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« Letter of the week! | Main | Europe: the bigger picture »

Pub closures: response from the Department of Health

Last month I wrote to public health minister Anne Milton who seems to believe that there is little or no correlation between smoking bans and pub closures. I don't make a habit of making public letters sent to MPs, ministers or civil servants, but there are exceptions to every rule.

My letter was sent on behalf of the Save Our Pubs & Clubs campaign:

Rt Hon Anne Milton MP
Parliamentary Under Secretary of State for Public Health
Department of Health
Richmond House
79 Whitehall
London SW1A 2NS

Dear Minister,

Pub closures and the smoking ban

You are quoted in the Morning Advertiser on 25 November declaring that “there is little, if any, evidence that would link the closure of pubs and clubs to the introduction of [the smoking bans]”.

A quick look at a report in the Guardian (12 April 2010) should give pause for thought. This sets out the British Beer and Pub Association research on pub numbers in the UK from 1980 to the present. These data are part of a series stretching back decades.

Over the period 1990-2010 the total number of pubs has indeed shown a long-term decline from around 63,500 to 52,000:

UK pub numbers 1990-2010
(source British Beer and Pub Association)

1990 63,500
1991 62,200
1992 61,600
1993 61,000
1994 60,700
1995 61,000
1996 60,800
1997 60,600
1998 61,000
1999 61,500
2000 60,800
2001 60,700
2002 60,100
2003 59,400
2004 59,000
2005 58,600
2006 58,200
2007 56,791
2008 54,818
2009 53,466
2010 52,000

However, a little analysis demonstrates the considerable acceleration of the trend from the end of 2006 – the last data point before the bans in England, Wales and N Ireland.

The period from 2006-10 showed an average closure rate of 2.7% a year - over four times as fast as the long-term trend of 0.6%. In other words, on average more than a thousand more pubs closed each year after the bans than before.

Years Change in UK pub numbers
1990-4 -1.10%
1994-8 -0.10%
1998-2002 -0.40%
2002-6 -0.80%
2006-10 -2.70%

Average trend ... pubs closed per year
Pre-ban (1990-2006) -0.60% ... 331
Post-ban (2006-10) -2.70% ... 1550

Given the frequent references to the impact of the smoking ban by licensed trade associations and companies this is likely to be much more than just a coincidence.

Please find attached a research paper that examines the pub closure data in more detail. This shows an almost exact correlation between the rates of decline in pub numbers in Scotland, England, Wales and even the Republic of Ireland, when viewed in comparison to the varying dates of their bans.

All of these data are publicly available. Given the commitment of the Government to a private sector-led recovery, the closure of more than a thousand businesses a year in a key part of the economy surely requires a more thorough investigation and review.

I look forward to your response and hope that the Government will review its decision not to review the smoking ban in accordance with a commitment given by the previous government.

Yours sincerely,

Simon Clark

Yesterday I received a reply - not from Anne Milton (who is too busy schmoozing with ASH!!) - but from someone in the DH's "Customer Service Centre" which sounds more like something you'd find in Kwik Fit than a government department.

Needless to say, the DH has completely ignored the gist of my letter (I expected nothing else), but judge for yourself:

Dear Mr Clark

Thank you for your letter to Anne Milton about smokefree legislation. I have been asked to reply.

In preparing the smokefree legislation, the Government of the time considered the possible economic impact on pubs and the hospitality trade of taking action on secondhand smoke. A Regulatory Impact Assessment (RIA) was published alongside the Healtj Bill. The RIA contains estimates of cost and benefits of legislation to end smoking in enclosed public places and workplaces. A copy is available on the Department of Health website at

Closures in the pub industry and general hospitality sector were covered at the time of Parliament's consideration of the legislation in 2005/2006 and the Regulatory Impact Assessment published at that time includes the following statement (paragraph 323 on page 10, final sentence):

Given the evidence from other countries, as well as in England, the Department of Health understands that it is likely to be prevailing economic, structural and cultural issues, rather than the introduction of smoke-free legilation, which will be primary cause of any significant decline in the sector.

The Government believes that people should have the choice to smoke, but that it is also right that people are both made aware of the major health risks of smoking and are provided with support to quit.

Therefore, by increasing the information available about the dangers of smoking and providing support to individuals who want to stop, the Government can hope to reduce smoking by helping people make the choice or not to start or to give up.

At the same time, it is right that others should be protected from exposure to harzardous secondhand tobacco smoke. The smokefree legislation eliminates smoking in virtually every enclosed public place and workplace in this country.

There is a clear evidence that the smokefree legislation is working very well and almost all enclosed workspaces and public places are free from secondhand smoke. Many families are now voluntarily making their homes smokefree, reducing children's exposure to secondhand smoke.

Public support for the smokefree law is high and continues to grow. Even a majority of smokers now support the law. Because of this, ministers see no reason to review it.

I should also point out that the smokefree provisions in the Health Act 2006 were carried on free votes across all parties by large majorities in both Houses of Parliament. This Parliamentary support for smokefree legislation reflected the very widespread public support.

