Under the influence: 2. How industry captured the science on minimum unit pricing
BMJ 2014; 348 doi: https://doi.org/10.1136/bmj.f7531 (Published 08 January 2014) Cite this as: BMJ 2014;348:f7531All rapid responses
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We are writing regarding the article by Jonathan Gornall’s in the recent issue of the BMJ. This article should never have been published in a respected academic journal, even as a feature piece, as it did not come close to the standards of scholarship that should be expected of such a journal.
Appreciation of the scientific method and the economic way of thinking
The article seems to begin with the assumption that statutory minimum unit pricing (MUP) for alcohol is self-evidently desirable and that, by implication, those who oppose it only do so out of sinister intentions guided by vested interests. This leads the author to look for financial relationships that frequently do not exist but are implied by association, rather than accept the more obvious explanation that many people sincerely disagree with the policy on grounds that are ‘evidence-based’. The feature makes no attempt whatsoever to engage in the scientific or economic debate but merely tries to undermine the process of pursuing knowledge in a scholarly fashion by disparaging the reputations of those on the other side of the debate. As such, it is worth restating the case that is made by the opponents of MUP, arguments that have simply not been addressed by the proponents.
Firstly, the idea that, ceteris paribus, higher prices tend to lead to lower consumption is not such a novel insight in economics as it appears to be in public health. It is not an observation that would lead to the publication of scholarly arguments in an economics journal-. However, the precise impact of MUP will depend on behaviour and the impact found in any model will be determined by the way the model is constructed. If social scientists tell a computer that a minimum price will reduce licit alcohol consumption and that, more controversially, this reduction will lead to better health outcomes, it is self-evident that the computer will reflect this in its estimates of ‘lives saved’. Moreover, the number of ‘lives saved’ will rise as the price rises. For those who lobby for MUP, this is sufficient information to make the policy ‘evidence-based’.
But the evidence is partial because the models are partial. They disregard, for example, the costs of the policy and the likely unintended consequences. There may be costs in terms of health if, for example, people on low incomes maintain their alcohol consumption levels, but spend less on food and heating for their family. There are likely to be substitution effects, such as the purchase of illicit alcohol or illegal drugs, which have health hazards associated with them. There will clearly be financial costs resulting from prices being artificially raised. These costs will depend on consumption levels, but they will not be trivial and they will affect people on low incomes more than those on high and middle incomes.
These are essentially the arguments that we have laid out in the IEA’s work, backed up by economic analysis. The medical establishment’s support for MUP implies that doctors are either unaware of these costs or feel them to be a price worth paying for the predicted benefits. This is a perfectly valid opinion, but it can only be a subjective evaluation of the costs and benefits. An estimate of lives saved in a partial equilibrium model can never, on its own, justify the implementation of a given policy. If this were the only consideration then there would be no limits to government intervention in almost any area of private economic and social activity. Economic decisions involve trade-offs. If public health academics wish to make a serious contribution to an economic debate, they must recognise this.
Our own opinion is that the costs and risks would outweigh the likely benefits, as they did in Denmark when a “fat tax” was briefly introduced. The government appears to have taken a similar view to our own on this occasion. We understand that this is disappointing for many readers of the BMJ, but it does not warrant the bizarre assortment of ad hominem attacks and smears that you published on 8 January.
Funding and vested interests
We trust that your readers are not surprised that an education and research charity whose mission is to promote a wider understanding of the role of markets choose to publish work in this field. Your readers will also not be surprised that the alcohol industry lobbies against MUP. Mr Gornall lists examples of companies with interests in the sale of alcohol having meetings with government departments as evidence that politicians were “under the influence” of the industry and that the pubic consultation “was a sham”. Neither conclusion follows from the evidence.
1. Nowhere does he detail the activities of the large, well-funded effort to promote MUP over a period of several years, including those of taxpayer-funded organisations such as Alcohol Concern. If there has been an imbalance in access to politicians, Mr Gornall provides no evidence for it. He merely demonstrates that those involved in one side of the debate had some access to politicians.
