Why there’s no point trying to define a “substantial meal.”

As new Covid tier rules in England threaten to decimate the pub industry, there’s no neo-prohibitionist conspiracy here: just an indifferent government that’s too lazy to help.

N.B. Updated 3rd December with new information regarding “contracting arrangements” with food providers for pubs that don’t have a kitchen.

From tomorrow, 32 million people – 56% of the population of England – will be living under Tier 2 restrictions. In this tier, they will be allowed to drink in pubs, but only if they are also eating a “substantial meal”.

This has led to an increasingly entertaining/depressing/frustrating (delete according to how much skin you have in the game) national conversation about what constitutes a “substantial meal.” Government attempts to clarify the rules over the last few days have revealed a shocking lack of thinking behind them.

Most people I’ve seen discussing the issue in both mainstream and social media assume that the rule is in place to discourage immoderate drinking, which could in turn lead to a loss of inhibition and lower willingness to comply with social distancing rules.

That’s a big assumption – when pubs reopened after Lockdown 1 on 4th July, the media universally predicted a wave of drunken behaviour that would lead to a surge in new cases. That wave never materialised. But let’s run with the assumption for a moment.

The Science Bit

Alcohol is absorbed into the bloodstream slowly from the stomach, and rapidly from the small intestine. Having food in the stomach slows down the passage of alcohol to the small intestine while also allowing enzymes in the stomach more time to break down and deactivate the alcohol. So drinking on a full stomach doesn’t just slow down your alcohol absorption; its means you end up absorbing less alcohol overall.

So there is some logic here: if you believe (despite lack of solid evidence) that drunker people are less likely to observe social distancing and other measures to prevent potential Covid spread, mandating that they can only drink while eating would help reduce – or at least slow down – potential drunkenness.

Getting eggy with it

So how much food do we have to consume to get this effect? Well, this is where it gets complicated. Not to mention utterly ridiculous. Because the government appears to have no idea.

In October, we were told that a Cornish pasty was a substantial meal, but only if you order it with chips or a side salad – as you do. Yesterday, another cabinet minister told us that a Scotch egg counts, only to be swiftly contradicted by the Prime Minister’s office, which was in turn contradicted again by Michael Gove half an hour ago, after I had already started writing this. Evidently, the government cannot agree on what is and is not a substantial meal.

Another problem is, what’s substantial for one person is different for another. I have friends who would be full after one Scotch egg, and others who could eat a platter full. The amount of food needed in the stomach to slow down the absorption of alcohol varies from person to person.

If we were looking for an average though, let’s say we were to split the calorific difference between a Scotch egg (around 300-340 calories) and a Cornish pasty (700-900 calories) we might get to, say, an average of 500 calories (a Ploughman’s or a cheese and tuna panino, but not a chicken fajita wrap) as the boundary between what’s substantial and what’s not.

But we’d be wasting our time.

The reason it doesn’t make sense is that it’s got nothing to do with the size of the meal

As pub operators have asked for clarification, more rules have been made up – sorry, made clear.

Firstly, you can’t have another drink after you’ve finished eating. This makes no sense at all. You can order your first drink when you order your food. You can also presumably order more drinks while you’re waiting for your food to be delivered to the table. These drinks will, by definition, be drunk on an empty stomach, the alcohol flowing straight into your small intestine and from there into your bloodstream within minutes. But once you’ve finished eating – when your stomach is at its fullest and therefore when you will absorb alcohol at the slowest rate – you’re not allowed to drink alcohol any more. Notwithstanding the fact that eating a meal can break down a small amount to the alcohol already in your system (but not enough to make much difference) this makes nonsense of the idea that these measures will have any effect in reducing the drunkenness that arguably wasn’t going to be there to begin with.

Secondly, it seems the calories are only substantial if they come from the pub’s own kitchen. Wet-led pubs that have takeaway menus allowing you to order from nearby pizzerias or chips shops have been informed that these meals don’t count. Neither are you allowed to take your own packed lunch to the pub, no matter how substantial it is.

One bit of good news, however, is that, despite some contradictory messages over the last week or so, the official guidelines state that “pubs that don’t normally do food may enter into a contracting arrangement in order that they are able to do so and remain open.” There’s no detail offered beyond that, and I’ve heard that some taprooms have been told the money must got through the pub’s till rather than the food provider’s, but with a bit of jiggling, it looks like, for example, tap rooms that have arrangements with food trucks could remain open.

The “substantial meal” rule has absolutely nothing to do whatsoever with slowing the absorption of alcohol into the bloodstream. Trying to define what counts as “substantial” via calorie counting or physical volume – as a reasonable person would – is a waste of time because it is absolutely irrelevant to the definition of a substantial meal. The Scotch egg thing is simply a side-show.

