Memorandum from Quaker Action on Alcohol
and Drugs (QAAD) (DGB 30)
SUMMARY
1. We welcome the idea of social responsibility
in the gambling industry, but we are concerned that some measures
in the Draft Bill do not give sufficient protection to children
and are likely to lead to an increase in problem gambling.
2. We would like to see the idea of Amusement
With Prizes machines for children discontinued. If this is not
to be the case we recommend that extra outlets and increased opportunities
for children to play these machines are not created in Family
Entertainment Centres or other venues.
3. We recommend that the opportunities for
children to see adults gambling are not increased
4. We recommend that the expansion in the
number of high-value slot machines, particularly in casinos, take
place at a limited rate and that their effects on problem play
are researched before a large-scale proliferation is allowed.
5. We recommend that a much higher level
of funding be mandated for the Gambling Commission and the Gambling
Trust in order to provide appropriate help for problem gamblers,
and that this would be most fairly achieved by a levy proportionate
to profits.
6. We recommend that the government set
clear parameters and targets regarding levels of problem play
and that the work of the Gambling Commission is developed with
reference to these.
7. We recommend that Regional and Local
planning takes account of the social consequences of gambling
and that density of gambling outlets be grounds for a refusal
to license premises.
8. We recommend that premises licences should
not be granted in close proximity to residential facilities for
proven vulnerable groups.
9. We recommend that baseline data on levels
of problem gambling are collected now, and that research concentrates
particularly on the impact of legislation on vulnerable groups.
10. We recommend that particular attention
be given to the combined effect of changes to gambling and alcohol
licensing laws; that local areas be allowed to respond flexibly
to any concerns; and that research is undertaken to monitor any
rise in the co-occurrence of gambling and alcohol problems.
1. INTRODUCTION
1.1. 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 and advice services
within the Religious Society of Friends and aim to support organisations
with similar aims and objectives. Trustees have professional or
voluntary experience in the prevention or treatment of dependent
behaviours and give their time to QAAD voluntarily. QAAD also
made a submission to the DCMS Select Committee.
1.2. 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.
1.3. These are our own principles about
gambling, but we would not wish to impose these personal choices
on others. However, we make this submission because we have some
concerns about children, vulnerable groups and problem play arising
from the Draft Bill and the accompanying policy.
2. CHILDREN
2.1. The Policy notes that, "gambling
and children do not mix": the Budd report was more explicit
in stating that the vulnerability of children to problem gambling
" . . . has led us to make recommendations that would reduce
their opportunities to gamble or to see others gambling."(p.
90)
2.2. We believe that the Draft Bill departs
from this principle by instituting the new category of Amusement
Without Prizes (AWP) slot machines for children's play. It also
seems likely that the effect of the Bill will be to increase the
opportunities for children to see others gambling.
2.3. In this connection, we have several
concerns about the proposed "Family Entertainment Centres"
which seem allowed to have unlimited numbers of Category C and
D machines under the terms of the Draft Bill. Though some similar
premises already exist, they are usually found in holiday areas:
the Draft Bill is likely to enable an increase the numbers of
gambling outlets nationally that are available to children on
a day-to-day basis. Family Entertainment Centres would provide
an environment in which gambling behaviour is modelled by adults
and mimicked by children. Since the age at which gambling begins
is correlated with problem play (Ide-smith and Lea, 1998; Fisher,
1993, 1999; Gupta and Derevensky, 1998) and children are more
prone than adults to developing problems (Fisher, 1993; Griffiths,
1990) the risks of increasing general rates of problem play amongst
children and in the next generation of young people are obvious.
The evidence that the children of problem gamblers are particularly
vulnerable to developing problems themselves is particularly significant
in relation to modelling opportunities.
2.4. Since these proposals obviously "mix
children and gambling" we would prefer to see neither of
them enacted. However, if they are, we recommend severe limitations
on the numbers of AWP machines and a definite physical and visual
separation of adult gambling areas.
2.5. There seems nothing in the Act that
will limit the numbers of Family Entertainment Centres unless
regulations are breached. We suggest, therefore, that only a controlled
number of new premises be licensed, and that their effects on
children are researched before any widespread proliferation is
permitted.
2.6. In the same context, we would also
note that the Draft Bill enables premises which undertake one
kind of gambling to readily provide another: bingo facilities
to which children may be admitted are likely to provide other
opportunities for children to gamble or to see adults doing so.