2. In a letter to the Telegraph that was timed to coincide with the publication of his article, various doctors complained about the industry’s “deplorable practices”, but these appear to consist of no more than holding meetings with MPs. Is the ‘public health’ lobby above engaging in such deplorable practices itself, or are meetings only deplorable when one’s opponents hold them? Do we not expect elected representatives to understand both sides of an argument before putting forward legislation which is such a significant step that it might, in fact, be illegal (see below).
3. Mr Gornall claims that the All Party Parliamentary Beer Group allows an unusual degree of access to MPs and quotes John Holmes of Sheffield University saying that drinks industry representatives use these groups as a way to “talk to lots of MPs in a way that just wouldn’t be available to any public health group.” This is simply untrue. There is an All Party Parliamentary Health Group, an All Party Parliamentary Group on Primary Care and Public Health, an All Party Parliamentary Group on Environmental Health, an All Party Parliamentary Group on Global Health and an All Party Parliamentary Group on Smoking and Health (the latter co-ordinated by the private pressure group Action on Smoking and Health), to name only five.
4. Similarly, John Holmes is quoted as saying: “We can’t really change the narrative in any way—we don’t have that power—but bodies such as the Adam Smith Institute have this public megaphone which is disproportionate to the scientific merits of what they’re saying.” This is an extraordinary comment. Nobody has had more influence over the minimum pricing debate than Holmes and his colleagues at the Sheffield alcohol unit. The findings of their computer model have been quoted on countless occasions by broadcasters, campaigners and politicians, including the Prime Minister at the start of Mr Gornall’s article. The influence of privately-funded think tanks has been trivial by comparison. This is not surprising, the annual income of the IEA is far smaller than the turnover of a typical single GP practice.
5. No evidence is provided – because none can be found – that drinks industry funding to the IEA is at all significant as a proportion of our income or that drinks industry funding is greater than, for example, funding by the retail industry who would benefit from MUP. Whilst the IEA has a policy of donor confidentiality, all public listed companies publish their donations and, as Mr Gornall implies, but does not have the courage to say, such donations to the IEA are small. Mr Gornall mentions a (presumably deplorable) meeting between Jeremy Hunt and the chief executive of Asda supermarket, saying that it “reveals the incestuous web of influence spun by think tanks and lobbying companies paid to lobby on the [alcohol] companies’ behalf.” The BMJ should provide evidence that think tanks have been “paid to lobby” or it should formally retract this slur.
6. Given that Mr Gornall wishes to imply that the funding of think tanks influences their research agenda, readers might wish to reflect on the fact that it is more than likely that the income of the BMJ is mainly from government sources and that Mr Gornall was paid to write the article that he did. We address the arguments in BMJ articles and put forward by Mr Gornall on their merits. However, those that believe that funding sources influence arguments may wish to consider that a journal that frequently promotes government solutions to social problems is largely funded by the subscriptions of government-funded universities and members who receive their salaries from the government. Mr Gornall should be even handed when discussing how funding might create bias in policy debates.
The “right-wing” slur
Whilst we acknowledge that discussions about policy can become heated, Mr Gornall goes beyond what is reasonable when he refers to the input of free market institutes as a “barrage of pseudoacademic shots from the far right”. This exceeds the limits of civilised discourse. We trust that in the cold light of day, the BMJ recognises that smearing opponents of price-fixing as fascists is disgraceful. An apology and retraction would be welcome.
The intellectual heritage of the IEA is classical liberal. The first Editorial Director was a member of the Liberal Party, though other senior staff have had a variety of political affiliations or none at all. If the phrase “far right” was used to describe an individual, a set of policies would be conjurred up in the imagination that would bear no relationship to those that IEA authors have promoted in practice. Indeed, the use of price controls and minimum prices to achieve social objectives are much closer to the policies of those that any reasonable person would regard as standing for the “far right”.
The IEA was formed because of a serious concern that over-arching central planning of the economy, that was so in fashion intellectually after the Second World War, could lead ultimately to some kind of totalitarian fascism. It is up to the reader to make a judgement about whether the continuation of the policies of the post-1945 government would have led to this result (as it did, for example, in some South American countries) but it was a sincerely held view by economic liberals and it is within that economically liberal tradition that the IEA continues to work.
