Costs of minimum alcohol pricing would outweigh benefits
BMJ 2014; 348 doi: https://doi.org/10.1136/bmj.g1572 (Published 19 February 2014) Cite this as: BMJ 2014;348:g1572
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In his response to the BMJ’s ‘Under the Influence’ series, Christopher Snowdon makes a series of misleading and inaccurate claims regarding the evidence base pertaining to minimum unit pricing (MUP) for alcohol. Many of his claims repeat critiques of the Sheffield Alcohol Policy Model which Snowdon expressed in a report co-authored with John Duffy, a scientist who acted as a paid consultant for the Scotch Whisky Association during its legal challenge against MUP [1]. Although Snowdon claims his arguments have “simply not been answered”, we actually produced a detailed rebuttal of Duffy and Snowdon’s critique in January 2013 [2]. Given Snowdon has ignored its arguments, we wish to take this opportunity to briefly restate the relevant points.
Firstly, Snowdon argues that: “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’”. This is a misrepresentation of how the Sheffield Model works. The key inputs driving the model’s results are not the subjective decisions of researchers but, as is appropriate, published evidence on the purchasing patterns of UK drinkers [3] [4], evidence on the impact of price changes on those purchasing patterns [5] and evidence on the epidemiological relationship between drinking and risk of harm [6]. We have published extensive sensitivity analyses demonstrating how alternative data, evidence sources and analytical methods affect model results. The baseline data is updated periodically and we have adapted the model to other contexts to ascertain how policy effectiveness may respond to changing baseline conditions [7-9]. All of this work is in the public domain and accessible to all interested parties.
Snowdon’s second major point relates to the challenges of evidence-based policy-making. He argues: “the evidence is partial because the models are partial” and “Economic decisions involve trade-offs. If public health academics wish to make a serious contribution to an economic debate, they must recognise this”. We have, in fact, stressed throughout our work that no model can capture all aspects of a complex reality and all of our publications follow good scientific practice by discussing the main limitations of our analyses [3] [4] [10]. Snowdon’s ability to assess these limitations is a product of our transparency. We also agree that policy decisions must strike a compromise between competing interests. Our rebuttal of Snowdon’s previous critique acknowledges this: “The judgment as to whether the wider evidence base and the modelling is reliable enough to enable policy makers to… implement MUP falls within a complex public process of debate involving academic peer review, political judgment and scrutiny, and commentary and consultation with the public and stakeholders holding a range of worldviews and vested interests.”
Thirdly, Snowdon claims that MUP is regressive and will penalise those on low incomes. We have recently published a detailed equity-focused appraisal of MUP which shows this argument to be simplistic [3]. As moderate drinkers with low incomes buy very little alcohol sold for less than the proposed 45p per unit threshold, the effect on them will be negligible. In contrast, alcohol purchases made by heavy drinkers with low incomes will be substantially affected. However, as this is the group at greatest risk of harm due to their drinking, they also stand to accrue the greatest health gains from the policy. We estimate approximately 80% of the health benefits of MUP would accrue to those in routine or manual worker households and the long-term unemployed – a clearly progressive outcome. Any judgement on the equity of MUP should take this more nuanced assessment into account.
Finally, Snowdon takes issue with our claim that: “[The Sheffield Alcohol Research Group] 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”. While we agree that researchers can and do influence the narrative, our chief frustration is not with our own contribution but with our critics’ engagement in ‘scientific debate’. This is exemplified by Snowdon and his co-author, John Duffy. In October 2012 the Scottish Government asked us to comment on a critique of the Sheffield Model produced by Duffy and submitted as part of the Scotch Whisky Association’s legal challenge against MUP. Our detailed rebuttal was submitted to the court. In November 2012, Duffy and Snowdon published their critique for the Adam Smith Institute which contained similar arguments and made no attempt to engage with our rebuttal [11]. Again, we published a detailed response in January 2013 [2]. In April 2013, Duffy published a third critique in the newsletter Significance which presented variations on the same arguments without any acknowledgment of our previous responses [1]. As a scientist, we would expect Dr Duffy to display good scholarship in three ways: firstly by referencing our responses to the critiques so readers are aware of relevant work; secondly by responding to the rebuttals rather than repeating similar or the same criticisms and, thirdly, by submitting his arguments to the peer-reviewed journals which published our original work (The Lancet and Addiction). To our knowledge, he has refrained from engaging on all three counts.
