Health Committee - The Government's Alcohol StrategyWritten evidence from Balance, North East (GAS 06)
Balance welcomes The Government’s Alcohol Strategy (2012) and its acknowledgement of the harms associated with current levels of alcohol consumption in England.
We particularly applauds the proposal of a minimum unit price for alcohol, and the recognition that affordability, as well as availability and marketing are all major factor in driving levels of excessive consumption and associated health harms.
We are pleased that strategy acknowledges the link between alcohol advertising and consumption, especially aimed at young people, but feel the ongoing involvement of the alcohol industry in public health campaigns is an area of great concern—It is our belief that the alcohol industry should not shape policy; further the measures proposed in the strategy are not strong enough and too vague. We would welcome the introduction of a version of France’s Loi Evin.
Overall the strategy is thin on detail and targets and says nothing about resources; this is a particular concern for treatment providers.
Overall Response to The Government’s Alcohol Strategy
1. Establishing who is responsible within Government for alcohol policy in general, policy coordination across Whitehall and the extent to which the Department of Health should take a leading role
1.1 The strategy, published by the Home Office, is light on detail, particularly in relation to targets and outcomes.
1.2 It is skewed towards a “law and order” agenda with the Prime Minister setting the tone in his introduction.
1.3 The choice of language suggests that alcohol problems in society can be placed at the feet of the “young binge drinker”; the “irresponsible” and the “ignorant”. It fails to set the problem in the right context, that of a population level issue which involves significant numbers of people drinking at levels of increasing and higher risk and one which affects everyone in the country either directly or indirectly.
1.4 DH ownership and contribution appears to be small. That being said we welcome support for Identification and Brief Advice (IBA) and Alcohol Liaison Nurses in hospitals. However, we support Alcohol Concern’s response to the strategy in stating the need “to ensure sufficient resources can be made available for alcohol services which has long been underfunded, if we are to match the aspirations set out in the strategy.”
2. Coordination of policy across the UK with the devolved administrations, and the impact of pursuing different approaches to alcohol
2.1 Alcohol policy should be coordinated across the UK. In the North East we share many of the problems of alcohol harm with our neighbours and we should be following a similar path, one which is based on sound, scientific, independent evidence. We believe, in particular, the level at which minimum unit price is set should be coordinated across the jurisdictions.
3. The role of the alcohol industry in addressing alcohol-related health problems, including the Responsibility Deal, Drinkaware and the role of the Portman Group
3.1 While Balance welcomes the Government’s recognition that the industry needs to do more, we don’t believe it should be playing such a central role in helping to shape Government alcohol policy. We believe there is a fundamental conflict of interest when corporations with a legal obligation to maximise profits for shareholders are involved in shaping public health policy.
3.2 Further, the evidence to date does not suggest that the alcohol industry will deliver the changes needed to reduce alcohol harm unless those changes are supported by legislation. For example, the industry failed to deliver on its promise to include labelling information on 50% of its products under the last Government. What’s more, to reduce alcohol harm we need to reduce the amount of alcohol consumed at a population level which goes against the industry’s responsibility to deliver maximum shareholder value. While supporting the Responsibility Deal, many alcohol companies and its representative organisations are active in undermining the international evidence base.
3.3 We are concerned that the strategy appears to rely on organisations which are totally funded by the alcohol industry. For example, the Portman Group plays a role in overseeing alcohol marketing while at the same time it has been publicly undermining the well established and independent evidence base supporting minimum unit price (eg Henry Ashworth, Chief Executive: “…calling for Soviet Union style population controls cannot do anything but alienate the vast majority of people who already drink within Government guidelines”).
4. The evidence base for, and economic impact of, introducing a fixed price per unit of alcohol of 40p, including the impacts on moderate and harmful drinkers; evidence/arguments for setting a different unit price; the legal complexities of introducing fixed pricing
4.1 Balance supports a minimum price per unit for alcohol as the best evidenced and most targeted way to address the problem of the affordability of alcohol (alcohol is 44% more affordable than it was in 1980).(1) The Sheffield study indicates that the introduction of minimum price would reduce consumption amongst harmful drinkers and young drinkers while having a minimal effect on those drinking within the guidelines.(2)
4.2 We welcome the bold step in committing to the introduction of a minimum unit price (MUP) for alcohol. However, many independent experts believe that an intended MUP of 40p per unit level to be too low.
4.3 The previous Chief Medical Officer called for an MUP at 50p, while Scotland is unlikely to introduce the measure below 45p and may go higher. A briefing paper released this month by the BMA Board of Science says “a minimum price for the sale of alcohol should be set at no less than 50p per unit, and this should be kept under review to ensure alcohol does not become more affordable over time.” Evidence from certain Canadian provinces which have MUP indicates that the measure should be regularly reviewed to maintain its effect.
4.4 Some have suggested that the introduction of MUP will lead to increased profits for the retail sector and in particular the large supermarkets. While the Scottish Government is looking to claw some of these back through the tax system, the strategy for England and Wales relies on the extra income from alcohol being used to reduce the price of other goods in store. We’d like to see how the Government propose to ensure this happens. The worst outcome would be that the profits are further used to increase the sophistication and reach of alcohol marketing.
4.5 A comprehensive analysis of 1003 sets of data from 112 studies, including information spanning two centuries and many countries, found a significant negative relationship between alcohol price and drinking.(3)
4.6 Should MUP be introduced at the level suggested by the previous Chief Medical Officer, namely at 50p, it would have the added advantage of closing the price differential between on and off licence premises. This would arguably protect small businessmen running community pubs as well as reducing the frequency of pre-loading.
