Plain packaging versus minimum pricing

This is a new thing for me: an attempt to write a genuinely short blog post.  (We'll see how that goes...)

Andrew Brown over at Mentor has written a blog post about a YouGov survey looking at various attitudes people have at the moment, which includes some stats on plain (in fact most likely standardised) packaging for tobacco and minimum unit pricing (MUP) for alcohol.

Andrew wonders whether this is to do with the messages around the values behind Public Health, or that tobacco control messages have been around for longer, or simply that people think plain - sorry, standardised - packaging doesn't have a (direct) cost to them, the consumer, where MUP would.

So many thoughts occurred to me that I thought rather than leaving a comment or trying to condense things into a tweet or two, I'd do my usual and expand this out into a rambling post.  I would stress that these are just some thoughts, and I'd love comments or feedback via comments below or Twitter.

My immediate thought was: have they controlled for whether people are smokers/drinkers?  We're obviously going to care more about a policy that directly affects us, so that's quite important.  I can't see any evidence that they have, and this brings us onto a couple of wider points about cultural attitudes.

First, more people in the UK drink than smoke - pretty much the same proportions of men smoked at all as drank at twice the recommended limits in 2011.  That means (and reflects the fact) that drinking is more commonplace than smoking, which is reflected in (and the result of) wider aspects of society.  There's something about the place of alcohol in society and British history that is telling, and this is reflected in literature, for example. I can immediately think of plenty examples of drinking and literature (my personal favourites being Alan Sillitoe and Thomas Hardy), where the only example of smoking taking a prominent role in literature that occurs to me straightaway is Tolkein.  More substantively, we have pubs but we don't really have smoking clubs (at least, not in the aftermath of the ban).

Second, there's an idea of 'safe' drinking, which is crucial.  Despite in my view it being a mistaken and unhelpful position to take, it's not uncommon to hear it voiced that, for example, smoking 'brings nothing but bad breath disease & death'.*  The common argument in favour of the smoking ban over the years is that there is no safe level of (second-hand) smoke.  Contrast this with the impression (sometimes challenged) given by the 'recommended' limits that there is a 'safe' level of drinking.

Drinking, therefore, is not seen as an unequivocal vice.  There is an elusive practice called 'responsible drinking'.  This might be, as Andrew suggests, because anti-tobacco lobbying has been around for longer, but it's also about the importance of alcohol in our culture even before this.  Nights out, venues, 'keying' of time, have long centred on alcohol, and never really on tobacco.  Alcohol is associated with good times and bad.  Weddings and funerals would be (almost) unthinkable without alcohol for many in Britain; the same couldn't be said for tobacco and many social situations.

This takes on crucial importance when we think about how the measures described - plain packaging and MUP - are universal.

I've written previously about how MUP is understood (or at least portrayed) by the Coalition - or more specifically Cameron - as a targeted measure.  James Morris has persuasively argued that the logic of MUP is based on a population model of public health, but equally the debate continues as to who the measure will affect and how hard.

The point here is that these aren't 'Booze ASBOs' or sobriety orders, which target those who are seen to have transgressed.  Under MUP everyone who buys alcohol would do so in a regulated market (and everyone who smokes would have to smoke cigarettes bought in plan packets - though perhaps the market for cigarette cases would boom?).  That is, whether or not there would necessarily be a material effect on all drinkers, which is still debatable, the starting position is that alcohol is by definition problematic.  This isn't an easy fit with ideas of 'responsible drinking'.

In my research, I found that even amongst those going out drinking on a Friday night on the night-time high street, who might be classed as 'binge' drinkers, there was an amazing tendency and ability to distinguish oneself from those 'other' drinkers who were the real issue.  People might drink a lot but they're not about to start a fight.  They might end up drunk, but they'd never drink to get drunk; they drink for the taste and the drunkenness is just an almost irrelevant byproduct.  And so on.

I've argued before that attempts to govern by concepts ('responsible', 'moderate', 'binge', 'excessive') is difficult, because people have a tendency to want to justify their own behaviour to themselves and others, whether consciously or not.  Give them an idea of responsible drinking, and a particular model of irresponsible drinking, and most people won't see themselves in the irresponsible camp.  (And conversely, for those that do, this is often seen as amusing and precisely what's being aimed for: trangression of norms established by perceived authorities such as governments.)

So what's my answer to Andrew's question of why we tend to see MUP as unacceptable?  I think it's because MUP hints that, actually, for every single one of us, alcohol is no ordinary commodity, and, although that's its primary attraction, it's also something we don't really want to hear.

(And there we go, I didn't keep it short.) 

