Health Committee - The Government's Alcohol StrategyWritten evidence from Redcar and Cleveland Adult Drug and Alcohol Joint Commissioning Group (GAS 04)

The Government’s Alcohol Strategy, released 23 March 2012, had been anticipated for some considerable time in a climate of increasing concern about the harmful effects that alcohol misuse has upon individuals and wider society.

Whilst the Strategy and many of the proposals contained within it are welcomed, there is a distinct lack of ownership of the Strategy; it is a “Government Strategy” not a “National Strategy”. Additionally there are no timescales relating to the desired outcomes which are outlined in the Strategy.

The Strategy document is published by the Home Office and its contents is very much focused upon crime, disorder and licencing issues. These are clearly areas of importance. Our concern relates to the lack of a coherent contribution from the Department of Health relating to the reduction of alcohol related health harms, particularly alcohol related hospital admissions.

The Strategy appears unfinished with mention of consultation required on no less than six important issues. At best the strategy reads as a list of “to do” enforcement style actions plans. We would have welcomed (and expected) proposals/actions relating directly to prevention and treatment strategies as present in our local area Alcohol Harm Reduction Strategy.

An introduction of a minimum unit price (MUP) for alcohol is welcomed although the suggested minimum unit price of 40p is perhaps not enough, with evidential research indicating that 50p would deliver better reductions in harmful alcohol consumption amongst high risk groups. Additionally the proposed legislation to end multi-buy promotions is welcomed but not without questions as to why it is not intended to apply such a ban to the on-trade.

The increased licencing powers relating to density of licenced premises and opening hours are welcomed and fit with the move towards allowing local authorities to address local licencing issues. These measures and the proposed late night levy do suggest a commitment towards making town centres a safer place to consume alcohol.

The intention to pilot sobriety schemes is an interesting development, but once again the focus appears to be from a crime and community safety perspective. This is all well and good but these schemes cannot succeed in isolation. They need to part of a multi-agency approach incorporating a dedicated course of treatment and/or education to ensure that rehabilitation occurs alongside punishment.

The intention to introduce a wider choice of lower strength alcoholic drinks and the challenge to the drinks industry to with regards to production, sales and promotion are covered by the Government’s “Responsibility Deal” with the alcohol industry. However, we hold concerns that the self- regulation of these pledges by the alcohol industry is not sufficient and would be best served by a legislative frameworks and timescales to ensure progress is made. This view is supported by a number of prestigious bodies including Alcohol Concern, British Medical Association and the Royal College of Physicians who have withheld support for the “Responsibility Deal”.

1.1 The strategy document released 23 March 2012 is described as “The Government’s Alcohol Strategy”. The document reads very much like a political manifesto centred upon addressing the crime and disorder issues associated with alcohol misuse. Whilst accepting the earlier Government Alcohol Strategy (2004) and update (2007) were published by a previous administration; they were very much holistic documents which could be viewed as part of a “National Strategy” due to the strategic aims of:

improving information and advice about alcohol use;

increasing identification and treatment of alcohol problems;

tackling alcohol related crime and disorder and improving services to victims; and

working with the [alcohol] industry to tackle harms caused by alcohol.

1.2 Throughout the new strategy document there is a distinct lack of information in chart or graph form and there are no timescales applied to the six desired outcomes stated in paragraph 1.6 of the Strategy.

2.1 The Government’s Alcohol Strategy is published by the Home Office which perhaps explains the focus upon crime, disorder and licencing. There is a distinct lack of input from the Department of Health in the document and no health related annexes as supplementary material. With alcohol related hospital admissions in England rising unabated year on year and having broken one million admissions for the first time in 2011; it would appear at best misguided to have overlooked the need for a contribution relating to lower risk drinking and preventing alcohol related health harms.

2.2 Although published by the Home Office the strategy does not appear to fit into any of the existing Home Office structures. It appears to transcend a number of themes including licencing, anti-social behaviour and violence without a best fit. Additionally the document bears the name of the Prime Minister, yet he does not chair any of the groups to which the Alcohol Strategy relates.

3.1 Released some months later than its expected publication date, the Alcohol Strategy appears to be an “incomplete” document. The Strategy lacks action points and contains commitments to consult on important issues including:

minimum unit pricing—setting the actual price per unit or whether it actually goes ahead?

multi-buy promotions.

mandatory codes.

anti-fraud measures.

health measures.

