Police Reform and Social Responsibility Bill

Memorandum submitted by North West Directors of Public Health (PR 102)

Dear Mr Benton,

Committee consideration of licensing reform

I am writing to you to ask your committee to consider one aspect of the Government’s proposed licensing reforms further and advise the Government on a course of action. Laudably the Government has recognised the need to take account of the health impact of licensing decisions. As North West’s lead Director of Public Health on alcohol I am only too aware of the impact of the inadequacies of the current licensing regime on public health and the burden on the NHS.

The Government has indicated in its response to the consultation exercise that whilst it agrees that health bodies should be responsible authorities it does not feel able at this stage to bring forward proposals for a health harm objective in licensing. In my view this is unfortunate as a clear health objective will be necessary to give force to health bodies role as responsible authorities. This can be made to work effectively in conjunction with cumulative impact policies and I would urge the Committee to consider this.

Scottish licensing legislation has led us to understand the challenges of clarifying what data should be admissible in health terms. The lack of specificity in the Scottish health objective has lead to challenges for colleagues north of the border and accusations of vexatious representations. Given the lack of effective proposals to tackle very cheap alcohol such as a minimum unit price for alcohol (as opposed to the proposed below cost ban) it is essential that licensing can be effective as possible in addressing health harm in this bill and not a later stage.

There are many different sets of data collected within the National Health Service, and I believe that several of these would be vital to form a balanced opinion when considering an application and whether there should be an objection. The list should not preclude any other data sets that currently or may exist in the future if they are relevant to the case.

Data sets which are currently collected on a routine basis by the NHS which I believe would be the most efficacious when weighing up whether a health authority should object to an application are:

· Joint Strategic Needs Assessment

· Hospital Admissions– Alcohol related admissions

· Emergency Department Data

· Mortality Data – Alcohol related deaths

· Local Health Surveys

· Health Survey for England - Model-Based Estimates of Drinking

· Alcohol treatment data

Whilst I fully appreciate that the committee’s time will be very limited to consider existing aspects of the bill I would urge the committee to seek expert witness to advise on how a clear and specific health objective in licensing could be achieved.

I know you and your fellow members will be acutely aware of how pressing the alcohol harm issue is and hope you will give this issue due consideration.

January 2011