Addition, 17^th May 2013
Partly because it doesn’t so directly relate to the public’s perception of drinking versus smoking (though it’s crucial in the background) I’ve forgotten to mention here one of the key points that I’ll often bore people with.  Public Health often draw the key comparison between the two practices, citing how smoking has declined considerably over the past 40 years, and how alcohol policy and harm reduction should learn from anti-smoking campaigns (and sometimes other behavioural changes, such as seat belt use).  (I noticed this at the recent Alcohol and British Society conference, for example.)  The key difference is the idea of passive smoking.  The smoking ban was able to gain public support not as a paternalistic measure, but as a liberal one, in line with JS Mill’s harm principle: your smoking would not just harm yourself, but me too.  Despite this, it is still judged on whether it has lowered general smoking prevalence, and this is partly where the difficulty for the smoking-drinking analogy lies.  Passive drinking, despite the efforts of Liam Donaldson, hasn’t caught on as a concept.  Of course all these aspects of the culture are mutually reinforcing: this difference is partly what allows alcohol to have such a central role in British society, but it’s also that central role that makes us less likely to accept Donaldson’s point.  And so on. 

*I think we have to acknowledge the pleasures of intoxication and trangression, which includes the very thing that motivates Wollaston: smoking kills.  Smokers know this, and this is partly why it is transgressive and offers a devil-may-care allure.  If we ignore these points, then we can't possibly build an effective harm reduction strategy.

**Personally, I think that even the Sheffield work has neglected the fact that pricing policies aren't solely based on cost: if your £3.50 wine becomes £4.50, the £4.50 wine isn't going to stay at the same price; there's an incentive for there to be a differential.  Looking at how tobacco pricing strategies have coped with increased taxes, there's sure to be some complicated dynamics regarding the pricing strategies for the lower and higher ends of the market, but it's certainly hard to say that people currently consuming above the MUP floor won't be affected.

A Postliberal Public?

Despite it dating from 22nd April, as far as I can see, today has seen the Joseph Rowntree Foundation (JRF) publicising – and the media picking up on – a report they commissioned from NatCen based on the British Social Attitudes survey.

As you’ll see if you look at the Guardian and Telegraph links, the story the media have tended to run with is that Labour supporters especially – but the population generally – have shifted from societal explanations for poverty to those emphasising laziness in particular. That is, we’re much more likely to see poverty as an individual’s fault now, as opposed to in 1986 (with the highpoint of societal explanations over that period in the first half of the 1990s).

The survey offered for options for people to answer the question “Why do you think there are people who live in need?”

• ‘Inevitable in modern life’ (the most popular throughout);


• ‘Laziness’;


• ‘Injustice in society’; or simply


• ‘Unlucky’

I noted in a previous post that recently there’s been a lot of discussion of how postliberalism might be an appropriate way of characterising current political trends in the aftermath of the financial crisis.  Individual decision-making and market mechanisms are viewed with more suspicion than they used to be, according to Will Davies for example.

 

The findings of this JRF/NatCen report got me thinking again about these ideas.  Although I didn’t state it in the end in the blog post, one initial response I had to these suggestions of postliberalism was that the political elite remained neoliberal, but I could perhaps allow that the British public might be postliberal.*

 

This is the argument of David Goodhart with respect to immigration: his ‘political tribe of north London liberals’ has been divorced for some time from broader ‘public opinion’.  You’ll also find it in the work of Blue Labour, with Maurice Glasman arguing that ‘The lessons of New Labour are not to have a contemptuous attitude to the lived experiences of people but work within them to craft a common story of what went wrong and how things can be better’.  Or in Philip Blond’s Red Toryism, which argues that we have become a ‘bi-polar’ nation, divided between government and populus.

 

This idea has particularly come to the fore with the ‘UKIP surge’ in the 2013 local elections.  Max Wind-Cowie, amongst others, has argued that UKIP is picking up votes from those who feel abandoned by the ‘excesses of both social and economic liberalism’ from both Labour and the Tories.  He advises that both parties could ‘grasp the post-liberal nettle’ and win these voters back, and still avoid some of the simply ‘illiberal’ policies that UKIP promotes.

 

In this sense, these arguments are consistent with what I’ve said before: neoliberalism is still alive and well in the corridors of power.

 

However, the other side of these arguments about a disconnect between voters and parties is that the public at large is ‘post-liberal’ – and this claim is certainly questionable.

 

As I’ve mentioned before, Thatcher sought to change the heart and soul of the nation, and in the discussion of her legacy – just weeks before her death – the consensus seemed to be that she had succeeded (‘she changed everything’, The Independent told us); the only question was whether this was a good or a bad thing.  Britain was now a Thatcherite nation.

 

To some extent, this tension is about the way we see UKIP and Thatcherism.  Max Wind-Cowie obviously sees UKIP as postliberal, but at the same time parallels are drawn between the ability of both Margaret Thatcher and Nigel Farage to win working-class votes with right-wing policies, and there’s certainly a strong case to be made that Thatcherism has more than a little neoliberalism in it.

 

I’d understand the recent evidence – UKIP voting and British Social Attitudes surveying – as pointing to the possibility that in fact the British public remain in some sense Thatcher’s children, and as such neoliberal.