PHSE (Personal, Health, Social and Economic) education in schools.

3.2 Until definitive indicators and timescales for implementation are in place the Strategy reads more like a “wish list” or a “to do list” and as such a refresh of the Strategy will be needed to provide responsible authorities with clear and coherent guidance.

4.1 The indication that the Government recognises the introduction of a Minimum Unit Price (MUP) for alcohol as a means of tackling alcohol related harm is well received by the Redcar and Cleveland Adult Drug and Alcohol Joint Commissioning Group which has over recent months explored the feasibility of a local MUP to address health harms in the borough. The Government’s statement of intent with regards to MUP effectively allows local authorities to press on with local MUP schemes. There is however the major issue regarding at what level MUP should be set, with the Government Alcohol Strategy indicating that 40p may well be the chosen unit price, but consultation will occur on this. The influential Independent Review of the Effects of Alcohol Pricing and Promotion (2008) conducted by the University of Sheffield suggests that a MUP of 50p would provide the greatest impact in reducing alcohol related health harms. As a result there is a slight disappointment that the Government did not made the suggestion of a 50p MUP ahead of the consultation.

4.2 The Government’s commitment to consult on legislation to prohibit multi buy promotions in the “off-trade” is welcomed, particularly in light of the evidence from Scotland which suggests that a similar prohibition is having the desired effect. There is however some disappointment that the Government has not seen fit to extend such proposed legislation to the “on-trade”; ostensibly on the grounds of the on-trade is a more regulated environment. Whilst it may be true that Mandatory Code for Alcohol has outlawed irresponsible drinks promotions such as “all you can drink” and “dentist chair” drinking games; it is still possible for the on-trade to offer heavily discounted drinks to patrons and this must surely been seen as less than responsible behaviour and potentially a contributory factor in town centre based anti-social behaviour.

5.1 The introduction of additional licencing powers for local authorities to have greater control over density of licenced premises and opening hours is welcomed and fits well within the localism agenda. Such powers will allow for identified problem premises to be dealt with in a co-ordinated and responsible manner and should promote safety and good management of licenced premises whilst reducing anti-social behaviour in the night time economy. The introduction of the night time levy will go some way towards meeting the often huge cost of policing the night time economy; but there is the potential for a perverse incentive. Licenced premises may be tempted to stay open longer or continue to serve individuals in a drunken state in a bid to increase revenue and cover the late night levy. Such permutations will require a great deal of thought on a local level.

6.1 The Government Alcohol Strategy proposes piloting sobriety schemes to deal with individuals who are engaged in alcohol related anti-social behaviour or alcohol related offending behaviour is innovative. It is does however continue to demonstrate the emphasis upon crime and disorder which is a constant throughout the Strategy. Whilst accepting that there is a need to test the feasibility of sobriety schemes and the technology that is now available to enforce them; it would be short sighted to expect these schemes to be successful in isolation. It is to be hoped an education and/or treatment option will be developed and suggested as best practice to run alongside sobriety schemes. Without treatment and education sobriety schemes may serve only to usher individuals with alcohol problems towards other substance use and/or increased involvement with the Criminal Justice System. The combination of treatment/education/sobriety scheme would appear to be more holistic approach to addressing both the alcohol misuse and offending behaviour of individuals with alcohol identified as a criminogenic need.

7.1 The “Responsibility Deal” involving the alcohol industry is intended to “foster a culture of responsible drinking which, which will help people to drink within guidelines”. According to the strategy this will be achieved through pledges from the alcohol industry which include the introduction lower strength products. The anticipated benefits of the responsibility deal include improved public health, a reduction in crime and a practical demonstration that the alcohol industry is able to police itself without Government interference. Whilst the aims of the Responsibility Deal are admirable, it amounts to nothing more than a series of promises to change the status quo and is severely hamstrung by the lack of timescales and milestones to adhere to. The concerns about the effectiveness of the Responsibility Deal are perhaps best illustrated by the endorsements it has not received from respected expert groups including Alcohol Concern, British Medical Association and the Royal College of Physicians. In summary there does not appear to be sufficient confidence that the alcohol industry will make the much needed changes quickly enough; to use the analogy “Turkey’s don’t vote for Christmas” appears very apt in this instance and stresses the need for central government to be more demanding of the alcohol industry with regards to responsible promotion, marketing and sale of alcoholic drinks.

April 2012

Prepared 21st July 2012