On the same grounds, we believe these measures should not proceed
and that children should not be given access to adult gambling
venues.
2.7. We hope that children's play of AWP
machines and the impact of the greater availability of gambling
on their behaviour will be early priorities for Gambling Trust
research—with thorough baseline data taken before the changes
take place. This will enable an evidence-based approach to future
policy.
3. SOCIAL PROTECTION
Provision for problem gamblers
3.1. The Policy document states "the
Government believes that the trust must take a robust attitude,
in the light of experience, to the possible need for additional
funding from the industry."(6.35) However, it is already
apparent that the funding of £3 million per annum for the
Gambling Trust is unlikely to be adequate at approximately £10
per existing problem gambler. In view of the current dearth of
provision, new services will need investment in an infrastructure,
both practically and in terms of building up a body of training
and expertise. It could be argued that previous deficits are not
the responsibility of the industry, but since it is anticipated
that an extra £500 million per annum will be spent on gambling
over the next five years (in "A Safe Bet for Success")
the proportions of expenditure to profit do not seem unfavourable.
We would like to see a figure more commensurate with the £44,
£40, and £26 per problem gambler spent in New Zealand,
Canada, and Australia respectively (The Budd Review, p. 175.)
A levy in relation to profit levels would also seem a more equitable
and proportionate way of funding the social responsibility that
the industry seems willing to espouse.
3.2. The Policy document states that the industry
will fund residential counselling for people with severe problems
that "do not impinge on the responsibilities of the National
Health Service" (6.33) and also to "support treatment
that does not engage the NHS". This seems to acknowledge
a theoretical Health responsibility for problem gambling that
does not correspond with the reality of provision. Problem gambling
per se does not fall within the terms of Mental Health legislation
and is not usually tackled by services for other addictive behaviours.
As regards primary care, training and support for providers—to
whom the first signs of problematic behaviour often present—is
desirable but at the least patchy under existing provision, even
for "at risk" groups. (US research, for example, suggests
primary care physicians should consider assessing gambling issues
with their patients who have nicotine and alcohol problems: Pasternak
et al., 1999; Cunningham-Williams et al., 1998) "A Safe Bet
for Success" makes it clear that no additional National Health
resources will be available. If the government seriously expects
the NHS (and/or the voluntary sector) to provide services, it
needs to give leadership through criteria for the provision of
services and targets for their delivery—and to allocate
resources accordingly. If state provision were not to be forthcoming,
this should be honestly acknowledged, and the demands on the industry
will need to be correspondingly higher.
The prevention or limiting of problem play
3.3. It is welcome that the Policy document
speaks of a need for the Trust and the Commission to institute
research and to advise whether there has been "a particular
aspect of liberalization that has lead to a significant or disproportionately
large increase in the level of problem gambling" (4.4.) There
are two potential areas of concern: (i) specific games or activities
(ii) a general rise in problem gambling.
(i) Specific games. The clauses in the Draft
Bill that allow large casinos to provide unlimited numbers of
slot machines, and particularly of Category A machines with large
prizes, are a serious source of concern. There is already a significant
body of evidence from other countries about the features of these
machines that cause problem play, which was acknowledged by the
Budd Report. In this context, it is important to note that prevention/education
strategies are undeveloped as regards gambling, and there is not
a strong evidence-base for the success of this kind of work in
reducing the incidence of other dependent behaviours (substance
misuse, for example). At the other end of the continuum, formal
treatment provision is scant, while research in Australia suggests
that it is very difficult to "programme out" the addictive
features of slot machines, by, for example, reducing the speed
of play (Blaszczynski, Sharpe and Walker, 2001: the only measure
in this research that showed any significance in reducing problem
play was the reduction of the stake to one dollar)
Thus, dependency problems are far easier to
unleash than to prevent or to reverse, and de-regulation of these
machines on the scale allowed by the Draft Bill seems extremely
likely to raise levels of problem play. We hope that a much more
cautious approach to the proliferation of these machines will
be adopted than that implied in the Draft Bill. A small number
of rigorously researched pilot areas would be the most logical
approach. Failing that, we recommend a more stringent approach
to the numbers of these machines allowed in each size of casino,
and that no premises should be allowed unlimited numbers. Increases
could be enabled after a timed period of research and review.