 

On UKIP, Farage smokes, drinks and has an idea of a Little England centred around the pub (“every pub is a parliament”) – but his opposition to the smoking ban or minimum unit pricing (MUP) is an opposition not to neoliberalism, but paternalism.  His rationale for opposing the smoking ban, for example, is that it is ‘illiberal’.  This is exactly one of the words quoted from ‘Senior Conservatives and Liberal Democrats’ to explain the Cabinet wobble over MUP.

 

Immediately, this raises the suspicion that, despite its opposition to the free movement of labour, UKIP is more neoliberal than postliberal.

 

This impression is only strengthened when I think about how much of UKIP’s brand of euroscepticism rests on opposition to the Social Chapter and all those features that conversely led many within Labour to become pro-European, seeing the EU no longer as a ‘capitalist club’, but more as a brake on 1980s neoliberalism.  This is certainly how I grew up seeing the EU, and was shocked to find such euroscepticism amongst older Labour Party members.

 

Going back to the British Social Attitudes survey data, a key feature of neoliberalism understood in the way outlined in that previous post is the maintenance and expansion of marketised structures alongside a tendency to place responsibility for any undesirable outcomes on individual citizen-consumers.  That approach would imply seeing poverty as a result of individual failings rather than structural causes, in line with many respondents to the survey.

 

The prevalence of this worldview, represented by a falling number of people have seen poverty as caused by ‘injustice in society’, is at odds with an understanding that the public are somehow postliberal.  An awareness of how people are interdependent and the importance of solidarity (which are key themes of the work of all three) would surely mean that more people than currently would see poverty and general life chances as significantly determined by a lottery of birth and the structures of the world we live in, rather than reflecting underlying personal value or effort.**

 

And when I’ve read the work of people like Blond, Glasman and Goodhart I’ve got the impression that they do feel the public is fundamentally postliberal, as I’ve said.

 

But perhaps this is to look at things the wrong way.  What Blue Labour, Red Toryism, David Goodhart etc are saying is that the flaws of UK† society today are partly the result of politicians’ failures to see the importance of community and local relationships.  Certainly, living in a small town set in the Dorset countryside where I’ve found these elements more accessible has made me happier and more comfortable than living in E15 or E17, where I’d lived the two years prior to moving here.‡

 

Taking these approaches as recommendations for improving British political life, then, rather than descriptions of the wider polity, maybe there’s something in them.  And perhaps, if Jonathan Rutherford is to be believed and Blue Labour is seen as drawing on some kind of ‘English modernity’ like the New Left of people like EP Thompson and Raymond Williams, then such a political philosophy might tap into that ‘Little England’ theme of UKIP’s – and in a more positive way.  This is certainly what Blond and Glasman would like to see their parties doing.  They understand people as voting UKIP because there isn’t a mainstream party that seems to understand their concerns (even if they wouldn’t articulate them now in quite the postliberal language of the commentariat).

 

However, it’s one thing to say ‘this is what I would like to see politicians talk about’; it’s another to say ‘this is what will win you elections’.  Postliberalism at the moment, I’d suggest, remains more of a political recommendation than a characterisation of the electorate.  There might be elements within UKIP’s agenda that this approach could tap into, as Max Wind-Cowie suggests, but it’s hard to see postliberalism as an electoral panacea for either Labour or the Conservatives, or to think that it will instantly resonate with the electorate now.

 

Of course, with Thatcherism in mind, I would argue that it’s possible for particular discourses and policies to in themselves change the weather, so that you make your own luck, but this can take time and power.

 

At the moment, I’d suggest that David Cameron expresses it pretty well: we’re all Thatcherites now, but then again maybe we’re not.  Certainly the effects of that individualistic (even neoliberal) worldview can still be felt – and not just in the corridors of power.  Politicians maybe aren’t so distant from the rest of us as the postliberals might have us believe.

 

*Although if they’d never been neoliberal, or even liberal, it’s hard to see how they would be postliberal rather than simply communitarian.
** To some extent the particular decline in the societal explanation amongst Labour supporters might have more to do with tribal loyalty than a particular worldview: wanting to believe that the party has done as much as it can, so any residual poverty will be the fault of the individual rather than the government.  However, in terms of effects, this still amounts to a neoliberal view that at least up to 2010 was remaining pretty resilient.
†In ‘A Note on Language’ at the beginning of his book The British Dream, Goodhart explains: ‘I generally use the word Britain when I really mean the United Kingdom.’  How to wind up someone with (some) Ulster heritage…
‡Though I should point out, in liberal fashion, that living here wouldn’t suit everyone, and some people would probably feel more comfortable and welcomed than others.

MUP in Scotland

As you’ll realise if you’ve been able to see anything in the news today apart from the (reliably predicted) UKIP surge in the local elections, the challenge to MUP in Scotland brought by the Scottish Whisky Association and others has been rejected by Lord Doherty.

Plenty has been written about this already by other people (just check the Twitter feed of Stephen McGowan).  What I wanted to do at this point is think through how this relates to what I said the other day about industry involvement in the policy-making process.

