Alcohol misuse affects a large number of people. The current annual death rate from alcohol-related conditions is more than three times that for deaths in road accidents, and the cost to the NHS of treating such conditions is around 3% of its annual budget. The government's strategy is a welcome attempt to address some of these problems in a coherent way. The main focus of the strategy is the need to address public order issues. We agree that these are important, but we believe that the health impact of the misuse of alcohol is more insidious and pervasive.
Objectives and targets
The Committee believes it is important to ensure that the objectives of policy on alcohol are clearly stated and calibrated. The great majority of citizens enjoy alcohol without significant evidence of harm to their health. The Committee accepts that it is not possible to define a level of alcohol consumption which is, in any absolute sense, safe for all citizens at all times. We do not believe, however, that this conclusion should lead to disproportionate or heavy handed controls which are justified neither by public support nor evidence of proportionate health gain. The Committee also believes that healthy societies expect all citizens, both corporate and individual, to exercise their individual freedoms in ways which respect the rights and interests of their fellow citizens and observe shared standards of responsible behaviour. It is part of the function of Government to stimulate, lead and if necessary regulate, in order to encourage the development of this culture.
The Committee believes that an Alcohol Strategy should be seen as part of a wider public health strategy, and should contain some key quantified, alcohol-specific objectives which will provide both a framework for policy judgements and an accountability framework.
What is 'safe'?
Although we accept that it is a complicated issue, we regard a clearer, evidence-based definition of the health effects of alcohol consumption as fundamental to successful policy development in this area. The work of the Chief Medical Officer needs to be carried forward as a matter of urgency. Public Health England, acting independently of Government, then needs to use the outcome of the review as the basis for its promotion of public understanding of the issues, setting out the level at which harms are likely to result alongside sensible drinking guidelines.
Despite some perceptions that binge drinking is largely a public order issue, the evidence presented to us suggests that it does contribute to some of the long-term health harms that have concerned us. We conclude that these health problems need to be addressed no less urgently than problems with public order and anti-social behaviour.
Minimum unit price
The Committee welcomes the Government's decision to introduce a minimum unit price for alcohol. It is, however, struck by how little evidence has been presented about the specific effects anticipated from different levels of minimum unit price. The proposition that demand for alcohol is relatively price-elastic seems uncontroversial. Rather than relying on generalised statements about the effect of price on consumption, the Committee urges the Government to build its case for a minimum unit price by establishing direct links: between specific alcohol products and specific alcohol-related harms; between different levels of minimum unit price and the resulting selling prices for the products which are linked to alcohol-related harms; and the likely effect of different levels of selling prices for those products on demand for those products in the target range of households.
Given the Government's decision to introduce a minimum unit price, the debate has been about the level at which it should be set- whether it should be 40, 45 or 50 pence - but the setting of a minimum unit price will not be a one-off event. Once a minimum price is introduced, if it is judged to be successful, the level will need to be monitored and adjusted over time. A mechanism will need to be put in place in order to do this, but as yet there has been no indication from the Government of what it intends to do other than to consult on the price. One way of setting the level would be to establish an advisory body to analyse evidence and make recommendations to Government. Whatever mechanism is chosen should be used when setting the initial level of the minimum unit price to ensure that from the beginning the price is clearly evidence-based.
It has already been announced that the minimum unit price to be introduced in Scotland will be 50 pence per unit. There are practical arguments in favour of the same minimum price being set in England to avoid problems with cross-jurisdiction trading. Our main concern, however, is that the level of minimum price that is set should be evidence-based and designed to be effective. If the minimum unit price in England were to be fixed at a different level to that in Scotland, we would expect the evidence supporting that decision to be set out clearly. This is another argument in favour of establishing a transparent mechanism for setting the price.
The evidence we have seen does not convince us that a ban on multibuys is either desirable or workable. The proposed minimum unit price will provide a floor price for the sale of alcohol, including discounted sales. The Committee supports the principle of setting the minimum unit price at a level which is effective at reducing identified alcohol-related harm; it believes that an attempt to outlaw well-established and convenient retailing techniques for alcohol products, regardless of price level, would simply create opportunities for retailers to find innovative and newsworthy work-arounds which would invite ridicule and bring the wider policy objective into disrepute.
Challenging the industry to act responsibly
Messages contained in alcohol advertisements play an important part in forming social attitudes about alcohol consumption. The Committee believes that those involved in advertising alcoholic products should accept that their advertisements contain positive messages about their products and that these messages are supported by considerable economic power. If this were not the case it is not clear why shareholders should be content for their companies' resources to be spent in this way. Since it is true, however, it is important that the alcohol industry ensures that its advertisements comply in all respects with the principles of corporate social responsibility. Closer definition of these principles as they apply to alcohol advertising is a key objective of the Government's Responsibility Deal.
The Committee does not believe that participation by the alcohol industry in the Responsibility Deal should be regarded by anyone as optional - we regard it as intrinsic to responsible corporate citizenship. We welcome the willingness of the industry to address the harms that alcohol can cause but we believe that it should be clear that the Responsibility Deal is not a substitute for Government policy.
It is for the Government, on behalf of society as a whole, to determine public policy and ensure that a proper independent evaluation of the performance of the industry against the requirements of the Responsibility Deal is undertaken. We recommend that such an evaluation is commissioned by Public Health England. We will be particularly interested to see the assessment of the effect of reducing the alcohol level in certain drinks. We do not believe that reducing the alcohol in some lagers from 5% to 4.8%, for example, will have any significant impact. If the industry does not being forward more substantial proposals than this it risks being seen as paying only lip service to the need to reduce the health harms caused by alcohol.
Expectations within the Responsibility Deal
The Committee is concerned that those speaking on behalf of the alcohol industry often appear to argue that advertising messages have no effect on public attitudes to alcohol or on consumption. We believe this argument is implausible. If the industry wishes to be regarded as a serious and committed partner in the Responsibility Deal it must acknowledge the power of its advertising messages and accept responsibility for their consequences. The industry will take a significant step down this road when it makes it clear that alcoholic products should not be marketed in ways which address audiences a significant proportion of whom are aged under 18, and cannot therefore legally purchase the product.
Advertising of alcoholic products on television is subject to rules which are relatively targeted and sophisticated. The Committee believes there is scope to apply these principles more widely and recommends that this principle be reviewed in the context of the Responsibility Deal. Serious consideration should be given to reducing to 10% the proportion of a film's audience that can be under 18 and still allow alcohol to be advertised, or to prohibiting alcohol advertising in cinemas altogether except when a film has an 18 certificate.
The Committee believes that the approach adopted in the French Loi Evin merits serious examination in the English context. In particular the Committee recommends that Public Health England should commission a study of the public health effect which would be delivered in the UK by adopting the principles of Loi Evin; such a piece of work would provide a valuable reference point for the evaluation of the effectiveness of the Responsibility Deal which the Committee has recommended should also be undertaken by Public Health England.
We welcome the work which the Department is undertaking to provide an evidence base to allow commissioners to make informed decisions about which models of treatment provision are most effective in addressing the health issues caused by alcohol abuse. In particular commissioners need evidence about the most effective form of early intervention in order to reduce the number of avoidable hospital admissions which currently represent avoidable illness for patients and avoidable costs for taxpayers. The evidence we received suggested that the establishment of Alcohol Specialist Nurse services throughout the country is one of those measures. The fact that over 70% of the costs to the NHS of alcohol-related services was spent on hospital treatment demonstrates the scale of the opportunity to restructure services to achieve better outcomes.