MUP is an extreme policy and attempting to slur those engaged in free political debate is an extreme response to the dropping of that policy
Mr Gornall writes as if the case for MUP is self-evident. Not only are there concerns, however, about its economic effect, it is also a policy that is unusual – perhaps even extreme. There are natural concerns about economic and social freedoms as well as disputes about the economic impact that do not even seem to have been considered by Mr Gornall. However, the policy is also of doubtful legality. No country has yet adopted the system at a national level and the European Commission has repeatedly warned that it is legally unsound and limits competition.
Moreover, the policy is patently regressive and will increase the cost of living for millions. There are, then, numerous reasons why the government would perform a “U-turn” on this issue after consulting with a broad range of stakeholders. The thrust of Mr Gornall’s complaint is not that industry actors and free market think tanks have had “undue influence” over the government - whatever that may mean - but that they have had a voice at all. There is no evidence whatsoever of any wrongdoing. Think tanks voiced their opinion, businesses mobilised their customers and politicians made their minds up. It is disappointing from your perspective that the government felt that the costs outweighed the benefits on this occasion, but the grubby insinuations and factual errors in Mr Gornall’s article are beneath you.
Britain remains a putatively open society in which free speech and access to politicians and opinion-formers are available to all. As the medical establishment increasingly resorts to legislative coercion in its bid to regulate lifestyles, it can expect to encounter continued resistance from those who believe in free markets and personal liberty, including a very large proportion of the British population. On issues such as minimum pricing, we believe that you are profoundly wrong. We do, however, believe you to be sincere (point 6 above is only made to demonstrate how people who think like Mr Gornall might consider how your own vested interests would affect your views). If we are to have a mature debate about public policy, we ask that you at least recognise that we also mean what we say and address the arguments in IEA publications. Not one sentence of Mr Gornall’s article attempted to do this.
Yours sincerely,
Christopher Snowdon,
Head of Lifestyle Economics, Institute of Economic Affairs
Competing interests: No competing interests
I'm getting really worried about the way the debate on alcohol pricing has been conducted. We seem to have reached a state where we believe that gallant public health scientists are fighting the evil demons from an industry that wields enormous power over government and cares not for the health of its customers. This Manichean attitude appears to have led to some general derangement of peoples reasoning ability when judging evidence. This will not lead to good public health policies.
The BMJ more or less alleged that the government had covered up key evidence that unambiguously pointed to a minimal pricing policy. The media repeated the allegation apparently forgetting that the core conclusions of the Sheffield Model were published in 2008 and only a relatively minor update had been held back from publication. That's not much of a cover up.
Then there is a big review alleging the industry has conspired to corrupt the evidence on pricing. The tone of the argument implies we simply can't trust any opposition to the policy as most of it will have been sponsored by industry vested interests. But the idea that the public health evidence in uniquely virtuous compared to anything presented by industry is deeply flawed. We should judge arguments on their merit not their sponsor. After all the Sheffield study was initiated by (and its content influenced by) the previous Chief Medical Officer who wanted a nice headline-grabbing policy before he retired.
Gornall's general desire to rubbish any criticism of minimal pricing leads him to confuse important critiques which are essentially political and moral arguments not critiques of the evidence. Jamie White's "Quack Science" paper is a powerful argument against the idea that government knows best and can only make us good by coercion. It is good to be reminded that the idea we only ever behave virtuously when an angelic government makes us do so is the first step to an Orwellian nightmare. There is an important political and moral argument here that should not be casually dismissed because of a tenuous association with industry lobbying.
No doubt we should be wary of that self-serving industry lobbying. But the effect of demonizing industry seems to have made many people entirely credulous about what anti-alcohol campaigners argue. So they accept that the Sheffield model and the Canadian evidence on minimal pricing is extremely robust, unambiguous, reliable and applicable to current English circumstances. And they believe this more because the industry doesn't like it. We don't need, it seems, to be skeptical about the quality of evidence. It is produced by the angels in public health and opposed by the evil industry. But the evidence isn't that good or that reliable as people like me have argued since it was first published (and I'm not sponsored by the booze pushers).