Fundamentally, thinking back to my view of the appropriate role of the industry, this ‘petition’ was an attempt to shut the stable door after the horse has bolted.  I understand the motivation – to mitigate any effects, avoid setting a precedent, and take a symbolic stand against regulation – but the judgement basically makes precisely this point: all the evidence and arguments have already been discussed, and the decision has been reached on the basis of a perfectly reasonable process.

The whole debate is structured around whether the action is reasonable and proportionate to the problem.  Notably, the idea of there being a ‘problem’ of ‘excessive consumption of alcohol’ is taken as given.  (There would certainly be some mileage in a detailed analysis of how class is understood in this judgement.)

For the industry – and in fact for England in general – this is a great opportunity.  Although the two countries are not identical, this offers that rare opportunity in policy-making: a pilot project with the opportunity for simultaneous comparison.  We can have a look at how MUP works in Scotland, with the English as a (rather unscientific) control group.  Of course, the Canadian case already offers comparisons between different areas with different systems, but if we’re honest a comparison closer to home will always have more impact.  There will of course be complications, such as the economic recovery potentially advancing at different rates, and the fact that we start with somewhat different longer-term trends in consumption, but the comparison should still be instructive.

But this doesn’t mean that the industry should be preparing all the ways to rubbish the evidence from the Scottish case.  First, some research suggests that regulation might benefit both public health and the industry.  Second – and to my mind more importantly – if England did wait and see before implementing MUP (as seems likely even if this isn’t for scientific reasons), the lull would give the industry the opportunity to set aside their attempts to rubbish the evidence on public health, and instead develop and communicate all those arguments that they have thus far strikingly failed to do.

So here’s to a genuinely informed, intelligent, rounded debate…

Alcohol policy and the industry

I feel that my previous post was a bit like weak academia, but what I hope to do with this one is illustrate how some elements of the model I proposed for understanding policymaking might be useful.

One of the debates I mentioned in my last post was about the role of the alcohol industry in policymaking.  This has been in the news, as a result of a report by Jim McCambridge, Ben Hawkins and Chris Holden which argued that the alcohol industry misrepresented research evidence in its submissions to the Scottish Government’s 2008 alcohol policy consultation, which included proposals for minimum unit pricing (MUP).

A lively debate followed (I found John Holmes on Twitter particularly interesting), and in one case strayed into a semantic discussion of the nature of ‘evidence’.*

The headline of a blog on the Guardian website presented the wider debate in stark terms: “Should those with a vested interest comment on minimum alcohol pricing?”  This headline is itself a misrepresentation of the clear summary of the research Suzi Gage that followed.  The specific suggestion of the researchers is that ‘industry actors’ shouldn’t be involved in ‘the interpretation of research evidence’.

Thinking back to my previous post, this specific wording by McCambridge and colleagues really amounts to a claim that the alcohol industry isn’t the expert in what I posited as the second stage of thinking about policy: ‘what works’.  The gripe of McCambridge and colleagues is that the industry downplays strong evidence and promotes weak evidence or unevidenced conjecture in its place.

There is a statement in the article that ‘policy making is not a purely rational process, informed only by evidence.  It is by definition political and thus subject to a wide range of influences’.  I would take issue with this.  Policy cannot be solely informed by evidence, because evidence without aims is meaningless.  The decision on what these aims might be is certainly political, but that does not mean that it is by definition ‘not … purely rational’ – or more precisely that this somehow contrasts categorically with discussions of evidence.

What’s happening here is a prime case of the sort of problem L Susan Stebbing (the original thinker-to-some-purpose) was concerned to highlight.

It seems to me almost self-evident that the alcohol industry should be permitted to express its views on government policy, rendering the Guardian blog headline a bit of a straw man.  What’s at issue is quite how this should happen.  If we understand the injunction from McCambridge and colleagues as being that the alcohol industry shouldn’t get too involved in the ‘what works’ part of the policymaking process, this doesn’t rule out it contributing to the more fundamental question of ‘what is the problem’ (and what would be legitimate actions to address this).

This really hit home with me last November, when I was attending the DrugScope conference and felt that, regardless of my personal position, I could probably make the industry’s case better than Mark Baird was doing.  This is partly about not being so confrontational with those coming from a public health perspective, but it’s also about shifting the debate to ground where there is genuine uncertainty – and in fact there can never be certainty, because in this sense the decision is a political and moral one, rather than being simply about effectiveness.

The industry has a perfect right to sit at the policymaking table, but only as a stakeholder if it is being the industry.  If it’s trying to be a commentator on research evidence, you’re probably better off asking someone else (like McCambridge, or any number of other people).  The industry might commission research – but then you’d want to ask the actual researchers about the detail of that, rather than an industry representative such as Mark Baird (particularly given his slightly unusual definition of what constitutes ‘evidence’).

So, if I’m recommending shifting the debate to an earlier, more fundamental stage in that policymaking cycle, why, and what difference would that make?

