and mobile
phone messages originating from abroad, cannot be controlled.
16. However, the Government is fully conversant
with the fact that these technologies can be and are being directed
from abroad in a very destructive manner by those involved not
only in promoting gambling but also in advertising, junk emails,
pornography, hate campaigns, paedophilia. Eventually, supranational
bodies will be obliged to grapple more realistically with the
regulation of these technologies.
17. In the meantime, the matter could be
dealt with by placing greater responsibility on the conduits for
remote gambling. This would include Internet Service Providers
and interactive television and mobile telephone providers.
18. The details of this need to be worked
out by the Gambling Commission, but the basis must be incorporated
in the legislation. Otherwise, the increase in pathological gambling
from remote gambling is likely to be considerable. It will not
be dealt with by "warning" messages or advice about
"treatment" for excess (see para 21 below).
19. The Government clearly recognises that
commercial gaming, with its rapid turnover, is the most likely
form of gambling to be taken to excess. It is therefore appropriate
that the proposed legislation maintains the ban on credit for
gaming in casinos and prohibits the use of credit cards in gaming
20. It is therefore highly anomalous that
the use of credit cards will be allowed for remote gambling. This
way of dealing with the situation is wholly undesirable since
payments should be made by dedicated smart cards.
21. There is no doubt that, if the proposed
changes are implemented, there will be a considerable increase
in pathological gambling. The suggestion that this can all be
dealt with adequately by setting up treatment facilities is a
chimera. The draft legislation clearly envisages major expansion
in all types of gambling with inevitable increased participation
throughout the community. In such a setting, it is unrealistic
to expect "treatment" to deal with all the harm resulting
from this activity, which by its very nature is liable to be taken
to excess. This is especially so if, as is likely to be the case,
commercial pressures will encourage continued and increased participation.
22. It is vital that social considerations
should be given much higher priority than is provided in the Draft