But the most disturbing thing of all is that the lack of critical thinking about minimal pricing has led to a widespread belief that minimal pricing is a magic bullet for the problems of alcohol abuse. But alcohol abuse is a deeply rooted social problem built on long standing attitudes and behaviors. These change slowly and most are not addressed by minimal pricing (some might even get worse). Instead of thinking about a range of policies designed to improve those deeply embedded attitudes over time and thereby drive significant sustainable change we are grasping at a headline grabbing but probably ineffective magic bullet.
We are also guilty of ignoring important signals of changed behavior because the anti-alcohol lobby can't readily fit them into its model where people only regulate their consumption when forced to do so by government. Alcohol consumption and risky behavior have actually fallen substantially in England in the last decade, even in the young. But these facts are rarely discussed as they would undermine lobbying for further restrictions on booze like minimal pricing.
The campaign for minimal pricing promises a magic bullet to solve problems and distracts us from harder, less headline-grabbing policies that will have more effect in the long term. An it makes us uncritical when judging evidence. None of this is good for public health.
Competing interests: Drinks alcohol, builds models but doesn't trust them.
Re: Under the influence: 2. How industry captured the science on minimum unit pricing
Christopher Snowdon’s first response to my series of articles about the influence of the alcohol industry on public health policy was published on his blog, “Velvet Glove, Iron Fist”, on January 9, and I thank him for taking the trouble to bring his interesting views to the attention of a wider audience. Any reader of the BMJ interested in learning more about Mr Snowdon’s agenda should certainly visit his entertaining blog. [1]
I also recommend a visit to the website of the Institute of Economic Affairs, for which Mr Snowdon works as Head of Lifestyle Economics. There, he sets out his position on public-health interventions with impressive clarity:
“If market liberals stand idly by as the state sets prices, restricts commercial speech and demonises industries (and their customers), they will stand for anything. Under the pretext of ‘public health’, basic levers of competition—price, content and marketing—are increasingly falling under state control. With the advent of minimum pricing and plain packaging, the possibility of the government dictating how much a product sells for and what it looks like has become very real.” [2]
In his Rapid Response, Mr Snowdon expresses concern that my article “seems to begin with the assumption that statutory minimum unit pricing (MUP) for alcohol is self-evidently desirable and that, by implication, those who oppose it only do so out of sinister intentions guided by vested interests”.
Actually, the article began with the fact that the government had decided that MUP was the right thing to do and that this public-interest decision, taken by a democratically elected body, was overturned by vested commercial interests, supported by organisations such as the IEA and the Adam Smith Institute operating in pursuit of an ideological agenda.
As Mr Snowdon points out, my article did indeed make “no attempt whatsoever to engage in the scientific or economic debate”. That was not its remit. At issue was the influence of the alcohol industry on a government not only too weak and timid to stand up for a public health policy it had already acknowledged would save lives - a conclusion based on research it and its predecessor had commissioned - but also sufficienty two-faced to ignore the evidence generated by that research.
I leave the debate on the merits of minimum pricing to those who know what they are talking about. Anyone wishing to form their own opinion about the related merits of Mr Snowdon’s critique of Sheffield’s work should read his co-authored paper, “The minimal evidence for minimum pricing”, written for the Adam Smith Institute,[3] followed by Sheffield’s public response to it. [4]
The BMJ’s readers will of course have been well aware that the alcohol industry sought to lobby against minimum pricing. As readers will have also known, the industry is fully entitled to do so and, in the interests of its shareholders, legally obliged to do what it can to maintain dividends (and please let’s be clear that its motivation in this case was nothing other than a desire to preserve profits).
Such surprise as the article invited was reserved for a government which, having committed itself to minimum pricing in its published Alcohol Strategy, then reversed its position under pressure from the alcohol industry at a time when it was supposedly consulting only on the level at which MUP should be set. This apparently shameless about-face revealed the extent of the influence the industry has over government, and the hopelessness of the public health lobby’s position in the face of it, no matter how many meetings it might have with ministers or officials.
Mr Snowdon implies that the opposition to minimum pricing mounted by him and the Institute of Economic Affairs was based predominantly if not exclusively on their carefully considered, scholarly conclusion that the policy was flawed. It is clear, however, that Mr Snowdon and his colleagues are ideologically opposed to any kind of public health intervention on principle, whether or not the measure in question might achieve the intended effect of alleviating harm and saving lives.