We believe the public health community should welcome contributions to policy debate from those with alternative worldviews as this is conducive to a well-functioning democracy. However, we also believe those contributions should follow two principles: first they should acknowledge the full range of available evidence and, second, they should engage reasonably in the dialectic argument rather than ignoring already public rebuttals and repeating previously dismissed claims. The BMJ’s Under the Influence series and other research has highlighted how the alcohol industry fails on the first principle due to its biased and selective use of evidence [12]. Snowdon’s response to the BMJ fails on the second principle. Given the high profile of the BMJ’s investigation and the commentaries that have followed, we believe that it is untenable for Snowdon or Duffy to present again their misleading claims about our work without referencing and engaging with the existing rebuttals.
John Holmes
Petra S. Meier
Robin C. Purshouse
Alan Brennan
Reference List
(1) Duffy JC. The price of a drink - too exactly? Flawed evidence for minimum unit pricing. Significance 2013; 10(2):23-27
(2) Brennan A, Purshouse R, Holmes J, Meng Y. A public response to the Adam Smith Institute's critique of the Sheffield Alcohol Policy Model. 2013. Sheffield, University of Sheffield.
(3) Holmes J, Meng Y, Meier PS, Brennan A, Angus C, Campbell-Burton CA et al. Effects of minimum unit pricing for alcohol on different income and socioeconomic groups: a modelling study. Lancet 2014;
(4) Purshouse RC, Meier PS, Brennan A, Taylor KB, Rafia R. Estimated effect of alcohol pricing policies on health and health economic outcomes in England: an epidemiological model. Lancet 2010; 375(9723):1355-1364
(5) Meng Y, Brennan A, Purshouse R, Hill-MacManus D, Angus C, Holmes J et al. Estimation of own and cross price elasticities of alcohol demand in the UK: A pseudo-panel approach using the Living Costs and Food Survey 2001-2009. J Health Econ 2014; 34:96-103
(6) Corrao G, Bagnardi V, Zambon A, La Vecchia C. A meta-analysis of alcohol consumption and the risk of 15 diseases. Prev Med 2004; 38(5):613-619
(7) Hill-MacManus D, Brennan A, Stockwell T, Giesbrecht N, Thomas G, Zhao J et al. Model-based appraisal of alcohol minimum pricing in Ontario and British Columbia: A Canadian adaptation of the Sheffield Alcohol Policy Model Version 2. 2012. Sheffield, University of Sheffield.
(8) Meng Y, Purshouse R, Brennan A, Meier P. Model-based appraisal of alcohol minimum pricing and off-licensed trade discount bans in Scotland using the Sheffield Alcohol Policy Model (v2): An update based on newly available data. 2010. Sheffield, University of Sheffield.
(9) Meng Y, Brennan A, Holmes J, Hill-MacManus D, Angus C, Purshouse R et al. Modelled income group-specific impacts of alcohol minimum unit pricing in England 2014/15: Policy appraisals using new developments to the Sheffield Alcohol Policy Model (v2.5). 2013. Sheffield, ScHARR, University of Sheffield.
(10) Purshouse, R., Brennan, A., Lattimer, N., Meng, Y., Rafia, R., Jackson, R., and Meier, P. Modelling to assess the effectiveness and cost-effectiveness of Public health related strategies and interventions to Reduce alcohol attributable harm in England using the Sheffield Alcohol Policy Model version 2.0. Report for NICE. 2009.
(11) Duffy JC, Snowdon C. The Minimal Evidence for Minimum Pricing: The fatal flaws in the Sheffield Alcohol Policy Model. http://www.adamsmith.org/blog/liberty-justice/the-minimal-evidence-for-m...
(12) McCambridge J, Hawkins B, Holden C. Industry use of evidence to influence alcohol policy: A case study of submissions to the 2008 Scottish Government consultation. PLos Medicine 2013; 10(4):e1001431
Competing interests: No competing interests
While I am happy to take the credit for colourful adjectives regarding Prof. Chapman's advancing years, his killer example of my 'invective' ('insane wibblings' etc.) was not written by me but by one of my blog's readers. As Chapman provides a link to the post in question, it is surprising that he did not read it more thoroughly. My words appear in the main text of the post under my name whereas comments appear below the post under the heading 'comments'. This is how blogs typically work.