Well, my first point is that all this industry ‘misrepresentation’ of research evidence isn’t a genuine debate about efficacy or effectiveness.  It seems fair to assume that the industry will continue to oppose intervention, even if in my view some explanations of why this is so (the shareholder imperative) are potentially a little simplistic in terms of their understanding of modern capitalism.**  Evidence can’t really change the industry’s position on intervention, because it’s based on economics and politics.

This applies not just to the alcohol industry’s position on alcohol policy, but to the issue itself in general.  The public health evidence can show that an intervention like MUP might reduce health harms across a population, or perhaps for a specific group; what it can’t show is whether this is a desirable aim, or (assuming health understood in these terms is a ‘good’ we want to promote as a society) how this balances against other potential ‘goods’ such as the pleasure of intoxication or the principles of liberty and autonomy.

L Susan Stebbing would probably argue that the industry should just come out and make this position clear, for reasons of transparency and so that we can have a constructive dialogue and genuine debate.  I’m tempted to think that, as well as this – in policymaking or public health circles perhaps – being open in this way would actually improve the industry’s standing.

Personally, I’m not sure that MUP would actually be an infringement of individuals’ (or corporations’) rights, but these sorts of arguments can’t be entirely undermined by predicted public health benefits.  When McCambridge says (in the radio link on the BBC article) that MUP would ‘benefit’ society at the expense of the industry, he’s assuming a particular view of the ‘good life’ and a particular conception of ‘society’ as opposed to ‘industry’.  These assumptions are not incontrovertible truths; they are particular ways of understanding the world.

If, in the mind of the public (or policymakers specifically), liberty and the pleasures of intoxication and taste trump living longer, that’s it – the argument is over no matter how effective a potential intervention might be.  And this would be without questioning the reliability or validity of the public health evidence.

In a sense, this is what McCambridge and colleagues are saying – as I quoted above, what they actually say is that ‘industry actors’ shouldn’t be involved in ‘the interpretation of research evidence’, and taking my model this would mean the industry wouldn’t have much of a role in the second stage – the ‘what works’ stage – but it might feed into the first: defining the problem.

However, I’m not sure how this could work out in practice.  I can’t really see the industry changing tack and being more open about their interests and objections.  (This is at a time when unfavourable comparisons with the tobacco industry are being made by McCambridge and colleagues.)  On the other hand, this doesn’t matter so much if we have policymakers and a wider public who are able to see the issues for what they are and consider them critically.

This idea of a public more willing and able to engage critically with public policy issues and cut through the rhetoric is at the core of L Susan Stebbing’s book, alongside the hope that politicians and other policymakers themselves might be clearer in their thinking and rhetoric.  Given that today, almost 75 years after it was first published, the arguments of Thinking to Some Purpose still seem directly relevant, it’s easy to be defeatist about the nature of public debate.  For the moment, though, I’m happy just to keep trying to follow Stebbing’s advice that ‘we should develop in ourselves a habit of sceptical inquiry’.

* Holmes also cited several other similar articles or findings.  One that’s quite informative is the discussion in response to this article in the BMJ.  I’m particularly interested in Don Shenker’s analogy with the car industry, where marketing a car on the basis of its safety record was apparently ‘anathema’ in the 1960s and 1970s.  (The discussion, under the tab ‘Read Responses’, seems to be free to non-subscribers.)

** On this front I immediately think of JK Galbraith’s idea of the technostructure, but there’s plenty of other work that critiques this sort of modelling of industry actors.

Evidence in policymaking

Edit (30th April 2013):  As has been pointed out in the comments, it doesn't look like Ben Goldacre's tweet I mention in the highlighted section below was actually aimed at Jeremy Hardie.  I've left it there, though, partly out of transparency but also because the debate between them is still what sets the context for this post, though obviously there's also plenty of others contributing to this too (notably, for me, the British Educational Research Association - BERA).

I’ve been noticing quite a few discussions of evidence and policymaking recently.  There’s been a bit of a spat between Ben Goldacre and Jeremy Hardie, after the publication of his book Evidence-based policy: a practical guide to doing it better co-authored with Nancy Cartwright.  At least, I assume that’s who Goldacre was getting at when he tweeted:

It is very sad - and odd - how some in the policy community hear "do more RCTs" and pretend they've heard "do only RCTs"

This is presumably in response to Hardie’s IPPR blog post, which itself was a response to Goldacre’s Building Evidence into Education report.  (And around we go…)

Also, this week has seen the publication of a study suggesting that the alcohol industry’s evidence to the Scottish Government was misleading.  This led to the inevitable exchanges on Twitter between Mark Baird and John Holmes, amongst others.  I’m going to write about that specific issue separately, but the point here is that there’s much to be discussed about evidence and policy.

What I want to do here is offer a model for understanding policymaking that, I hope, helps shed some light on – and cut through – some of these discussions.

I know that there are plenty of models of policymaking already available in social policy textbooks, and I’m sure I’m reinventing the wheel at some level.  However, I want to be clear about what I’m trying to do with the model.  This isn’t about modelling how policy is made in practice and the variety of influences on it (though there are plenty of models for this).

