HARM MINIMIZATION CAN BE ACHIEVED BY A SYMBIOSIS BETWEEN GOVERNMENT, INDUSTRY AND INDIVIDUALS

Livingstone & Adams [1] highlight the nexus between distribution, density and socio-geographic location of electronic gaming machines (EGMs), commercial market forces and government reliance on gaming taxation revenue. They describe in detail the substantial expenditure associated with this form of gambling. However, population prevalence rates of around 1% obfuscate the fact that 5% of adults gamble regularly on EGMs with 16–28% of club and hotel patrons, respectively, meeting criteria for pathological gambling [2]. Problem gambling rates are undoubtedly greater in less regulated Australasian jurisdictions, for example, Macau, although patterns may differ; putative cultural factors contribute to baccarat and casino table games rather than EGMs being reported by treatment-seeking problem gamblers (personal communication, Lee Wai Wah Seiko, SKH Counselling Service of Problem Gamblers, Macau) in Macau. As articulated by these authors, regulatory framework and government attitudes shape the extent of social harm. Similar to Korn & Shaffer [3] and Williams, West & Simpson [4], Livingstone & Adams advocate for a public health approach that utilizes upstream strategies to minimize the serious harmful consequences experienced by problem gamblers. However, as pointed out astutely by Adams [5], governments maintain roles as legislator, regulator and beneficiary of gaming activity and are therefore exposed to an unenviable conflict of interest. This conflict is evident globally, where the expansion of gambling is linked partly to governments being forced to compete with cross-jurisdiction operators to retain revenue within their borders (see Meyer, Hayer & Griffiths [6] for an overview of gambling in Europe; Singapore's decision to open two casinos in response to loss of gaming revenue to Macau casinos). It is my contention that because of these conflicts governments will remain reluctant to pursue responsible gambling measures actively in the absence of community/political pressure. What is fundamentally needed is the establishment of a national independent authority that has governance, powers to inform legislation and mandate public health initiatives. I concur with and support Livingstone & Adams' concern that current symbiotic relationships between industry and government represent an unhealthy communion. This does not have to be the case. What is essential is to answer the question as to whom is responsible for what. I argue that the primary focus for responsible gambling is consumer protection; that is, the promotion of gambling within affordable limits. It is noted that all gambling-related harm stems from individuals exceeding personal discretionary disposable income and time. Thus, a reduction in demand and supply using public health and social regulation strategies will lead invariably to a reduction in gambling expenditure. It remains to be seen if attracting non-gamblers into the field or increasing the expenditure levels of recreational gamblers offsets this reduction. In principle, however, the distribution of consumption model supports the notion that a reduction in total consumption will result in a general decrease in population-based harm [7]. However, I consider that the focus applied by Livingstone & Adams is perhaps too narrow. It is my contention that a greater emphasis must be placed on the need for a collaborative approach between governments, industry and consumers if we are to achieve effective our goals of harm reduction. The requirement for a collaborative rather than adversarial position is clearly articulated in the Reno model [8]. Unfortunately, many readers have misinterpreted or used incorrectly the content of Blaszczynski et al.'s [8] paper to attempt to shift the focus of responsibility onto the individual. This is reflected, as Livingstone & Adams note correctly, in the gambling industry's preference to deflect responsibility by referring to neurobiological differences between problem and non-problem gamblers that suggest deficits reside within the individual. The recent Brochu versus Loto-Quebec out-of-court settlement determining that video lottery terminals (VLTs) (equivalent to EGMs) did not cause pathological gambling [9] is used to reinforce this argument. Paraphrasing the authors' title, Blaszczynski et al.'s [8] position is that a symbiosis should be formed between governments, industry and individuals to promote a culture of responsible gambling. In this context, governments retain an obligation to protect consumers. This is achieved by introducing evidence-based strategies to educate community members of the nature and inherent risks of gambling, determining policies regarding technical standards and placement of automatic teller machines (ATMs), restricting credit gambling and monitoring the effectiveness of strategies. The government's role is to determine the optimal density and distribution of gambling outlets that balance harm and participation in a currently legal recreational activity. Industry operators, on the other hand, are required to maintain the provision of ‘safe’ products and environments (removal of ATMs), staff training, timely and full information on the operation of products and chances of winning and the avoidance of exploitation and inducements and misleading advertising, and appropriate responses to those seeking assistance (self-exclusion and treatment services). Individuals retain the ultimate decision to gamble or not making informed choices based on accurate and timely information. All have equal obligations in the promotion of responsible gambling. Consistent with Livingstone & Adams, I contend that there is a need to revise policies that affect the availability, density and distribution of gambling, but this can only be achieved optimally if governments relinquish their dual relationship as regulator and beneficiary. This will not be achieved until the infrastructure for governance by a national independent authority is established. Only then will structural and situational variables contributing to problem gambling be modified effectively. None for this commentary. The author has received research funding from the gaming industry and government departments for various studies and commissioned reports, and has acted as a consultant to both government and industry operators on responsible gambling measures.

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