(In an American context the evidence is that: "The availability
of a casino within 50 miles [versus 50 to 250 miles] is associated
with about double the prevalence of problem and pathological gamblers
. . ." Gambling Behaviour and Impact Study. Gerstein
et al, 1999 p ix)
(ii) Problem gambling rates. The Prevalence
Survey of 2000 suggests a current UK rate of problem gambling
between 0.6 and 0.8 per cent, while the Australian rate of 2.3
per cent causes very serious levels of social concern. Given this
relatively narrow difference in absolute terms, it is necessary
to define the terms "significant" and "disproportionately
large" much more precisely (though perhaps within a percentage
range). Guidelines of this specific nature are used in other areas
of public policy as targets: this kind of explicit guidance from
government would give the GC clear parameters within which to
interpret its responsibilities. This would increase its focus,
its efficiency and its transparency. It would also embody and
enable a proactive—rather than a reactive—approach
to social responsibility and to problem play.
The Gambling Commission
3.4. The independence of the Gambling Commission
and the Gambling Trust are central. We recommend a strong and
wide representation of academic experts, representation from Gamcare
and from self-help groups—particularly in the work of the
Gambling Trust. Informed voices on problem gambling must be sufficient
to be effective rather than token, and have a significant input
in the development of Codes of Responsibility for the industry.
3.5. The effectiveness of the Codes of Responsibility
in promoting responsible practice and reducing problem gambling
should themselves be the subject of research and audit.
4. LICENSING
ISSUES
4.1. It is not entirely clear to us from
the Draft Bill and its Policy what kinds of guidance will be given
to Regional and Local Authorities and what the parameters will
be. Economic regeneration appears to be the driver for regional
policy: though this consideration is important, we believe it
should be balanced by social concerns—and that all public
planning bodies at local, regional and national level should have
responsibility to consider both economic and social impacts when
implementing and assessing this legislation.
4.2. It appears that the principles underlying
the Bill may be similar to those of the Licensing Bill for alcohol
(2003), and that Local Authorities will not have the right to
refuse a premises licence on the grounds of density or the accumulated
social impacts of multiple gambling premises. If this were to
be the case, such a limitation would have a significant effect
on the experience of "ambient gambling" in an area.
Whilst the Policy for the Draft Gambling Bill states concern that
gambling opportunities should not proliferate and change the characters
of towns, there appears to be no definite mechanism for Local
Authorities—or their residents—to register, or to
take action about, concerns of this nature. We believe that the
original recommendation of the Budd Report should be adopted,
and that Local Authorities should have the flexibility to refuse
gambling licences, on grounds that would include:
— Density of gambling premises or size
of premises (with the total availability of gambling opportunities—such
as total numbers of slot machines—as criteria).
— The feelings of local residents (if
sufficiently widespread and formally measured).
— Local data about rates of problem
play (with reference to thresholds: see paragraph 3.3 (ii), above)
— The siting of premises in proximity
to groups with proven vulnerability to problem-play: eg residential
units for looked[en rule]after children (Westphal et al.,1998);
schools; residential treatment facilities for those with gambling
problems; or for those with psychiatric problems or with drug/alcohol
dependency (Black and Moyer, 1998; Crockford and el-Guabaly, 1998;
Lesieur and Blume 1991; Griffith and Sutherland, 1998)
Additionally, we recommend that Regions or Local
Authorities be required to make an assessment of social impact
and that this be included in the returns sent to the Secretary
of State.
4.3. This Bill follows changes to the laws
involving alcohol licensing under the provisions of the new Licensing
Bill (2003). Licensing for the two leisure activities follow similar
procedures (3.62 of the Policy Document). Opportunities for gambling
and drinking alcohol will both be extended at a similar time and
in some cases in the same places. There is already significant
evidence of the co-morbidity of alcohol and gambling dependency
problems and there is a risk that both will increase as a combined
result of these changes. Once again, we suggest that local and
regional bodies are empowered to deal with problems that may arise
from this rather than disabled from doing so. We recommend that
the effects of alcohol consumption on gambling be a priority area
for research by the Gambling Trust. We also hope that evidence
will result in government willingness to use "the flexibility
available in the legislation" to review and amend these provisions
if necessary.
5. FINAL NOTES
5.1. We welcome the measures that have been
taken by the Gambling industry so far to embody social responsibility
and hope that these will be developed further.
5.2. We have been acquainted with the contents
of the submission of the Methodist Church and support its recommendations.
5.3. We wish the Committee well in its work
and would be willing to be called to give evidence.
December 2003
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