by Professor David Hawks
National Centre for Research into the Prevention of Drug Abuse
GPO Box U1987 Perth, Western Australia 6845
Phone: (O8) 9368 2055
A keynote address delivered at the "Gambling Away Our Community" Conference sponsored by the Inter Church Gambling Taskforce and the Victorian Local Governance Association held at the Melbourne Town Hall on Friday 29 May 1998
Parallels are drawn between the alcohol and gaming industries and the application of harm minimisation strategies to "imprudent" gambling considered. The likely response of the gaming industry to such strategies is anticipated as is the need to address the structural incentives to gambling.
When I was first approached to contribute to this conference I was asked to address two topics -
At the time I said I had very little experience or specialised knowledge of gambling but that I had plenty of bruises to show from my dealings with the alcohol industry.
While I will be making only one presentation to this conference, I have been encouraged to address both topics, related as they are, and given the similarities between the alcohol and gambling industries.
Both are legal and earn vast amounts of money for governments. Both are also unusually well connected politically and so enjoy considerable support in Cabinet. Both represent revenue "cows" to be milked at a time when there is pressure on governments to reduce other forms of taxation and increasingly to move to a user pays system.
Of particular consequence for this conference is the fact that proponents of both industries claim that the vast majority of their adherents do not suffer any harm from their attachment and that those who do, do so as the result of some personality deficiency (or in the case of alcoholism, some metabolic deficiency) for which the industry cannot be held responsible. In the case of the gaming industry it is claimed that gaming is an entertainment, not dissimilar from other forms of entertainment, which while costing their customers money, confers no harm on them.
Accordingly, while both industries may be supportive of the need for treatment for those who evidence a dependence on their product, neither will happily countenance any restriction on their activities designed to restrain the average punter.
Both industries also resist any government intervention which they identify with nannyism on the grounds that gambling, like drinking, is an individual right over which, unless it can be shown to result in public damage, governments should have no jurisdiction.
The gambling and alcohol industries are also similar in arguing that the availability of gambling and drinking services is a sign of a country's sophistication; a suggestion which they bolster by arguing that tourists require such facilities which unless they are provided will result in them going elsewhere, with adverse consequence for Australia's economy - "blackmail by tourism".
Both industries also only give attention to the quantifiable benefits of their activities, noting the number of people employed by them, the revenue provided to governments etc., and resist giving credence to the harm associated with these activities, the quantification of which is very often difficult to document.
Finally, both seem to argue that the money spent on them is somehow or other new money which would not have been spent on other products or services and that, should their activities be curtailed, the contribution they make to the economy would be lost rather than as economists would argue merely redeployed elsewhere.
More controversially it has been suggested that in the same way as it has been amply demonstrated that as the per capita consumption of alcohol increases so do the problems associated with drinking, it is also the case that as per capita expenditure on gambling increases so do the problems associated with it. If that is the case then Victoria is heading into trouble with per capita expenditure on gambling having increased from $450 per head in 1992 to $748 per head in 1997. That it is anticipated that 40% of total expenditure will come from overseas visitors is analogous to say that Australia's over supply of alcohol can be solved by exporting alcohol overseas.
Given the similarities between the two industries it is not unreasonable to ask whether there are not lessons to be learned from the way in which the alcohol industry has been persuaded of its responsibilities.
Among the strategies which have been effective in countering the view that the only consequences of the alcohol industry's activities have been beneficial has been the broadening of the definition of problems associated with alcohol. While it was argued that the only adverse consequence of alcohol was alcoholism as clinically defined it could be contended that the extent of the problems associated with alcohol were relatively insignificant, affecting perhaps 2-5% of the population, a not dissimilar percentage to those claimed to be pathological gamblers. When however the definition of what were alcohol-related problems was expanded to include, for example, drink driving, drowning, motor vehicle accidents, domestic abuse, suicide, etc. it could be demonstrated that alcohol had a much larger adverse impact on society and the health system.
This proved particularly the case when the aetiological contribution of alcohol to a number of diagnostic conditions was identified by metanalysis.
Employing such techniques it could be shown that in 1992, hazardous and harmful alcohol use (defined in terms of the NH&MRC guidelines) (Pols & Hawks, 1992) caused the loss of 3,660 lives and 55,450 person years of life before 70 years, at an average of 15.2 years of life lost per death. There was also a net occurrence of 71,593 hospital episodes and use of 731,169 hospital bed days caused by hazardous and harmful alcohol consumption.
Of particular consequence for the argument often put by the industry that alcohol returned a net benefit to the economy were those economic analyses, for example, those carried out by Collins & Lapsley (1991), which showed that on the contrary [and conservatively] alcohol costs the Australian economy between 6 and 8 billion annually. I say conservatively because many of the adverse consequences of alcohol, for example its contribution to sick leave not covered by a medical certificate, could not be quantified in this economic analysis.
Related to the first of the points made above (the broadening of the definition of problems) has been the shift of focus from the relatively few addicted drinkers to the much larger number of drinkers who drink on any one occasion at a hazardous or harmful level, estimated to be up to 40% of drinkers and the association of such "binge" drinking with harm.
