HC 1048-III Health CommitteeWritten evidence from Association of Convenience Stores (PH 35)

1. ACS (Association of Convenience Stores—Annex 1) welcomes the opportunity to respond to the Health Select Committee Inquiry into Public Health. The restructuring of the NHS and the devolution of public health decision-making to a local level creates both opportunity and challenges for the retail sector.

2. This response covers the following issues:

ACS’ current public health initiatives and how they will be affected by the reforms;

the impact of the public health reforms on the business sector;and

the need for greater ownership of policy relating to the illicit tobacco and alcohol trade as part of the public health agenda.

Public Health Initiatives

3. ACS has worked with Government and other industry bodies to create voluntary partnership schemes which aim to tackle public health issues. Below is a summary of Community Alcohol Partnerships (CAPs) and the Change4Life convenience store project. These schemes are designed to be introduced at a local level in response to specific local problems and rely on strong relationships being created between local businesses, communities and other authorities. The devolution of public health responsibility should encourage the creation of these local partnerships. However there remains a role for national Government and industry representatives to make the case for partnership working and to provide support and encouragement where necessary.

Community Alcohol Partnerships

4. The Community Alcohol Partnership model was developed by the Retail of Alcohol Standards Group (RASG) and aims to tackle public underage drinking through co-operation between alcohol retailers and local stakeholders. CAP addresses both the demand and supply side of underage drinking through enforcement, education and public perception.

5. The key component in CAPs success is that it is based on partnership approach which sees retailers as part of the solution to underage drinking, not just part of the problem. All parties share information to ensure that issues relating to underage drinking, whether concern surrounding a retailer, proxy purchaser or certain underage drinking area, are tackled. This work goes hand in hand with joint confiscation operations between police and trading standards and educational sessions for pupils and parents in local colleges and schools highlighting the legal issues in attempting to purchase alcohol and raising awareness of proxy purchasing.

6. The impact of CAPs has been independently evaluated. In the trial area of St. Neots, Cambridgeshire evaluation showed:

a 42% decrease in anti-social behaviour incidents in the St Neots area from August 2007 (pre-project) to February 2008 (post-project);

a 94% decrease in under-age people found in possession of alcohol; and

a 92% decrease in alcohol-related litter at key hotspot area.

7. Kent County Council was the first area to introduce a CAP county wide and they had the scheme independently evaluated by Kent University. Overall results showed criminal damage down by 28% and total recorded crime was down by 16%.

Change4Life Convenience Stores Project

8. ACS has also been involved with the Change4Life convenience stores project, which encourages convenience store retailers to improve their offer of fresh fruit and veg and creates invaluable links between schools, health workers and retailers. The project has three aims:

increase access to and availability of fresh fruit and vegetables in convenience stores;

increase sales of fruit and vegetables by focussing on improving range, merchandising, quality and communication in stores; and

drive awareness of fruit and vegetables to the consumer through good sign posting within retail stores using the Change4Life brand.

9. Over 200 stores have taken part throughout England over a period of three years and have seen on average sales growth for fresh fruit and veg of 35%. This is particularly important for tackling health inequalities as many of these stores are in deprived communities and offer the only source of fresh and health food.

10. Retailers have to commit to reviewing their range of fresh fruit and vegetables, appointing a fresh food champion, introduce a fruit and veg marketing plan and using the Change4Life branding only on fresh fruit and vegetables. ACS is continuing our commitment with the project under the Responsibility Deal.

Impact of the Public Health Reforms on the Business Sector

11. While the shift towards localised public health decision making will facilitate the operation of localised schemes, it could also create significant problems for businesses, especially those operating on a national level. It has to be recognised that in many instances these problems will result in extra cost and burdens and a balance must be struck between localisation and business certainty.

12. There are clearly some public health policy areas which require a lead from national Government, either due to the complex nature of the evidence base or the associated legal complexities. For example any activities restricting price, promotions and siting clearly needs to be taken at a national level, due to the complexities surrounding European competition law.

Public Health Role of the Secretary of State

13. Despite the devolution of power, the Secretary of State needs to retain leadership for the direction of public health policy. In particular the Department of Health needs greater ownership for policies relating to the reduction of the illicit tobacco and alcohol trade. The illicit trade, particularly in tobacco products, is a threat to Government public health policies, especially those targeted at reducing health inequalities. A significant proportion of lower income smokers buy tobacco from illicit sources within the UK and young smokers are also likely to be at greater risk. It is clear that further efforts to control smuggling are probably the most important tobacco control measures that Government can adopt, particularly with a view to reduce underage smoking.

14. Yet current responsibility for this policy resides with HMRC at both a national and a local enforcement level, while for other associated legislation responsibility lies with the Department of Health. The Secretary of State needs to take responsibility for this issue, heading a regular cross-Government illicit trade policy meeting with representatives from HMRC and the Home Office.

15. With the Department of Health taking the lead, there could be a devolution of responsibilities relating to local inland enforcement to the Police and Trading Standards. Understandably HMRC focus their enforcement on preventing large cross-border shipments. However the inland illicit trade, which allows products to be accessed from tab houses, white vans and car boots, is not tackled with the same resource. Trading Standards and Police, who currently enforce other aspects of tobacco and alcohol legislation on the ground, have the networks with retailers and communities to more effectively tackle the issue.

16. Tackling the illicit trade for tobacco alone would significantly benefit the health service, leading to 4,000 fewer deaths caused by smoking-related illnesses and creating an increased tax revenue of £1.3 billion. It is clear and the responsibility for this issue must be transferred to the Secretary of State for Health as a crucial aspect of the Public Health remit.

Annex 1


ACS is the trade body representing the interests of over 33,000 convenience stores operating in city centres as well as rural and suburban areas. Members include familiar names such as The Co-operative Group, Spar and Costcutter, as well as independent stores operating under their own fascia. Our members operate small grocers, off-licence or petrol forecourt shops with between 500 and 3,000 square feet of selling space.

June 2011

Prepared 28th November 2011