What I’m trying to do instead is think in a slightly abstract way about how policy is made: what thinking or ideas underlie policy?  That doesn’t mean that this thinking is overt, or that policymakers themselves are always conscious of it, but (even if it’s only implicitly) positions are taken on each of the following aspects.  I would suggest this model is helpful for looking at existing policies, or policy debates, in order to better understand some of the currents and influences that are underlying them.

I hope that you’ll be able to see how it’s helpful to identify (sometimes hypothetical) steps in policymaking, conceived of as a problem-solving process, from my next post, which will be about the role of the alcohol industry in alcohol policymaking.

It also helps shed light on my earlier post about alcohol and neoliberalism.  If we can see that a ‘problem’ and ‘solution’ have been defined in particular ways, we can start to think whether there is a broader approach to the idea of government and policy that is affecting how people approach certain issues.

However, I’m keen to stress that this is just some thoughts about how to think about policymaking that have come to me recently; this post shouldn’t be taken as an attempt to produce a definitive model of policymaking.  I’m sure people will be able to spot gaps in the argument, or perhaps misunderstandings of certain policy areas.  If you do, please let me know, as it will help my way of thinking about policy.  Certainly, there could be more or fewer steps to the model.

1. What is the problem?

‘Problem’ is a bit too specific a word here, really, but any policy has several aims, which might be understood as attempts to solve certain problems.  One of the things that fascinates and frustrates me about alcohol policy is that there’s any number of aims – and that’s crucial for all the stages that follow.  However, whether it's stated clearly or not, there will always be some perceived ‘problem’ underlying a policy.

2. What works?

This is seen as a key issue in current politics.  It’s what’s behind the Goldacre-Hardie spat and, having been a key part of Tony Blair’s rebranding of the Labour Party, this precise phrase is now the title of new independent policy advice centres set up by the Coalition Government.

How to judge ‘what works’ is what Goldacre and Cartwright & Hardie discuss, and with more detail and insight than I can here – or could even if I had more time and space.  The point I want to stress here is that this is not a neutral, value-free question, because it presupposes an answer to the previous one: what are we trying to do with the policy in question?  You can only judge whether something ‘works’ if you know what its aim is.  A computer doesn’t ‘work’ very well for cooking a roast dinner, but it might ‘work’ for looking up advice on how to do this.

There are two issues with this.  First, as I’ve already stated, there’s very often multiple aims of policies – and sometimes these can even be in conflict to some extent.  A drug treatment policy might want to increase the number of individuals who are free of any drug dependence, but you wouldn’t want to do this at any expense.  There’s a possibility that the same policy that successfully pushes a lot of people through the system successfully leads to others feeling alienated, and they therefore go on to disengage and commit more crime, suffer more health harms and so forth.  That is, you can’t judge the policy on one aim, or on one metric.

This brings me to the second point.  The measurement of ‘what works’ depends on choosing some way of measuring success and failure – ‘operationalising’ your concepts, as I was taught.  This is where there’s often disagreement about education policy: do rises in GCSE pass rates indicate a successful policy, or is this metric inadequate?

Ben Goldacre, in his paper on education and research, suggests that most of the time this operationalising isn’t an issue, as we should be able to find decent metrics that we can agree on.  To a certain extent this is true – we could perhaps develop better metrics than GCSEs or SATs, or we could contextualise them to understand what they ‘really’ tell us about the standards of education in the country.

However, this only brings me back (again) to question 1: what are we trying to do with education policy?  When people disagree about standards slipping, this isn’t simply because they don’t have faith in the exam system; they’re also often expressing an underlying difference in opinion about what examination is for and, more generally, what education itself is for.  It is impossible to agree on a metric to measure the quality of education if we can’t agree what we’re trying to do by teaching someone history, for example – and there’s any number of things we might be trying to do, perhaps all in combination (knowledge of dates, an understanding of the human condition, an understanding of the evolution of the British institutions of government, an ability to think analytically and assess claims of evidence or causality, etc etc).

I realise that this makes the idea of this sort of model questionable: if we can’t have a single measure of ‘what works’, then what is the help of this concept in a model like this?  My point is that by looking at a policy and thinking through what the phrase ‘what works’ might mean, we can begin to see the assumptions that underpin the policy area.  If we were to analyse the new curriculum, or the 2003 Licensing Act, or the recent Higher Education reforms, we’d find implicit answers to these questions (even if they were only: aim to save money, does it work measured by whether or not the deficit is technically reduced).  These help us understand what’s actually going on in policymaking, and I’d hope give us some idea about the process could be better.