The most obvious application is, to the extent possible, to control the consumption of alcohol in association with gambling. While there is remarkably little research on this issue it is not unreasonable to suppose that intoxication affects a punter's perceptions of the odds and influences their betting strategies. Despite this, alcohol is readily available in licensed betting outlets and in some circumstances is provided at discounted or complementary prices. It cannot be coincidence that casinos are some of the few venues enjoying 24 hour liquor licenses.
Adopting the example of standard drink labelling, there should also be a clear statement of the odds at the point of "purchase". In the same way as it is a consumer's right to know how much alcohol they are consuming in a form which they can relate to the advice given about responsible drinking, it is surely a gambler's right to know what the odds are in relation to a particular game.
Associated with this it should be illegal to engage in irresponsible promotions which exaggerate returns or which deceive in relation to the odds. Lotteries in Western Australia are advertised under the logo "everybody wins" which except in the most general sense, that is, a percentage of the earnings are returned to the community, clearly is deceptive.
The taxation of alcohol has been found to be a very effective means of influencing consumption though it is a means we in Australia have been loathe to apply except in relation to the now outlawed licence fees. The price of alcohol, which is significantly determined by the taxation impost applied to alcohol, is one of the means used to limit its availability. Applying a similar logic to gambling would recommend that access to games not be rendered too available or their cost so modest as to make them accessible to everyone. Both of these strategies have clearly not been observed. At the very least no credit should be extended to gamblers or ATMs placed in close proximity to gambling outlets. The same logic would apply to pawnbrokers.
Licensing law in all of our states makes it illegal for a licensee or their employees to continue to serve someone whom they judge to be intoxicated. While this law has until fairly recently been widely flouted it enshrines an important principle, that is, that a licensee has a responsibility to ensure that a patron does not, as a consequence of the service offered, become incapable of determining whether that service should be continued.
Has the same principle application in gambling? Could we conceive of a situation in which a croupier might "refuse service" to someone they judge to be no longer acting prudently. Clearly this would be a matter of fine judgement but so it is in relation to intoxication where the requirement already exists in law. At present we have the anomalous situation whereby those who win consistently may be refused service, while those who lose consistently may receive inducements to continue gambling.
In the same way as it has been persuasively argued that it is too late to wait until someone has developed a physical dependence on alcohol before attempting to address that dependence when to do so is very difficult and subject to relapse: it would be recommended that the early signs of dependence on gambling be widely and publicly disseminated and that there be appropriate treatment and referral agencies catering to people displaying these signs.
Increasingly it has been argued that activities like smoking, drinking and gambling all of which have the potential for producing dependent behaviour should attract an additional tax which is hypothecated with a view to its being used to fund public education and treatment for those adversely effected by these activities and to buy out that sponsorship of activities attractive to young people on the model adopted in the case of tobacco. To do so, I would suggest, is no more than part of the proper costing of these activities, the proper accounting of their benefits and adverse effects.
In the same way that it has been determined that particular alcohol promotions may invite rapid consumption leading to intoxication, for example, happy hours and the provision of spirits as cheap ''shooters", it is open to the gaming industry to ban forms of gambling such as those offering continuous programmed reinforcement, which have been found to be particularly "addictive". Additionally, there are a number of technical fixes which may be of assistance, the imposition of payment intervals and cooling-off periods after significant wins being two such examples.
The Jellinek Consultancy in Amsterdam has recently published a number of "breaks to play" including breaking through the process of automatically playing on, restrictions on the attractiveness of the game and restrictions on the recruiting character of the gaming machines. In the same way as it is now acknowledged that even a single episode of intoxicated drinking may have disastrous consequences, so may a single episode of "reckless" gambling.
With the advent of standard drink labelling increasing efforts have been made to educate drinkers as to the limits of safe consumption, complicated though those these are by the need to take into account gender differences and drink driving requirements. Should not the same guidance be available regarding "safe gambling" and the early signs of "unsafe gambling" - the equivalent of low risk and hazardous consumption.
There is I think one more parallel with alcohol which can be drawn, which I suspect however will be less popular with this audience, many of whose members are understandably involved in the treatment of problem gamblers. It is the assertion that while of course the provision of treatment is a moral requirement of any civilised society, to attempt to provide treatment, which in this case is both costly and difficult, in the absence of any attempt to prevent the occurrence of dependence, is a nonsense. It represents a strategically inappropriate response. And yet it is the response that the gaming industry and government are only too happy to encourage. It is a nonsense because the prevalence of dependence on, or problems associated with, these activities is such that treatment, however lavishly provided will never be a sufficient response to these problems. To believe otherwise is to collude with the industry which would want us to believe that it is only a vulnerable few who will ever develop problems associated with their gambling, whereas in fact there is no consistently demonstrated personality trait associated with the propensity to become dependent on gambling. On the other hand, there are a number of situational and structural determinants or risk factors which the gaming industry is loath to acknowledge and will I suspect resist changing.
