- On 9 April 2020, the Institute of Economic Affairs, an educational charity, published a briefing paper with a Press Release declaring its conclusions that “Minimum pricing had no impact on alcohol-related deaths in Scotland in the eight months after it was introduced”. Commenting on his findings, Christopher Snowdon of the IEA and author of the briefing, claimed it showed “all in all, this is more evidence that minimum pricing has been an expensive failure”. Minimum pricing of 50p per gram of alcohol was introduced in Scotland in May 2018.
- Then in February 2021, a further press release was issued, with a link to the same, unaltered briefing, entitled “Calls to increase minimum pricing on alcohol ‘almost obscene’, says IEA expert (Mr Snowdon again). “It is almost obscene that campaigners with secure, taxpayer-funded jobs are trying to raise the cost of living for people on low and average incomes”.
- Both the briefing paper itself and the two Press Releases are in breach of the Charity Commission’s guidance on what charitable education must be. I am familiar with this guidance from my time as a Charity Commission Board member.
Requirements of charitable education
The Charity Commission’s guidance states that “[the charitable advancement of education involves] “researching and presenting information in a neutral and balanced way that encourages awareness of different points of view where appropriate”. “If the purpose of providing information or education is to persuade people to form specific conclusions, then this is not education”. Charitable education must not be promoting a pre-determined and controversial point of view. In all these respects, the briefing and two associated press releases fail the test.
The IEA’s research: neutral and balanced?
The author makes no attempt to summarize the results of previous research on the effects of alcohol pricing on reducing consumption and health impacts. That is a normal part of presenting research findings in a balanced way. In this case, the very strong evidence from multiple studies that alcohol pricing has significant effects of this kind – including those from Canada where minimum pricing has already been introduced – is ignored. This clears an obstacle to the particular conclusion that minimum pricing is an expensive failure.
His research approach is not peer-reviewed and the most appropriate research methods for this kind of work, well known in health economics, are not used or even discussed. What is required in the view of expert researchers, as in the Scottish Government’s extensive programme of research into the effects of Minimum Alcohol Pricing, is known as an interrupted time series analysis, which in lay terms means taking a series of years before the event you are investigating, in order to understand the effect of the event. This is essential, because otherwise you are not seeing the trends that are at work anyway, separately from alcohol pricing. Mr Snowdon takes monthly comparisons between figures for deaths and hospitalisations in England and Wales and Scotland in a period of only 8 months before and after the introduction of Minimum Alcohol Pricing in Scotland and notes that they are roughly the same across Great Britain; he concludes that the new measure in Scotland has had no effect. But if we want to know what effect this particular measure has had, we must know what would have been expected had no such measure been introduced;and to do that, you need to take a run up of a few years so that you can see the trends and compare the actual outcome with what the expected outcome would otherwise have been. The very fact that deaths and hospitalisations linked to alcohol are so much worse in Scotland than in England and Wales (not mentioned in the IEA piece) shows that there are factors at work in Scotland which are different from the rest of Great Britain and which must be taken into account.
Because Mr Snowdon doesn’t adopt this method, he can’t see the possible impact of other factors or what the comparative figures for Scotland and England and Wales would have been had there been no Minimum Alcohol Pricing in Scotland. That undermines his conclusion that it has had no effect. The truth is that, until the interrupted time series analysis commissioned by the Scottish Government and now underway on the impact on deaths and hospitalisations is completed, we do not know what the impact has been. Thus, the central conclusion of the briefing is unreliable.
It is also notable that the context of introducing Minimum Alcohol Pricing in Scotland in May 2018 is not presented. You would not know from the IEA briefing that the rates of death from alcohol are twice as high in Scotland as in England and Wales, nor that the alcohol-related mortality rates in the most deprived areas of Scotland are 6 times as high as in the least deprived areas, while the rate of hospitalisations related to alcohol are 9 times as high. The failure to explain this context in a balanced and neutral way enables Mr Snowdon to:
- paint the supposed impact of the Minimum Pricing Policy as an unfair assault on people on low incomes, without mentioning that that is precisely where the worst problems of alcohol misuse are concentrated
- depict the motives of those in favour of extending minimum pricing in his most recent press release as “trying to raise the cost of living for people on low and average incomes” (which he describes as “almost obscene”) rather than trying to address egregious problems that Scotland has with alcohol-related harm which affects deprived communities far worse than others.
This seems the very opposite of the Charity Commission requirement that charitable education should encourage appropriate awareness of different points of view. We are being steered to the particular conclusion that minimum pricing is an expensive failure that unfairly hammers the poor.