In any case, a distinction must be drawn between jibes made for comic effect and defamatory accusations made in earnest. For example, when Prof Chapman referred to me as an 'Olympian t**spot' on social media last July [tweet deleted but Google has kept a trace of it here: https://www.google.co.uk/search?q=simonchapman6+olympian+tosspot&ie=UTF-... ] that was mere vulgar abuse and was not to be taken too seriously. I fully defend his right to make such remarks. But when, more recently, he described members of the liberal student organisation Liberty League as 'racists', it was a serious slur [ https://twitter.com/SimonChapman6/status/438388238089089024 ]. Similarly, Mr Gornall's description of free market institutes as being on the 'far-right' goes beyond vulgar abuse and requires evidence or apology, particularly since it was not made in the social media playground but in a serious journal.
Contrary to Prof Chapman's claim, I have had articles published in peer-reviewed journals [ http://www.emeraldinsight.com/journals.htm?issn=1745-9265&volume=13&issu...
http://onlinelibrary.wiley.com/doi/10.1111/j.1468-0270.2010.02039_4.x/ab... ] and I have also reviewed articles for peer-reviewed journals. However, considering the amount of nonsense that has passed peer review over the years [ http://www.sciencemag.org/content/342/6154/60.full ], I prefer to look at the merits of research rather than relying on its source.
I am happy to expand on my declaration by reproducing verbatim what I originally sent the BMJ:
"The author has occasionally spoken at meetings organised by the alcohol industry and the government. He has received a fee in neither instance, but has sometimes received travel and accommodation expenses."
Prof Chapman and Mr Gornall might view trivial expenses to attend conferences as "ties". I call it working for free.'
Competing interests: The author has occasionally spoken at meetings organised by the alcohol industry and the government. He has received a fee in neither instance, but has sometimes received travel and accommodation expenses.
We overlooked a revised statement of competing interests given to us by Christopher Snowdon during the preparation of his rapid response (http://www.bmj.com/content/348/bmj.f7531/rr/685644) for print.
The competing interests should have read:
"I have read and understood the BMJ Group policy on declaration of interests and declare the following interests: The author has occasionally spoken at meetings organised by the alcohol industry and the government. He has received a fee in neither instance, but has sometimes received travel and accommodation expenses".
Competing interests: No competing interests
I weep with despair when I encounter this sort of worldview.
It is hard to know where to start on demolishing this teetering 'castle in the air' of hard boiled prejudice, malignant casuistry and neo-liberal claptrap.
Far from being an open society, Britain and many other nations have become the profitable playthings of unaccountable, unelected oligarchs who fund and direct governments for their own benefit, rather than for the benefit of the electorate. Recent history is awash with the most appalling governmental delinquency and Milquetoast dependence on financial elites.
The Anglo-American neo-liberal free market globalised capitalist model has had its day in the sunshine and is now sinking beneath the weight of its own corruption, internal contradictions and amorality. Not to mention that it doesn't work.
If anyone should be doing any retracting and apologising it is the apologists of the elites.
Yours sincerely
Steve Ford
Competing interests: No competing interests
Chris Snowdon's call for civility ("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.") will surely have no competitors this decade for the most unctuously nauseating piece of hypocrisy to appear in the BMJ's pages.
Snowdon's blog is little more than a foaming sewer of schoolyard invective. He has no economic qualifications and to my knowledge has never published a single piece of research in any peer reviewed journal.
Here are some choice examples he has fired at me in recent years: 23 May 2011: “His insane wibblings are worrying yes, but still bloody funny to read. It's quite incredible that such a retard has achieved so high a profile since he must take 10 minutes every morning figuring out how his trouser zip works.”
http://velvetgloveironfist.blogspot.com/2011/05/glorious-idiocy-of-simon...
“that sad old sociologist Simon Chapman”; “the irksome, omnipresent über-wowser Simon Chapman”; “Anti-smoking dinosaurs like Simon Chapman”; “the creepy sociologist Simon Chapman”; “scrotum-faced head-banger Simon Chapman” “reptilian sociologist” “wizened quackademic Simon Chapman” “wrinkly rocker Simon Chapman” “that twisted old narcissist Simon Chapman” “Coffin-dodging sociologist Simon Chapman” http://velvetgloveironfist.blogspot.com.au/search?q=Simon+Chapman
I note he declares no competing interests. I have a screen shot from his blog dated 12 March 2008 where he says "he has no affiliation of financial ties with the tobacco industry or any anti-smoking group." That declaration was later quietly removed. Snowdon has many ties with tobacco interests (see http://www.tobaccotactics.org/index.php/Christopher_Snowdon). Will the BMJ be asking Snowdon to elaborate on his declaration about alcohol?
