A Monash University report has highlighted the unfortunate bias so-called independent entities can show toward the gambling industries.

In 2015, the Faculty of Medicine, Nursing & Health Sciences’ Dr Charles Livingstone and Louise Francis released the Review of VCGLR decisions, and other gambling issues.

The report criticised the practises of the Victorian Commission for Gambling and Liquor Regulation (VCGLR) for approving 132 out of 142 applications received regarding increased numbers of EGMs at Victorian licensed venues.

Selected highlights were republished recently in Bayside News, with additional comments from Dr Livingstone stressing that such venues are “not pubs anymore, they’re not clubs, they’re not places attuned to family needs … they’re basically places that are enticing people to gamble and gamble quite a lot”.

PubTIC sought further clarification on this matter from Dr Livingstone, but was met with mostly unabashed defence of the principle that gaming operators and products are fully responsible for the “harm” caused to users.

Below is an abridged transcript of the correspondence of questions on the subject.



Do you believe there is a causal relationship (as opposed to correlative) between increases in EGMs and venues offering them, and problem gambling?

Dr Livingstone:

There is now sufficient research evidence to support the hypothesis that gambling intensity and gambling related harms (including problem gambling) is strongly associated with the accessibility of EGMs in local areas. This has been demonstrated by the work of the Productivity Commission (1999 and 2009), Rintoul et al (2014), Markham et al (2014), Wardle (2012). This is not a matter of belief, by the way. The evidence is very strong on this.


Neither study (Markham et al 2014; Rintoul et al 2014) addresses the issue of causation, only correlation. It is somewhat obvious that gaming venues will appear with higher frequency in areas with residents inclined to gaming.

Why are EGMs in licensed venues considered a ‘cause’ of problem gambling, given consumers ready access to online alternatives?

Dr Livingstone:

EGMs have been and remain the most risky form of gambling, as measured by those attending for gambling counselling, and by every prevalence study ever undertaken in Australia. This is because of their ubiquity, ready accessibility (particularly in areas where local populations experience high levels of stress because of socio-economic disadvantage, high mortgage loads, extensive travel times etc), high impact (both stakes and speed of wagering), and their location in areas of community social space. Although there is no doubt that online gambling is likely to become a major cause of gambling harm if allowed to develop without appropriate regulation, it is also clear that the scale of online gambling is very much less than that of EGM gambling, and that the technological capacity to require appropriate harm prevention and reduction measures is greater than that for EGMs. This is particularly so given the extreme resistance to harm prevention and reduction measures which current EGM operators have demonstrated.


Venues are required to display information and advisory notices on seeking help with problem gambling. It is equally likely that attendees have been provided opportunity due to these. This would skew the rate of EGM users, as most forms of gambling (including online) do not have such laws governing the display of help services.

Venues can never be as available as online – particularly since smartphones. (Refer chart on gambling revenue online since 2009)

One of the greatest problems with online gambling is that much of it is illegal and unregulated – making “appropriate regulation” meaningless.

If problem gamblers are assumed – how is it better to deter regulated environments such as licensed venues, when reduction will simply drive more problem gamblers to unregulated environments?

Dr Livingstone:

There is little evidence that EGM gamblers (whether classified as problem gamblers or otherwise) take up online gambling if EGMs are restricted. In any event, better regulation in both terrestrial and online environments is required in order to prevent and minimise harm. Please note that, at present, there is no mechanism in Australia by which a gambler experiencing severe harm as a consequence of their EGM use can be effectively identified, let alone restricted from continuing to gamble on EGMs.


What (if any) studies have been done to on online take-up following restriction? Consider this argument in terms of the success of the war on drugs, and other historic attempts at prohibition.

Whose choice is it to “identify and restrict” gamblers? While the product remains legal, it comes down to individuals’ right to choice. Government has no role to protect people from their own potential behaviour.

Is choice preference not demonstrated in your UK research, showing gamblers far prefer the more modern FOBT EGMs, over the Class C & D machines?

Dr Livingstone:

FOBTs effectively offer multiple game types, including automated table games, and many include EGM type-games, although as I understand the UK situation a roulette simulation is the preferred game on these devices.

The problems with FOBTs are the consequence of a situation similar to that posed by EGMs in Australia: they are now ubiquitous (especially in areas of social stress), high impact, with wagers of up to 50 pounds (previously 100 pounds), and rapid in their speed of wagering. In NSW, licensed clubs operate similar devices, as do many Australian casinos.


Your report says: FOBT EGMs make up 23% of machines and collect 64% of revenue, while Class C & D machines make up 63%, yet only generate 12% of revenue.

The choice preference by UK consumers is obviously FOBTs, demonstrating why removing the more exciting option for gamblers will not reduce tendency to gamble. They will simply seek alternative sources.

What prompts your suggestion that “access to EGMs is regarded [by VCGLR] as a community benefit”?

Dr Livingstone:

It is clear from our examination of decisions of the VCGLR that access to EGMs is interpreted commonly by Commissioners as providing a benefit to the community. This is based on the logic that some people enjoy EGMs and the ‘consumer’s surplus’ generated by their use constitutes an economic good.


So there is no evidence, just your assessment.

If taken as given that problem gambling is a serious problem for community, would efforts to reduce effects not be better spent focusing on help for these individuals, rather than blaming the retailers? Venues will naturally reduce their reliance on the revenue if it were not there.

Dr Livingstone:

It is convenient for the gambling industry to place the blame or responsibility for gambling harm on individuals affected, since this argument, if accepted, reduces the requirement for appropriate regulation and effective interventions. This is about as helpful to the harm reduction process as blaming individuals because they are infected with influenza.

There are multiple causes of gambling harm and many of these (in all likelihood the majority) relate to the nature of the gambling products. Clearly, EGMs are the single greatest cause of gambling harm in Australia (and, increasingly, globally). Appropriate regulation and reform of the operation and governance of this segment of the gambling industry is necessary if we are serious about reducing this harm.


Are you really suggesting people become gambling addicts due to the products, against their will?

Isn’t this tantamount to blaming chocolate retailers for obesity?

Dr Livingstone:

(No further comment.)


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