Smoking is the largest single cause of preventable illness and premature death in the UK. It kills over 100,000 people every year and a recent academic study suggests that the cost to the British taxpayer is more than £5 billion a year. It causes 84 per cent of deaths from lung cancer and 83 per cent of deaths from chronic obstructive lung disease, including bronchitis.

Medical and scientific evidence also shows that exposure to secondhand smoke increases the risk of serious medical conditions such as lung cancer, heart disease, asthma attacks, childhood respiratory disease, sudden infant death syndrome and reduced lung function.

I realise that this reply is likely to be disappointing, but I hope it clarifies the Department's position on the matter.

Yours sincerely,

Customer Service Centre

Now, I'm not naive enough to have expected any other reply, but it is interesting that rather than address the issue of pub closures that have occurred since the smoking ban, the DH continues to quote from the Regulatory Impact Assessment that was carried out in advance of the smoking ban, despite the very clear evidence that the number of pub closures has increased enormously in the period since the ban.

I'm not going to fisk the DH's letter line by line because I can't be bothered, but one line does annoy me: "Parliamentary support for smokefree legislation reflected the very widespread public support".

I don't need to tell readers of this blog that this is simply not true. It may reflect opinion polls commissioned by ASH (that offered people a straight choice between smoking or smokefree without the option of, for example, separate smoking rooms) but it certainly doesn't reflect the surveys carried out by the Government's own Office for National Statistics that consistently found that a substantial majority (approximately 70 per cent) were opposed to a comprehensive ban.

Of course public opinion has changed a bit as non-smokers (and even some smokers) have got used to smokefree pubs and clubs, but not as much as the tobacco control lobby would have as believe.

On a more positive note, the response from the DH may be disappointing (if unsurprising) but the tone of the letter is well, neutral, and that is a significant improvement on previous years. Others too have commented upon the fact that, under Labour, letters from the DH were cool if not downright hostile.

Sure, public health minister Anne Milton and ASH's Deborah Arnott are birds of a feather. But until we hear more about the Coalition Government's tobacco control strategy it's not all doom and gloom.

Our understanding is that, unlike the previous regime, the new Government is at least listening, even if they spout the same old mantra. So my message is, keep writing to the DH and the relevant ministers.

More important, if you haven't already done so, is to write to your local MP. By and large, organised letter writing campaigns don't work. They're easy to spot and MPs will usually ignore them. A letter from an individual constituent - that's different.

Feel free to recycle the statistics in my letter to Anne Milton but the letter should be in your own words and no more than two sides of A4. You can also send them a copy of our Smoking Gun report.

Let me know if you get a response.

Reader Comments (12)

I have 2 similar PDF copies of the RIA, one unsigned has a printed date of December 2006 and the other copy is signed by Caroline Flint on 19.3.07!!!
The quote you were given is from paragraph 32 NOT 323 and is incorrect -- It should have read "....., as well as EXPERIENCE in England .... ".
You might ask what value can be put on such a statement when paragraph 69 specifically promised a review after 3 years. Is the RIA a fiction that only they can cherry-pick?
What might be an interesting exercise for the DoH Customer Service Centre would be to compare reality with the figures in the RIA.
How about the Revenue losses to the Exchequer from decline in cigarette sales OR the 'value' of Averted deaths from smokers giving up OR the Implementation costs OR Enforcement OR Education and communication OR, in fact, all the fictional figures.

January 13, 2011 at 17:32 | Unregistered CommenterChris

"I should also point out that the smokefree provisions in the Health Act 2006 were carried on free votes across all parties by large majorities in both Houses of Parliament. This Parliamentary support for smokefree legislation reflected the very widespread public support."

Almost 2/3 of the Tories who voted voted AGAINST the bill (55 Aye, 100 No)! THEY didn't believe paragraph 32 then, why should WE now?

January 13, 2011 at 19:55 | Unregistered CommenterJohnBoyWalton

Just out of interest, what have pubs or any other form of economy and business got to do with the Health Dept.? what has any review got to do with them? Businesses, failed or not, are not part of the remit of a Health Dept. What the hell would they know about any of it? Who gave them the right to veto business? Is this another leftover of the Blair era?

Bit of strict demarcation needed here.

January 13, 2011 at 19:56 | Unregistered CommenterFrank

How many ex-landlords, ex-bar staff, ex-customers of favoured locals has that wretched woman spoken to ?

As many, one would imagine, as the letters she's personally read from people like Simon.

Clearly, when Cameron says (as he is wont to do rather too often these days) "We're ALL in this together !", he is NOT including members of the Great British Public. In that sense, he must be congratulated for a rare piece of candour !

January 13, 2011 at 21:16 | Unregistered CommenterMartin V

I had a very similar reply from the DoH last September. My complaint was about the junk science in the 'Take 7 Steps Out' campaign. In the reply that I received, the author quoted exactly the same sentence about "100 000 deaths" that yours did. (Funny how Lansley said only 80 000 in his TV interview) My main point about the junk science was totally ignored.

Clearly, these people are following a script, although they changed the words around.