4.7 In a survey carried out by Balance with 244 landlords across the North East, over half had seen a decline in business in the previous year; 72% saw customers arriving later due to pre-loading; 72% would welcome legislation to address cheap supermarket prices; and 81% would support the introduction of a minimum price in the North East.(4)
4.8 The North East public also supports action to address the affordability of alcohol. More people think supermarket alcohol prices are too cheap (35%) than too expensive (13%) and 56% said they would support the introduction of minimum price, an increase of 7% on the previous year. Support for minimum price increases if it is seen to address social problems, with 83% saying their support would increase if it addressed drunk and rowdy behaviour.(4)
4.9 The strategy includes the introduction of fiscal marks for beer, supply chain legislation, and a licensing scheme for wholesale alcohol dealers. These measures are currently the subject of an HMRC consultation and are an important area of work. In WHO Europe’s recent report Alcohol in the European Union: Consumption, Harm and Policy Approaches it says “the level of illegal trade and smuggling predominantly depends on the level of Government enforcement”.
5. The effects of marketing on alcohol consumption, in particular in relation to children and young people
5.1 Balance welcomes the recognition in the strategy of the role played by alcohol advertising and marketing in creating a pro-alcohol culture and in influencing young people to drink earlier and drink more. We especially welcome work to develop an effective online age verification system as alcohol companies increasingly move their advertising and marketing activity into the online arena.
5.2 Balance is concerned that the strategy does not contain sufficient specific proposals to reduce children’s exposure to alcohol advertising and marketing. Instead, it relies on working with a partially self regulatory system which is currently failing to protect our children and which, in the case of organisations such as The Portman Group, is totally funded by the alcohol industry.
5.3 Tinkering with the existing system won’t make a significant difference in terms of protecting our children. Balance would like an approach similar to that taken in France, whereby the promotion of alcohol would be restricted to media that adults use; at point of sale in licensed premises; at local producer events. Content would be restricted to verifiable factual statements such as alcoholic strength, composition, place of origin, means of production, and patterns of consumption and must carry explicit health information.
6. The impact that current levels of alcohol consumption will have on the public’s health in the longer term
6.1 The Office of National Statistics estimated that in the UK there were 8.664 alcohol-related deaths in 2009, which is more than double the 4,023 recorded during 1992.(6) By way of a comparison 1,738 people died due to drug misuse in 2008.(7)
6.2 In its publication “reducing alcohol harm” the British Liver Trust states “The challenge of alcohol misuse is reaching epidemic proportions in the United Kingdom; with the average intake of alcohol rising steadily, NHS admissions from alcohol increasing”(8) and cites the research that suggests that the current death toll from alcohol is equivalent to “a jumbo jet crashing every 17 days”.(9)
6.3 It is estimated that 80% of liver disease is directly related to alcohol and possibly around a quarter of the total attributable mortality. Liver disease is the fifth most common cause of death in England. However, the British Liver Trust warns that this prevalence is growing and “mortality from liver disease could overtake stroke and coronary heart disease as a cause of death within 10 to 20 years”.(7)
6.4 The British Liver Trust states that “there is unequivocal evidence of a relationship between alcohol consumption and liver disease” and goes on further to suggest that “liver death rates offer a good measure for the success of any alcohol policy”.(7)
7. Any consequential impact on future patterns of service use in the NHS and social care, including plans for greater investment in substance misuse or hepatology services
8. Whether the proposed reforms of the NHS and public health systems will support an integrated approach to future planning of services for people who experience alcohol-related harm
8.1 The proposed health reforms will see the responsibility for alcohol services move from NHS to local government; this reconfiguration offers partnerships and Directors of Public Health an opportunity to develop coherent, robust alcohol-harm-reduction programmes across health, voluntary sectors; social care; police, judicial, and licensing authorities.
8.2 is essential that Joint Strategic Needs Assessments don’t just focus on anti-social behaviour or criminal justice agendas. Areas should provide a range of treatment options in line with NICE Guidelines. There are fundamental distinctions between drug and alcohol problems. These differences mean the recovery pathways for alcohol misuse may differ to that of drug misuse. There is a danger, following the focus of “recovery” set out in the 2010 Drug Strategy, that there is a narrowing of focus and loss of recognition of guidance on alcohol use disorders. We would concur with Alcohol Concern that sufficient resources should be made available for alcohol services, if we are to match the aspirations set out in the strategy.
9. International evidence of the most effective interventions for reducing consumption of alcohol and evidence of any successful programmes to reduce harmful drinking, such as:
9.1 Public health interventions such as education and information:
9.2 Reducing the strength of alcoholic beverages:
9.3 Raising the legal drinking age:
9.4 Plain packaging and marketing bans:
(1) Tighe A (ed) Statistical Handbook 2007, Brewing Publications Ltd.
(2) Independent Review of the Effects of Alcohol Pricing and Promotion 2208 University of Sheffield.
(3) Wagenaar A C, Salois M J, Komro K A Effects of beverage alcohol price and tax levels on drinking: a meta-analysis of 1,003 estimates from 112 studies. Addiction 2009; 104: 179–90.
(4) Public Perceptions Survey 2011—produced by Balance, North East of England Alcohol Office.
(5) World Health Organisation (1992) The ICD–10: Classification of Mental and Behavioural Disorders: Clinical Descriptions and Diagnostic Guidelines. WHO. Geneva.
(6) Office for National Statistics Alcohol-related deaths in the United Kingdom, 2000–09 January 2011; Burki T Changing drinking patterns: a sobering thought Lancet 2010;376:153–4.
(7) Health and Social Care Information Centre Statistics on Drug Misuse: England, 2010 January 2011.
(8) www.britishlivertrust.org.uk—reducing alcohol harm.
(9) Assuming 500 seats on a 747 (http://en.wikipedia.org/wiki/Boeing_747–400).