Unlike the alcohol industry where situational determinants of unsafe drinking are now being acknowledged and addressed, the gaming industry seems determined to establish an ambience which encourages irresponsible gambling. So, for example, while licensing law and a number of voluntary agreements between the alcohol industry and local authorities are increasingly moving toward the banning of irresponsible promotions, two drinks for the price of one or free drinks if you're young and female, service from jugs and underage service, the gaming industry seems determined to establish conditions which maximise the risk of irresponsible gaming. The absence of clocks or windows in gaming premises, the location of programmed poker machines in supermarkets, the proximity of ATMs to gambling outlets and the inducements to frequent gamblers (whom the odds would suggest are among the heaviest losers) to become frequent "fliers", etc. are just some of the examples which could be quoted.
Whereas the alcohol industry has albeit reluctantly accepted a code of advertising which precludes associating drinking with social, sexual and sporting prowess the gaming industry has exploited such an association by inviting celebrity endorsements and by advertising that implies everyone is a winner.
While the alcohol industry has accepted, however reluctantly, lower blood alcohol levels and random breath testing and has responded to both these initiatives by the introduction of low alcohol beers, the gaming industry has argued for more poker machines and their greater accessibility to the public.
In the same way that alcohol has now been recognised not to be a harmless product to be made as widely and readily available as cabbages, it will I hope be recognised that neither is gambling a harmless entertainment analogous to film going, the effects of which are wholly benevolent.
Finally and in the concluding sections of this lecture, let me address what I think will be the reaction of the gambling industry to these suggested measures based on my experience in dealing with the alcohol industry.
It will be first of all to claim that they are already a highly responsible and closely regulated industry and that they do not need more red tape, that is, that they can be trusted to be self-regulating. The nature of the product and the commercial imperatives operating in the alcohol industry have persuaded me that the retail industry at least with notable exceptions will only be as responsible as their profitability allows. I suspect the gaming industry is the same.
It should be realised that in the same way that the profitability of the alcohol industry is disproportionately dependent on those who drink regularly and at times excessively so, in all probability, is the profitability of the gaming industry dependent on frequent gamblers. After all the infrastructure costs of gambling are such that "on average" everyone has to lose. It is those who keep losing who contribute the most to its coffers.
They will claim to already pay substantial taxes and therefore meet the cost of any problems associated with their products . As I have already related, it is true at least of the alcohol industry that its activities as estimated by a variety of economists represent a net loss to the economy. That is, a proper accounting of the harms and benefits associated with alcohol suggest that we the tax payer subsidise their operations. While proper costing will need to take into account the whole gamut of benefits associated with gambling so also must it take into account the full gamut of harms, both direct and indirect.
It has been my experience in dealing with the alcohol industry that they will readily co-operate with measures which they judge to be good public relations, for example the skipper and safe home campaigns, the effects of which, while laudable, are limited and resist any measures they judge will significantly effect their profitability. And should we be surprised by this? As a consequence they will frequently use their collaborative or consultative status on government committees to delay interventions which will adversely impact on them and depict as do-gooders or as anti-alcohol anyone whom they judge to be concerned with the casualties associated with their products.
They will also claim, with some validity, in the case of the retail end of the alcohol trade that their staff are too transitory to warrant an investment in their training. They may be transitory but it must nonetheless be asked whether it is appropriate that the only requirement for serving alcohol, an indisputably potent and potentially dangerous drug, is that you be over the age of 18. Some means need to be found to address this problem if responsible service is to become the norm.
It will be claimed that gambling, like drinking, if not uniquely Australia is at least peculiarly Australian - we have after all been betting on the passage of flies on window panes at least since European settlement. As a consequence it will be argued that the gambling industry is deserving of special consideration, that its profitability should be protected and that its operations should be allowed to continue unabated despite mounting evidence of their harmfulness. The alcohol industry has claimed the same. There is something odd about these two industries, both of which are advocates of the free economy, claiming that they can only return an acceptable profit on an investment if permitted to trade in an unfettered way, whatever the harmfulness associated with that practice. The alcohol industry has come preciously close to claiming that it can only maintain its profitability if it is permitted to serve people to the point of their intoxication.
Finally, let me say that there is a danger when much of the research carried out in gaming is either directly or indirectly funded by the industry itself, that there will be a tardiness about ascertaining the adverse consequences of gambling and an exaggeration of its benefits, an exaggeration which unless we are vigilant we will collude with because it will be argued by governments that the benefits, for example the museums and art galleries which we, the responsible, enjoy are being bought for us by the feckless, that is, by those who are prepared to continue to gamble despite the mounting evidence of their losses.
Collins, D.J. & Lapsley, H.M. (1991). Estimating the Economic Costs of Drug: Abuse in Australia. Monograph 15, National Campaign Against Drug Abuse. Australian Government Printing Service: Canberra.
Pols, R. & Hawks, D.V. (1992). Is There a Safe Level of Daily Consumption of Alcohol for Men and Women? Second edition. Australian Government Printing Service: Canberra.
Aetiological is the term used for causation in the medical context.
Metanalysis is the term used to describe that form of analysis which employs as data the outcome of individual studies. For example, 25 studies of cardiovascular illness might be reviewed from the point of view of discerning the role of alcohol in their aetiology, such a review using the studies themselves as a database would be referred to as a metanalysis.
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