Competing interests: No competing interests
Re: Costs of minimum alcohol pricing would outweigh benefits
Christopher Snowdon who leads the new 'Lifestyle economics' at the Institute of Economic Affairs (IEA) writes to admonish the BMJ for publishing an article critical of the alcohol industry’s role in undermining the adoption of Minimum Unit Pricing of alcohol by the UK government.(1) The BMJ requires authors to declare competing interests (‘when a person has a personal or organisational interest that may influence or appear to influence the work they are doing. Usually this is a financial interest, but it may also be non-financial.'(2)) Snowdon disclosed only a personal conflict of interest, yet a close reading of his article and other data on IEA funding suggest that additional potential conflicts of interest exist.
The Institute of Economic Affairs is the oldest market liberal think tank in the UK. Snowdon’s role there is to examine 'the issues surrounding alcohol, tobacco, gambling, sugar, fat and soft drinks'.(3) Although the IEA 'has a policy of donor confidentiality',(1) even Snowdon’s article indirectly acknowledges alcohol industry funding of IEA stating that no evidence 'can be found' that 'the drinks industry’s funding to the Institute of Economic Affairs is at all significant as a proportion of our income or that drinks industry funding is greater than… funding by the retail industry. He also notes that that 'such donations to the institute are small.' Small or not, the fact that the IEA receives funding from the alcohol and retail industries when elements of both opposed MUP and therefore have an interest in what he writes, clearly constitutes a conflict of interest under the BMJ terms and should have been declared.
Additional evidence suggests other potential conflicts of interest may exist and raises serious concerns about the role IEA plays for major corporations whose products are potentially damaging to health. For example, tobacco industry documents released in legal settlements and recent documentation reveal that the major tobacco companies historically and currently fund the IEA.(4, 5, 6) This is relevant since Altria, the parent of tobacco firm Philip Morris USA and which spun off Philip Morris International in 2008, owns almost 30% of the global alcohol producer, SABMiller. Perhaps more importantly, however, it is clear that the IEA has played a role in the tobacco industry’s well documented attempts to create doubt about the health impacts of second-hand smoke and to influence the general way that risk is dealt with(7); the latter an issue that would also work to the alcohol industry’s advantage and on which alcohol and tobacco companies have previously collaborated (8). It is the apparent attempt by segments of the tobacco industry to undermine science that underpinned the BMJ’s recent decision to no longer publish research funded by the tobacco industry.(9)
A key issue is that the secrecy surrounding IEA funding makes it difficult to accurately assess the extent of any conflict of interest, an issue that has become a major concern of addiction specialty journals.(10) This secrecy appears to be something IEA’s funders deliberately seek – Philip Morris International has deliberately used the IEA to represent its interests in media debates (11) and other funders go to considerable lengths to disguise their funding of the IEA, channeling it for example through secretive US-based foundations.(12).
In the case of Christopher Snowdon the conflict of interest statement falls below the standards of transparency expected of academic authors writing in medical journals. We believe the BMJ should go back to Snowdon and require a full disclosure of both personal and organisational conflicts of interest. This should including the amounts and identity of the donor(s) of personal funding given for travel and accommodation and organisational funding to the IEA. The latter should include all funding (for membership, projects and events) from the alcohol and retail industries and indeed any other industry or industry-linked funds given for work on alcohol related topics.
In the wider case of the relationship between the IEA and its funders, the BMJ have said to us (in discussion of this Rapid Response) that their policy is to ask for disclosure of any relevant competing interests to the topic under discussion. We argue that all competing interests are relevant and should be declared; if they are not relevant then they are not competing interests.
The BMJ has two choices in relation to any articles from the IEA and related organisations: to require full disclosure of all funding or to refuse to publish the work. Without this, it is impossible to rule out or even assess potential financial conflicts of interest. As a result the BMJ may inadvertently be allowing the hidden vested interests its conflict of interest policy seeks to expose to promote their agenda via third parties such as the IEA.
References
1. Christopher Snowdon Costs of minimum alcohol pricing would outweigh benefits OBSERVATIONS Alcohol and Public Health BMJ 2014; 348 doi: http://dx.doi.org/10.1136/bmj.g1572 (Published 19 February 2014) http://www.bmj.com/content/348/bmj.f7531/rr/685644 (last accessed 24 February 2014).
