Science and Technology Committee HC 1536 Alcohol GuidelinesWritten evidence submitted by the British Medical Association (AG 27)

The British Medical Association (BMA) welcomes the opportunity to submit evidence to the Committee’s inquiry on the evidence base for alcohol guidelines.

The BMA has looked extensively at the issue of alcohol-related harm, and has published a number of reports in this area, which includes Under the influence—the damaging effect of alcohol marketing on young people (2009), Alcohol misuse: tackling the UK epidemic (2008) and Fetal alcohol spectrum disorders: a guide for healthcare professionals (2007). These reports have been used to inform this submission, and can be accessed at www.bma.org.uk/alcohol.

The BMA has not considered the evidence base for the Government’s guidelines on alcohol, or how the UK guidelines compare with other countries. As such, our submission focuses on the BMA’s policies in relation to the Government’s approach to communicating its guidelines on alcohol and the risks of alcohol intake to the public.

Evidence

1. A significant proportion of individuals in the UK drink above recommended UK guidelines. Most recent figures from the Office for National Statistics (ONS) show that in 2009, 22% of those consuming alcohol exceeded recommended UK drinking guidelines.1 This equates to 26% of males and 18% of females.2 The greatest proportion of men exceeding recommended drinking guidelines in 2009 were aged 45 to 64, whereas women aged 16 to 24 exceeded drinking guidelines the most.3

2. Much of the strategy to reduce alcohol related harm in the UK focuses on recommended drinking guidelines. While most people are aware of the existence of recommended drinking guidelines, few can accurately recall them, understand them, or appreciate the relationship between units, glass sizes and drink strengths.4,5,6,7,8 A 2009 ONS survey of adults in the UK, found that 75% of adults had heard of daily drinking guidelines, however, having heard of daily recommended levels did not necessarily mean that people understood what they were.9 The percentage of people who said they had heard of, but did not know the recommended limits in 2009, was around 30%.10

3. To ensure greater knowledge and understanding of UK drinking guidelines, the BMA recommends mandatory labelling of all alcoholic beverage containers. We believe it should be a legal requirement to prominently display on all labels information on alcohol content in units, recommended daily UK guidelines for alcohol consumption, and a warning message advising that exceeding these guidelines may cause the individual and others harm. It should also be a legal requirement to prominently display at all points where alcoholic products are for sale information on recommended daily UK guidelines, and a warning message on exceeding these guidelines.

4. The mandatory labelling of alcoholic beverage containers, along with point of sale information, will provide a useful method of increasing awareness of recommended drinking guidelines and health warnings, as well as supporting other alcohol polices that reduce alcohol-related harm. Labelling of alcoholic beverage containers and point of sale information, should be supported by information resources on what the recommending guidelines are, and what the effects of “exceeding” these limits can be, as well as sources of help and support to those recognising they may have a problem.

5. The BMA believes that this labelling and point of sale information should be mandatory, as the existing self-regulatory approach is ineffective, and has resulted in variable and limited market coverage. 11 Industry self-regulation has at its heart a conflict of interest that does not adequately address individual or public health.12 Assessments of compliance must be effectively measured and enforced by a genuinely independent body, with strong and meaningful penalties for non-compliance.

6. In relation to alcohol consumption during pregnancy, there is clear evidence that drinking heavily during pregnancy impacts on the development of the fetus, and it is as yet unclear whether there are any safe levels of maternal alcohol consumption.13,14,15,16,17 While there is no conclusive evidence that drinking at the maximum levels recommended when pregnant is harmful to the fetus, evidence continues to emerge on the possible risks of prenatal alcohol exposure at low to moderate levels.18,19,20,21,22,23,24,25 Given the current ambiguity regarding the level of risk to the developing fetus, as well as the reported underestimation or uncertainty of drinking guidelines by the public, the BMA believes the only safe sensible drinking message is not to consume any alcohol during pregnancy.

Professor Vivienne NathansonDirector of Professional ActivitiesBritish Medical Association

September 2011

References

1 Robinson S & Lader D (2011). Smoking and drinking among adults, 2009: a report on the 2009 General lifestyle Survey. Newport: Office for National Statistics.