3. How does it work?

This is really where Cartwright and Hardie attack Goldacre for his emphasis on RCTs (randomised control trials).  They say that RCTs can’t tell you whether something will work in a different context.  This is part of the more general point that RCTs can’t tell you how something works – that is, what the precise features are that deliver outcomes.  I don’t want to enter into this discussion now, but this is a key stage in the process, because it adds to the next stage…

4. A model for intervention

This is something that actually comes out as the ‘solution’ to the problem, and depends upon a belief that something ‘works’, with assumptions about how it works.  I’m thinking really of something like NICE guidelines for the medical profession:

• There’s a problem of heroin addiction, and we want to make sure individuals are no longer physically dependent on using heroin or other opiates.
• We’ve done studies of replacement therapies and found that in general prescribing methadone seems to ‘work’ towards this aim reasonably well.
• This is because it satisfies the body’s craving for opiates/opioids.
• Therefore, here are some recommendations for how to deliver this initiative (NICE guideline TA114)

However, in reality you might find that the guidelines aren’t actually that specific or tailored, and leave plenty of room for manoeuvre.  Certainly this is the case with the guidelines for the specific example I’ve just given.  This means that in practice we often have a further stage before there are actually interventions affecting people’s lives…

5. Application of guidelines by experts

In the methadone example, here we move to treatment staff actually putting a package of care in place for an individual service user, which will (we might hope) be based on NICE guidelines, but which we wouldn’t be able to exactly predict because it also depends on the application of context and clinical judgement.  In education policy, we might think of the national curriculum being the ‘policy’, and then the application of this being actual lessons.*

There is then something of a cycle taking us back to the beginning.  Doctors, in Goldacre’s example, implement guidelines, but on the basis of intuition, or performance data, identify new or continuing problems, which the NIHR can then investigate, taking us back to step 1 of the process.  Alternatively this might be done by some kind of policy review.

Thinking through these steps, I’m not sure that there’s always a 5, where guidelines/regulations are implemented by ‘experts’.  In terms of MUP, for example, I can only really think that this would imply some kind of inspection regime to ensure that prices in shops were indeed at least at the threshold.

Conclusion

I’ll finish this post in the same way I started it: by stressing that these are only some basic reflections about how implementing policy entails certain conclusions to have been reached.  I’d really welcome responses that critique this model, or potentially refine it, as something like it is the way I approach public policy discussions at the moment, and any improvement on my thinking would be welcome.

* This is where Hardie’s citing of Hayek’s Use of Knowledge in Society comes from.  (I didn’t really need to mention this, but otherwise there wasn’t going to be a footnote in this post, and that just seems a missed opportunity when all the others have them.)

Nudging and Rationality

I’ve promised myself I’d write something about ‘nudging’ on here, so here goes.  It’s really only some initial thoughts, and it’s more about the principle than the detail, but hopefully that will come across and be interesting.

I’ve written here before about how nudging isn’t necessarily new (look at James Kneale’s work on the interest during the nineteenth century in governing the shape and design of pubs), and as part of this how it’s consistent with ideas of neoliberalism.  Sometime in the future I’d also quite like to write about how it doesn’t really mark anything of a ‘third way’ between intervention and laissez-faire, but that’s not too dissimilar an argument to the one about neoliberalism.

What I want to talk about here is how I see a misunderstanding of human rationality and desires at the heart of the ‘nudging’ approach.

Underlying the idea of nudging as outlined by Thaler and Sunstein and those analysing their work (like Marteau and colleagues) is the understanding that two contrasting systems drive human behaviour.  One is a reflective, goal-oriented system; the other an automatic, unconscious system based on emotions/affect.  I found this idea to be explained clearly and simply by Dan Gardner in his book Risk.  He uses the terms Head and Gut to describe the two systems.

Thaler and Sunstein relate this duality to classical versus behavioural economics.  Classical economics, they say, treated people as if they only used Head – as perfectly rational, calculating individuals with access to perfect information and plenty of time to think.  In reality, we humans are flawed and use Gut quite a lot – often to ill effect.  Behavioural economics is seen as an improvement on classical economics, as it accepts that people are irrational, but continues to seek to model them.  As Jones and colleagues put it neatly, it seeks to render them ‘predictably irrational’.*

Thaler and Sunstein then take these insights as to how people behave irrationally in order to change their actions so that they are ‘rational’.

However, in my view this is slightly to misunderstand the motivation of classical economics.  It is not concerned with thinking about people’s inner monologues; it is concerned with modelling how they actually behave.  This is a common theme in social research, perhaps most vociferously put forward by David Silverman.  (This is not to say that at other times we shouldn’t be concerned as much with what people say as what they do.  I would of course humbly suggest that my work on drinking and distinction, and its implications for alcohol policy, is a case in point…)

In classical economics we don’t always have to worry whether someone ‘really’ wants the chocolate bar in the long run; we’re more concerned with how much they’re prepared to pay for it in practice when they get to the checkout counter.  That is, whether it’s Head or Gut, the point is modelling the decision and what this tells us about people’s expressed preferences.  This decision can’t really be ‘irrational’ in any meaningful sense, from this perspective; it’s merely expressing the way this person has (unconsciously) balanced present pleasure with future health and wealth.  That is, there isn’t really a reason to see the person as ‘predictably irrational’ unless we’re concerned with understanding the disjuncture between what they say and what they do.