2. BMJ. BMJ Group policy on declaration of interests http://www.bmj.com/sites/default/files/BMJ_Group_policy_on_declaration_o... (last accessed 24 February 2014).
3. Institute of Economic Affairs. 'Lifestyle Economics' http://www.iea.org.uk/lifestyle-economics (last accessed 24 February 2014).
4. Tobacco Tactics. Institute of Economic Affairs. http://tobaccotactics.org/index.php/Institute_of_Economic_Affairs (last accessed 25 Feb 2014).
5. Tobacco Tactics. IEA: History of Close Ties with the Tobacco Industry. http://www.tobaccotactics.org/index.php/IEA:_History_of_Close_Ties_with_... (last accessed 25 Feb 2014).
6. Doward J. Health groups dismayed by news 'big tobacco' funded rightwing thinktanks. The Adam Smith Institute and the Institute of Economic Affairs received money from cigarette firms, it has been revealed. The Observer, 1 June 2013. http://www.theguardian.com/society/2013/jun/01/thinktanks-big-tobacco-fu.... (last accessed 25 Feb 2014)
7. Tobacco Tactics. IEA: Working with RJ Reynolds, BAT and Philip Morris on Environmental Risk http://www.tobaccotactics.org/index.php/IEA:_Working_with_RJ_Reynolds,_B... (last accessed 25 Feb 2014).
8. Smith KE, Fooks G, Collin J, Weishaar H,Mandal, S, Gilmore A. “Working the System” – British American Tobacco’s influence on the European Union Treaty and its implications for policy: an analysis of internal tobacco industry documents. PLOS Medicine 2010. DOI: 10.1371/journal/pmed.10000202 http.plosmedicine.org/article/info%3Adoi%2F10.1371%2Fjournal.pmed.1000202
9. Godlee F et al. Journal policy on research funded by the tobacco industry. BMJ 2013; 347:8.
10. Babor D, Miller P. McCarthyism, conflict of interest and Addiction’s new transparency declaration procedures. Addiction 2014, 109, 341–344
DOI: 10.1111/add.12384
11. Tobacco Tactics. PMI’s anti plain packaging media campaign. http://www.tobaccotactics.org/index.php/PMI%E2%80%99s_Anti-PP_Media_Camp... (last accessed 21 Dec 2013).
12. John Mashey Fakery 2: More Funny Finances, Free Of Tax Desmogblog Thu, 2012-10-25 05:00. http://desmogblog.com/2012/10/23/fakery-2-more-funny-finances-free-tax
Competing interests: DM receives funding from the European Commission for an FP7 project (ALICE RAP) that focuses on rethinking addictions in Europe – the same project which funded the article criticised by Christopher Snowdon. He is also a director of Public Interest Investigations, a non-profit company which is behind two websites: spinwatch.org and powerbase.info. ABG has been subject to persistent defamation from Christopher Snowdon –he has published over 100 blog entries attempting to defame her and critique her research (http://velvetgloveironfist.blogspot.co.uk/search?q=gilmore%2Banna). Her research on the tobacco industry is currently funded by the US National Cancer Institute, National Institutes of Health (grant R01CA160695), Cancer Research UK (grants C38058/A15664, C27260/A12294) and ESRC (grant ES/L00206X/1); the funding from CRUK and ESRC supports the online wiki www.TobaccoTactics.org. JB is a board member of ASH. DM, ABG, JB are members of the UK Centre for Tobacco and Alcohol Studies, a UK Centre for Public Health Excellence (MR/K023195/1) funded by the BHF, CR-UK, ESRC, MRC, and NIHR, under the auspices of the UK Clinical Research Collaboration. NS has undertaken paid consultancy work and received travelling expenses from pharmaceutical companies developing drugs for the treatment of inflammatory bowel disease and liver disease &been paid for medico-legal work in the area of Hepatitis C and alcohol related liver disease. The following memberships and advisory work are unpaid apart from travelling expenses: EU Alcohol Forum, EU Alcohol Marketing Taskforce, Royal College of Physicians Alcohol Committee, Alcohol Health Alliance UK. Advisory work for the UK Department of Health, Home Office, Department of Transport, Cross Cabinet Strategy Committee, NICE, Southampton City Council, UK Police, British Liver Trust, various other bodies, NGO’s and local government, media activity of various forms. I was a trustee of the Drinkaware Trust until May 2013, and co-chair of the Responsibility Deal Alcohol Network until my resignation in August 2013 as a result of the u-turn over minimum unit price. TB: None declared.