2 Robinson S & Lader D (2011). Smoking and drinking among adults, 2009: a report on the 2009 General lifestyle Survey. Newport: Office for National Statistics.

3 Robinson S & Lader D (2011). Smoking and drinking among adults, 2009: a report on the 2009 General lifestyle Survey. Newport: Office for National Statistics.

4 Hasking P, Shortell C & Machalek M (2005). University students’ knowledge of alcoholic drinks and their perception of alcohol-related harm. Journal of Drug Education 35: 95-109.

5 Gill F & O’May F (2006). How “sensible” is the UK sensible drinking message? Preliminary findings amongst newly matriculated female university students in Scotland. Journal of Public Health 29: 13-6.

6 Plant MA & Plant ML (2006). Binge Britain: alcohol and the national response. Oxford: Oxford University Press.

7 Office for National Statistics (2010). Drinking: adults’ behaviour and knowledge in 2009. London: Office for National Statistics.

8 HM Government (2007). Safe. Sensible. Social: the next steps in the national alcohol strategy. London: The Stationery Office.

9 Office for National Statistics (2010). Drinking: adults’ behaviour and knowledge in 2009. London: Office for National Statistics.

10 Office for National Statistics (2010). Drinking: adults’ behaviour and knowledge in 2009. London: Office for National Statistics.

11 Department of Health (2010). Consultation on options for improving information on the labels of alcoholic drinks to support consumers to make healthier choices in the UK - response to consultation. London: The Stationery Office.

12 Babor T, Caetano R, Casswell et al (2003). Alcohol: no ordinary commodity. Oxford: Oxford University Press.

13 Gray R & Henderson J (2006). Review of the fatal effects of prenatal alcohol exposure. Report to the Department of Health. Oxford: National Perinatal Epidemiology Unit, University of Oxford.

14 Welch-Carre E (2005). The neurodevelopmental consequences of prenatal alcohol exposure. Advances in Neonatal Care 5: 217-29

15 Sokol R J, Delaney-Black V & Nordstrom B (2003). Fetal alcohol spectrum disorder. Journal of the American Medical Association 290: 2996-9.

16 O’leary C M (2004). Feta alcohol syndrome: diagnosis, epidemiology, and developmental outcomes. Journal of Paediatrics and Child Health 40: 2-7.

17 Royal College of Obstetricians and Gynaecologists (2006). alcohol consumption and the outcomes of pregnancy, London: Royal College of Obstetricians and Gynaecologists.

18 Gray R & Henderson J (2006). Review of the fatal effects of prenatal alcohol exposure. Report to the Department of Health. Oxford: National Perinatal Epidemiology Unit, University of Oxford.

19 O’leary C M (2004). Feta alcohol syndrome: diagnosis, epidemiology, and developmental outcomes. Journal of Paediatrics and Child Health 40: 2-7.

20 Royal College of Obstetricians and Gynaecologists (2006). alcohol consumption and the outcomes of pregnancy, London: Royal College of Obstetricians and Gynaecologists.

21 Mukherjee R A S, Hollins S, Abou-Saleh M T et al (2005). Low level alcohol consumption and the fetus. British Medical Journal. 330: 375-6.

22 Sood B, Delaney-Black V, Covington C et al (2001). Prenatal alcohol exposure and childhood behaviour at age six to seven years L I. Dose-response effect. Paediatrics 108: e34

23 Little J F, Hepper P G & Dornan J C (2002). Maternal alcohol consumption during pregnancy and fetal startle behaviour. Physiology and Behaviour 76: 691-4.

24 Hepper P G, Dornan J C & Little J F (2005). Maternal alcohol consumption during pregnancy may delay the developmental of spontaneous fetal startle behaviour. Physiology and Behaviour 83: 711-4.

25 Sayal K, Heron J & Golding J (2007). Prenatal alcohol exposure and gender differences in childhood mental health problems: a longtitudinal population-based study. Paediatrics 119: 426-34.

Prepared 5th January 2012