This is revealing of the ‘nudging’ perspective on rationality.  Rather than assuming, like conservative philosophers such as Michael Oakeshott and John Gray, that humans are incorrigibly irrational, Thaler and Sunstein want to re-mould them as more rational.

Oakeshott and Gray would consider this not just a vain, but a dangerous aspiration.  I don’t want to get into that argument now (though I have some sympathies with it), apart from to note that ‘rationality’ as an aspiration can be problematic for policymakers as they often see rationality (like Thaler and Sunstein) as decided by final outcomes rather than the process of thinking.  Smoking or drinking to drunkenness are not by definition irrational; they are only irrational if they don’t reflect how a person ‘really’ values their future health compared to their current pleasure.

This brings us round to this idea of ‘real’ preferences again.**  Thaler and Sunstein are concerned to demonstrate the falsity of the (straw man) claim that ‘almost all people, almost all of the time, make choices that are in their best interest or at the very least are better than the choices that would be made by someone else’.

For this statement to make any sense, it seems to me that we first need to understand what ‘best’ choices are.  Mill might make the suggestion that there are many different ways of living, and any individual with a ‘tolerable’ amount of common sense should be trusted to make their own choices.  Thaler and Sunstein don’t agree, as shown by their analogy of making life choices: a novice playing an experienced player at chess.

Not only are the aims of chess clear (to win), but the rules are also laid down formally.  We can imagine that different people might have different rules (or conventions or scruples) for going through life, but more importantly we certainly don’t agree on what the ‘aim’ of it all is.  The analogy is bizarre – who is a grand master at living?  Can we all agree who that might be?

One might generously assume that they mean something more like every individual is playing their own ‘game of life’, with their own aim and rules.  However, there remains this assumption that even for an individual there is a clear goal.  This is clear from the writings of the LSE philosopher Luc Bovens.

Bovens is very much in favour of nudges – he goes so far as to say that we should be considering ‘whatever works’ and these could well work so we should not be concerned about ‘ideological commitments to . . . human agency’, for example.  This raises important questions about how we might assess whether something ‘works’, which I’ll come back to in a later post, but for the moment I want to think about how Bovens judges whether or not nudges are legitimate.

Rather than some idea of preserving liberty, or an individual’s personal choices, he takes Thaler and Sunstein’s approach that we should be trying to help people make choices that are ‘better’ than the ones they make for themselves, and judges that an intervention is reasonable so long as it maintains a person’s ‘preference structure’.  This is defined as a consistent, coherent ‘conception of the good’.

Note that Bovens is not suggesting we do actually behave in accordance with such a structure; the whole reason we need to be ‘nudged’ is that we don’t.  As he puts it, ‘We choose on the background of a fragmented self’.  The aim of nudging is to put us together into a coherent self.

To me it seems completely impractical that we could work out what someone’s putative ‘preference structure’ is (what actions should be discounted as mistakes, and what as reflecting the underlying ‘reality’?), but the issue isn’t one of practice but theory.  That is, I don’t believe this is even theoretically possible – still less desirable.

As John Gray suggests, there are many competing desires, identities and communities within societies – and indeed within individuals themselves – and no single rational solution to balance them up.  Moreover, these desires aren’t consistent over time and they won’t all reflect a coherent view.

Given that the most outstanding philosophers across the ages have struggled to put forward a coherent, consistent worldview, it seems unlikely that the rest of us will have mastered one in our everyday lives.  What is the singly expressed ‘aim’ of your life, by which your ‘rationality’ can be judged?  How can intoxication be weighed against health; or reading against playing football; or cake against cheese?  Which should I be ‘nudged’ towards?

Although Thaler and Sunstein mock classical economists with their homo economicus, they are actually lamenting the nature of the human condition – they would like people to be more like this fiction.  Nudge is a manual for how to deal with the fact that humans make ‘bad’ decisions – defined as those they wouldn’t make ‘if they had paid full attention and possessed complete information, unlimited cognitive abilities, and complete self-control.’  As they would be the first to point out, this calculating ideal doesn’t sound like a human – and I’m not sure I would want to live in a world where people behaved like this, even if it were only through ‘nudges’ from on high.  Is a world led solely by the Head an attractive vision?  (And whose Head?)  To err is human.

* I’m not sure this phrase is theirs originally, but it’s through their work that I’ve come across it.

** This is particularly interesting in the field of addiction.  Thaler and Sunstein, like many others, cite the example of smoking, and how the ‘overwhelming’ majority of people want to quit.  This is fascinating for me, as in discussions of addiction and treatment reference is often made to the idea that a person needs to have a ‘genuine’ desire and commitment to change, and this is quite different from simply stating that one would like to quit (particularly in a world where addiction is stigmatised).

Although I’ve not referenced them directly, my thinking on nudging has probably been coloured by reading Amir & Lobel, Burgess, Goodwin, Grüne-Yanoff and Selinger & Whyte.