It is pretty clear that MPs who are in favour of the ban also have some sort of script - if Labour, I suppose that the script would be provided by the Party. My MP didn't even bother replying to a letter that I sent to her. But what should I expect? My MP is Quereshi.

January 14, 2011 at 0:06 | Unregistered CommenterJunican

It sounds very much as if you received a photocopy of my response from one of Anne Milton's faceless minions Simon. Not a certain Tim Morgan was it, or even our old friend Dora East?
Mine does say, however, that "the information given to you is the most up-to-date and accurate available, and there is nothing further to add."
I assume from that rather bald statement that as far as this government and/or the previous one are/were concerened, there have been no closures of any businesses of any kind, no increases in unemployment from the hospitality sector and/or sunsiduary businesses and that pubs & clubs are still teeming with people ever eager to be forced outside, rain or shine.
I received virtually the same reply 3 years ago from 'dear Dora so the songsheet hasn't altered much at all!
Phil Johnson

January 14, 2011 at 3:18 | Unregistered CommenterPhil Johnson

I find the ending very patronising 'the reply is likely to be disappointing'. It is, but not for the reasons they think - its disappointing because the reply fails to engage with any of the arguments Simon originally put.

January 14, 2011 at 8:57 | Unregistered CommenterMark Butcher

A "significant improvement on previous years?" Really? I haven't read anything more depressing on the subject. I thought the Tories were supposed to be less blinkered, but this seems like the same old lies and distortions to my mind.

January 14, 2011 at 22:55 | Unregistered CommenterRose W

I couldn't agree more, Rose.

"There is a clear evidence that the smokefree legislation is working very well and almost all enclosed workspaces and public places are free from secondhand smoke. Many families are now voluntarily making their homes smokefree, reducing children's exposure to secondhand smoke.

Public support for the smokefree law is high and continues to grow. Even a majority of smokers now support the law. Because of this, ministers see no reason to review it."

It's exactly the same old infuriating copy-and-paste verbiage one used to get in replies from Labour politicians, with its constant repetitions of the appalling propaganda term "smokefree" and its combination of barefaced lies ("a majority of smokers now support the law") and statements of the bleedin' obvious - yes, know we're not allowed to smoke in "enclosed workspaces and public places", and haven't been allowed to since July 2007. We're not stupid, you know. WE HAVE NOTICED.

PS Simon, can I humbly request that you refrain from using the term "smokefree" yourself? It's a made-up, Newspeak slogan and not a piece of proper English, and we should be doing all we can to eradicate it from our language rather than disseminate it more widely!

January 15, 2011 at 11:04 | Unregistered CommenterRick S

"we should be doing all we can to eradicate it from our language rather than disseminate it more widely............."

Rick - I support your sentiments (and your reasoning) entirely. But you're smart enough to know that - by now - it's far too late to eradicate the idea of 'smokefree'.

Why ? Because, as with all such examples of this particular case of Mind Control, the idea has now been repeated so often, and reinforced by the coercive power of the State so successfully, that it has become INTERNALISED - in much the same way as the habit of self-censorship crept into the East German psyche under Erich Honecker, the Chinese under Mao, the Russians under Stalin - and so on ad nauseam.

To my mind (which I tend to exercise rather more than is either politically or socially convenient at times), there is nothing more linguistically atrocious than 'Chair-person' or (God save us) 'Homophobia' (literally; 'fear of the same'), but who any longer has the energy or the temerity to challenge either the words or (more importantly) the faux-moral assumptions which their use implies ? Contrary to popular belief, there's NOTHING 'mad' about the MECHANICS of Political Correctness. And our wonderful Smokefree Culture - together with the language it has spawned - is merely Political Correctness with a stethoscope around its neck.

Remember what the torturer O'Brien said to Winston Smith in '1984':

"Power is tearing human minds apart and putting them back together in new shapes of your own choosing."

No fool - that O'Brien !

January 15, 2011 at 22:46 | Unregistered CommenterMartin V

Martin V.

You are right about 'smokefree', of course, but, like any similar slogan, it has a limited shelf-life. I do not know anyone at all who uses the word 'smokefree' in ordinary conversation, or, indeed, have I seen anti-smoking commenters using that word/phrase much. Once it has served its purpose, it will disappear.

What we have seen from Simon's article (re his letter) and the comments, is that the Health Dept is no longer a rational organ of Government - it is a propaganda machine (let us not confuse that dept with the actual NHS).

I vaguely hope (but do not expect) to see a simple sentence in the press one day. That statement would be something along the lines of:

"The Prime Minister announced today that the Health Dept and the Health and Safety Dept are to be rationalised. He said that there was too much duplication. A thorough review of the purposes and duties of these depts would be instituted."

the outcome of such a review might be very revealing.

January 17, 2011 at 1:02 | Unregistered CommenterJunican

"I do not know anyone at all who uses the word 'smokefree' in ordinary conversation............"

Indeed not, Junican ! But that is my point. The WORD may not be used in conversation simply because the CONCEPT has become so embedded in people's psyches that it's now practically beyond dispute that:


Rather like the declining fashion for Child Sacrifice, in fact !

January 18, 2011 at 11:32 | Unregistered CommenterMartin V

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