This was the IEA’s director-general, Mark Littlewood, writing on the occasion of Mr Snowdon’s appointment as its Head of Lifestyle Economics:
“Barely a day now goes past without the unveiling of some new proposal to limit, restrict or further regulate the consumer choices in our economy. An entire industry has developed to press the government to roll out a seemingly endless raft of initiatives, typically justified by appeals to public health, looking after vulnerable adults or protecting minors ... Through detailed research, we will be seeking to show that free market mechanisms produce better outcomes than heavy-handed and restrictive state regulation." [5]
If, as this appears to suggest, the IEA embarks on each piece of research with its key conclusion fully formed - that free-market outcomes are always the best - application of the most basic principles of research methodology invites one to conclude that its entire body of “research” must be fatally biased.
Do “free market mechanisms produce better outcomes than heavy-handed and restrictive state regulation”? It would seem reasonable, and unbiased, to answer “sometimes, perhaps”, rather than “always, of course” - not least when one considers which of these two mechanisms has been responsible for some of the great public health advances of modern times. Thankfully, successive UK governments of various political persuasions have chosen not to wait for company shareholders to vote to deal with polluted air, foul water, untreated sewage, poisonous food, rickets or toxic work environments, nor to rely upon them to introduce drink-driving laws, seat belts in cars and a public environment free from the dangers of second-hand tobacco smoke.
In considering the opposition of the IEA and others of its ilk to the policy of minimum pricing, one can’t help wondering which if any of these earlier initiatives might have met with their support. On a broader point, let us not forget that the cherished principle of personal freedom for which organisations such as the IEA fight so tirelessly is defended with no apparent regard for the costs paid by society as a whole in order that such frequently selfish freedoms may be exercised.
As for whether or not the IEA is supported financially by the alcohol industry, one can only speculate, because it isn’t saying. On its website it says it is “entirely funded by voluntary donations from individuals, companies and foundations who want to support its work” and respects the privacy of those who do. However, the credibility of the IEA’s long history of pronouncements in favour of the commercial interests of the tobacco industry - which, in the organisation’s opposition to plain packaging, continues to this day [6] - can be best assessed by reference to the Legacy Tobacco Documents Library maintained by the University of California, San Francisco, which contains an interesting historical record of British American Tobacco’s financial support of the institute during the Eighties and Nineties. [7]
Among the documents is an internal BAT note written for the chairman's policy committee in May of 1987. It reveals that the IEA went cap in hand to the tobacco company seeking a contribution towards the £600 000 it needed to buy the freehold of 2 North Street, the Westminster building that remains its home to this day. BAT, along with other major companies including Glaxo and BP, gave money, though perhaps not as generously as the institute had hoped. [8] The IEA's insistence that it receives no corporate donations "tied to policy areas or outcomes" [9] bears no scrutiny, given that its mission of "expounding the role of markets in solving economic and social problems" [10] dovetails so perfectly with the desire of big business interests to be spared profit-hampering interventions such as minimum pricing. But, installed as it is in the home that Big Tobacco et al helped to pay for, it is impossible to take seriously the IEA's claim that it has ever been "independent of … vested interests".
[1] http://velvetgloveironfist.blogspot.co.uk/2014/01/the-bmj-sour-grapes-an...
[2] http://www.iea.org.uk/lifestyle-economics/about
[3] http://www.adamsmith.org/sites/default/files/research/files/ASI_SAPM.pdf
[4] http://www.sheffield.ac.uk/polopoly_fs/1.247802!/file/sargrespadamsmith.pdf
[5] http://www.iea.org.uk/lifestyle-economics
[6] http://www.iea.org.uk/in-the-media/press-release/iea-response-to-governm...
[7] http://legacy.library.ucsf.edu
[8] http://legacy.library.ucsf.edu/tid/omo20a99/pdf?search=%22institute%20of...
[9] http://www.iea.org.uk/support-us
[10] http://www.iea.org.uk/about
Competing interests: I am the author of Under the Influence, the BMJ series examining the influence of the alcohol industry on public health policy in Europe and the UK.