In the press release summarising the briefing paper it is said that Snowdon’s research suggests that Minimum Pricing has had “no impact whatsoever” on health outcomes (a flawed conclusion as we have seen) and also “little, if any, impact on alcohol sales”. But this downplays the results of the research by a team from Newcastle University published in September 2019 which was based on interrupted time series methodology and is more professional and reliable than Mr Snowdon’s deductions from market research reports. The Newcastle study shows that
- there was a reduction in weekly purchases of alcohol by 9.5 grams per adult per household (a finding mentioned but not accorded much weight by Mr Snowdon)
- The increase in weekly cost per household was only 61p, (though this was greater in lower income households and households that purchased the biggest quantities of alcohol). This seems to contradict Mr Snowdon’s claim that “the financial cost to moderate drinkers has been much greater than predicted”.
- Changes in weekly expenditure on alcohol after Minimum Pricing was introduced were not systematically related to household income but increased wherever more alcohol had been purchased.
These three research results should surely have been highlighted in any balanced presentation. They do not support Mr Snowdon’s conclusion that minimum pricing “has been an expensive failure”; on the contrary, they seem to show that the policy has had impacts targeted on where the problems were worst. We have yet to see how these effects on purchases will have followed through into health outcomes or other social harms.
Summary: Breaches of guidance on charitable education
This combination of examples suggests that this briefing paper is not neutral or balanced as required of charitable education:
- There is no discussion of the context in Scotland leading the Scottish Government and public health organisations to address such a serious set of problems, far worse in Scotland than in England and Wales
- There is no effort to summarise the strength, depth and breadth of previous research findings on the relationship between alcohol pricing, consumption and health outcomes
- There is no peer review and no discussion of why Mr Snowdon did not use interrupted time series analysis of the kind regarded as essential by the Scottish Government and its university researchers – with the result that the central research finding of the IEA briefing paper is unsound
- The best research so far on the effects of the introduction of Minimum Alcohol Pricing in Scotland on sales and costs to households is not given proper weight, and in fact undermines some of Mr Snowdon’s claims about the impacts on sales, moderate drinkers and average income households
- The language used by Mr Snowdon is at times extreme – the very opposite of respectful of differing opinions. The accusation that it is “almost obscene” for those with secure, taxpayer-funded jobs to be “trying to raise the cost of living for people on low and average incomes” is the language of partisan, personally abusive polemic rather than charitable education.
In mitigation, it might be said that a Briefing Paper is not claiming to be an academic report and is designed to promote discussion. But that is no justification for departing from the basic requirements of charitable education. Moreover, the Charity Commission has rightly made clear that opinions publicly expressed by a staff member of the charity, under its auspices, cannot be regarded as a purely individual opinion: the charity will be held responsible.
The breaches reflect a partly political purpose
We do not need to look any further than the IEA’s own website to understand why this briefing paper and press releases should be so lacking in neutrality and balance. “We promote the intellectual case for a free economy, low taxes, freedom in education, health and welfare and lower levels of regulation.” That is the IEA’s corporate position, although it disingenuously claims not to have one. The website continues: “All those associated with the Institute support free markets….Those promoting the IEA’s mission believe that society’s problems and challenges are best dealt with by individuals, companies and voluntary associations interacting with each other freely without interference from politicians and the state. This means that government action, whether through taxes, regulation or the legal system, should be kept to a minimum. Our authors and speakers are therefore always on the look-out for ways of reducing the Government’s role in our lives and undertake rigorous analysis to demonstrate their case”. (My emphasis). In short, demonstrating a controversial, pre-determined point of view is the IEA’s raison d’etre and is exactly what Mr Snowdon is expected to do as Head of Lifestyle Economics: it’s war on the nanny state. This is little to do with charitable education, presenting evidence in a balanced and neutral way, encouraging awareness of different points of view, and allowing the reader to draw his or her own conclusion. It’s trying to persuade the reader that the advance of the nanny state must be resisted.
Moreover, the purpose of shrinking the nanny state, and minimising state intervention (eg in alcohol pricing) is political, in the sense defined by the Charity Commission in its guidance on political activity (CC9). And charities may not have a purpose that is partly political, since their purpose must be exclusively charitable.
I am therefore asking the Charity Commission to find:
- That the policy briefing and two related press releases breach the Commission’s guidelines on charitable education
- That these breaches follow on several previous breaches and reflect the fact that the purpose of the IEA is inherently partly political and therefore cannot be charitable.
- That the purpose of the IEA includes promoting a controversial, pre-determined position and therefore fails the key criterion for charitable education.