You know perfectly well what the rules are

Obviously then, many pubs set to enter Tier Two have been seeking clarification on what is going on – only to be told they already know. This was a consistent line across several interviews yesterday, when ministers were asked what constitutes a substantial meal.

“There is, to be serious, there is a well-understood definition of what a substantial meal is,” said Michael Gove, seconds after demonstrating that this was emphatically not the case, in what is sure to become known as #ScotchEggGate. The PM’s spokesman with whom he was disagreeing also insisted that “Bar snacks do not count as a substantial meal… It’s well-established in the hospitality industry what does.”

As confused publicans urgently seek clarification in order to determine whether they can reopen or not in Tier Two, desperately trying to avoid breaking the rules if they decide to, the government’s response is basically that old stereotype of a passive aggressive argument in a relationship:

“What’s wrong? Why are you angry?”

“You know why.”

“No I don’t. What have I done?”

“You know very well what you’ve done.

“If I knew, I won’t be asking, would I?”

The pub industry is asking what constitutes a substantial meal, only to be told it knows perfectly well what a substantial meal is, even though the government can’t agree with itself on what counts as a substantial meal.

This is not a stereotype from a relationship. This is not the argument you had with your little brother when you were twelve. This is the British government, guiding the country through a pandemic while trying not to crash the economy. Makes you want a drink, doesn’t it?

Reading a little more closely though, and we can see not only what they’re talking about, but why.

Are you sitting comfortably?

According to the Covid-19 winter plan, “Venues that serve alcohol can only remain open where they operate as if they were a restaurant, which means serving substantial meals (and accompanying drinks).”

This is where the phrase “substantial meal” comes from. This is why it’s important. It’s got nothing to do with the speed of alcohol absorption; it’s saying effectively that pubs are not allowed to operate as pubs: they are only allowed to operate as if they were restaurants.

The guide goes on to define a substantial meal as “a full breakfast, main lunchtime or evening meal”. Eat your Cornish pasty (with side salad, obvs) between noon and 3pm, and it counts. Between 4pm and 5pm, I’m guessing it doesn’t.

As well as the time of day, the key thing that makes a meal substantial or not is how it is served. When George Eustice was bullshitting on the hoof, what he actually said was, “I think a Scotch egg probably would count as a substantial meal if there were table service.” (my italics).  

This is why bar snacks, packed lunches and takeaways don’t count. If a pub behaves as a restaurant, customers remain seated and have table service on plates (I’m guessing boards, baskets and those wanky miniature shopping trolleys count here too) of food cooked in the restaurant kitchen. As ministers continue their public argument about Scotch eggs, the one thing they’re all consistent on is that it has to be table service. People have to be sitting down and have their food brought to them. The pub must behave as if it were a restaurant.

From this, it seems the “pubs must behave as restaurants” wheeze is all about restricting movement around the pub. That’s fair enough. But before Lockdown 2, pubs were already table service only. If you wanted to move around, you had to put on a mask. If you didn’t have a table, you couldn’t be served. So the substantial meal rule is designed to create a situation that was already in place. Unless there is good reason to believe that the previous regulations were not working – and I’ve not seen anything that suggests they weren’t – the substantial meal rule is not just devastating, not just nonsensical, but also completely unnecessary.

So why is it being introduced?

There have been suggestions of a conspiracy to destroy pubs, driven by the neo-prohibitionists. While I’ve written about their skullduggery many times, I don’t believe they’re behind this. With most conspiracies, where you suspect some secret organisation behind the scenes, it’s really just crap people fucking things up.

As it dishonestly claims to “follow the science,” this government has in reality allowed public opinion to guide its Covid response to a significant degree. The strategy of leaking ideas for Covid measures to mates in the press, and then gauging the response before deciding whether to implement them, is both cowardly and grossly irresponsible, but it has been the consistent strategy of Johnson’s government throughout the pandemic.

We occasionally hear nonsensical sentences like “We’ve got to close pubs to keep schools open,” as if allowing people to go for a pint makes kids more likely to come home with Covid after double maths. What it actually means is that all Covid restrictions are unpopular, but the public will accept some before others. Going to the pub is seen as a luxury – a sin even – especially by people who never go to pubs and have no idea what they’re like. The government has to be seen to do something. And we’ll just about accept pub closures because, despite my protestations to the contrary, it does make logical sense to some people that we might behave more irresponsibly after a drink (but not if we buy it from Tesco of course.)

The substantial meal rule came in simply because it sounds like a tough restriction, one that seems to make sense, even though the logic we all might assume actually has nothing to do with the decision. The lazy-arsed thinking behind such a cynical move also led to them to not think it through properly, and not bother to come up with a coherent set of answers to questions people were obviously going to ask.

That’s the problem with being lazy – you just create more work for yourself down the line.

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