The issue of “Harm Minimisation” is always a topical issue for licensed venue operators. It is referenced in section 3 of the Liquor Act 1992 as one of the main purposes of the Act and in section 1A of the Gaming Machine Act 1991. It has also been a hot topic in the news from the Office of Liquor and Gaming Regulation (OLGR). As such, it is not something you can selectively do when you want, in fact, it is something that must be at the core of many of the decisions you make when managing and planning the operation of your venue.
It is not my position to advocate on behalf of the regulatory agency, but I am mindful of their focus on this matter and some of the matters that they would like to see being addressed in more proactive ways, specifically as they relate to the provision of gaming machine services.
Of course, I am sure that all gaming venue operators are doing their best to comply with their RSG Policy and meet the standards of the Qld Responsible Gambling Code of Practice (the Code).
However, as previously advised in another article the agency is now endorsing conditions (primarily harm minimisation based) on to Gaming Machine Licenses (GMLs) both newly issued ones and those that have been subject to relevant applications for variations or changes.
These conditions are a clear indication of what the Commissioner’s expectation of gaming licensees is, particularly as it relates to the actions they are taking, or should be taking at their venue, to minimise the potential harm from gambling.
Obviously, if you are not making changes to your GML you are not necessarily required to update or amend your RSG, however it could be said that regardless of what you are doing, or not doing with the GML and gaming services, the RSG Policy still needs to be relevant and reflect current practices and community expectations.
To this end I would strongly recommend that gaming licensees take some time to review their RSG Policy too see when it was prepared and/or last updated, then genuinely ask themselves, how does it ‘stack up’ against these latest expectations, does it reflect the venue’s best practice and is it working towards minimising any potential harm from gambling?
If you should need any assistance with this process or you would like to discuss the matters I have raised above, please feel free to contact me direct.
Further, I would also suggest that if you are going to take the time to review your RSG Policy you should also do likewise with your RAMP. I have recently reviewed a number of venue RAMPs and identified that they contained redundant information, did not reference current matters that they should and some referenced matters of procedure, which would be better placed in the Staff Procedure / Operating Manual.
Remember if you put it in your RAMP then you should be complying with it – as such, being too specific can impact on your ability to vary your day-to-day operational practices, without ‘breaching’ your own RAMP. As such, all of the required matters need to be assessed, but you should be mindful of the language and detail used to confirm this has been done.
As with the RSG Policy, if you would like to discuss the updating of your RAMP, please feel free to contact me for a chat.
John Dickson | firstname.lastname@example.org | 0417 721 942
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