Health Committee - The Government's Alcohol StrategyWritten evidence from Institute for Social Marketing, University of Stirling (GAS 05)
THE GOVERNMENT’S ALCOHOL STRATEGY:
GAPS AND OPPORTUNITIES
In March 2012 the UK government published an alcohol strategy that set out proposals to reduce excessive alcohol consumption and to deal with the consequences of this consumption.
The strategy is ambitious in a number of respects but also contains a number of gaps. This short note identifies some of those gaps as well as areas where action set out in the strategy could be enhanced or expanded.
Our comments are grouped around the 4 “ps” of marketing—price, product, place and promotion. The government’s strategy contains proposals in all four of these areas.
1. Price
The strategy contains two main proposals on price. The first is to consult on a minimum unit price for alcohol. This proposal follows Scotland and is to be welcomed. Key considerations are what level MUP will be set at—there is good evidence to suggest that 45 or 50p would be more effective than 40p, for example. How long the consultation will take and when possible changes will be introduced is also key. Secondly, the strategy commits to a consultation on a ban on multi-buy promotions in the off-trade. This is already in place in Scotland and should be adopted more widely—it is not clear why this requires a consultation.
2. Product
The strategy is weak on changes to the product. It commits to working with the Advertising Standards Authority and other bodies to “look at the rules and incentives that might inhibit the promotion of lower strength alcohol products”. The strategy is silent on labelling and health warnings, for example. Larger and clearer warning labels on bottles could provide drinkers with better information and contribute to changing drinking behaviour as is the case with warning labels on cigarette packaging, for example.
More fundamentally it says nothing about the relative appeal of products and the need control those that have a particular appeal for the young. In our view there is no justification for a product that is more popular with children than adults. All new products should be subject to independent scrutiny to assess their appeal to young people and impact on public health before they are permitted onto the market.
3. Place
The strategy contains a number of proposals to promote better local action on alcohol, address issues around late night sales, outlet density, licensing and crime and justice measures, all of which are welcome. The strategy could have gone further in terms of proposals to ensure that sales in shops and supermarkets are limited to specific areas and specific times of the day, distinct from the sale of other products. For example, alcohol in supermarkets should be limited to particular areas where children are not permitted and that have separate entry points (ie turnstiles) and separate tills for purchases.
4. Promotion
The promotion of alcohol is extremely widespread and young people in particular are inundated by pro-drinking messages. This advertising has been shown to have a direct effect on both the age at which drinking starts and the amount consumed—reducing the former and increasing the latter. Despite this evidence, there are no proposals in the strategy to reduce the amount of alcohol advertising, or even to introduce a degree on independence into the regulatory process. Instead it is business as usual, with an industry driven focus on content regulation—and approach which lacks any evidence base and has been shown to fail. Nowhere is this complacency more apparent than with online advertising, which the strategy treats as a mere extension of current promotion. In reality it completely changes the landscape, with young people not just being marketed to, but being recruited as a peer to peer brand advocates, unwittingly feeding marketing campaigns with their personal details and generating their own promotional content. How, for example, can the current regime of content controls deal with this last phenomenon? And the talk in the strategy of better age restrictions on digital marketing is simply fanciful. Digital marketing has to be treated much more seriously.
The strategy also misrepresents the Loi Evin as a ban on advertising. It is nothing of the kind. Rather it is exactly the type of imaginative response to a major public health problem that the UK lacks, and it simply ensures that alcohol advertisers behave responsibly by a) restricting their messages to verifiable statements of fact b) making sure these messages only reach adults. If the Government could not bring themselves to learn from this excellent cross-channel experience, there were a number of intermediate steps they could and should have taken, including: prohibiting alcohol advertising on television before the watershed; limiting or prohibiting sponsorship of sport; and requiring health promotion messages to be screened before programmes or films promoting drinking.
5. Social Marketing/Health Promotion
The strategy also contains measures on information and education and on treatment but in both these areas the strategy is weak. On information and education, for example, there is a renewed commitment in the strategy to continue to work with the alcohol industry and its partners (ie Drinkaware) to provide the public with information on “safe” drinking whereas evidence from other related areas (such as tobacco) suggests that the producers of a harmful product should not be involved in designing or delivering public health messages. On treatment, there is an urgent need to ensure adequate implementation of existing NICE guidance on both brief interventions and treatment services and to make treatment more available and accessible. The Alcohol Health Alliance will be providing the Health Select Committee with a comprehensive critique of the strategy that will provide more detail on gaps in these areas.
6. Independence
We have used the word “independent” several times in our response. By this we mean independence from vested interest in the alcohol and advertising industries. None of the three bodies mentioned on numerous occasions in the strategy—Drinkaware Trust, the Portman Group and the ASA—pass this test of independence and this is much to be regretted.
May 2012