Health Committee - The Government's Alcohol StrategyWritten evidence from Alcohol Focus Scotland (GAS 10)

About Alcohol Focus Scotland

Alcohol Focus Scotland (AFS) is Scotland’s national alcohol charity. We advocate for evidence-based policy interventions to reduce the burden of alcohol-related harm and we work to provide accurate and accessible information about alcohol to policy-makers, practitioners, the media, and the general public.

Summary of Response

Alcohol Focus Scotland welcomes the Westminster Government’s Alcohol Strategy and the acknowledgement of the historically high levels of consumption and harm being experienced in the UK.

Action is required at a number of different levels, but controls on affordability, availability and marketing are critical to reducing consumption and harm.

Plans to introduce minimum unit pricing are particularly welcome as evidence shows a clear link between alcohol price, consumption and harm.

Increasing the price of alcohol is one of the most effective and cost effective ways to reduce consumption and harm at a population level.

Alcohol Focus Scotland calls on the government to significantly strengthen the strategy in relation to marketing.

To protect children and young people from exposure to alcohol marketing, Alcohol Focus Scotland calls for greater regulation of social media.

Alcohol Focus Scotland believes that the alcohol industry can be involved in the implementation of alcohol policy but should not be involved in the identification of public health goals given the obvious conflict of interest and the fact that their expertise is in producing and selling alcohol and not in protecting and improving public health.

1. Introduction

1.1 Over the last thirty years, a combination of deregulation, liberalisation of licensing laws and aggressive marketing has led to alcohol becoming more affordable and more available than at any time in recent history. This in turn has fuelled our consumption and as our consumption has increased, so too has the health and social harm caused by alcohol. One hundred people die every week from alcohol-related liver disease in England and Wales. Every year alcohol causes the admission of over a million people to hospital; is linked to 13,000 new cases of cancer and is associated with 1 in 4 deaths among young people aged 15 to 24.1

1.2 Alcohol Focus Scotland welcomes the analysis in the Strategy linking consumption levels with the ready availability of cheap alcohol and the fact that to date, industry needs and commercial advantages have been too frequently prioritised over community concerns.

1.3 Alcohol Focus Scotland further welcomes the recognition that “universal action” is required to address the underlying issues driving the increases in consumption and harm, as the international evidence shows that measures to control affordability, availability and marketing are amongst the most effective levers to reduce consumption.

1.4 Plans within the strategy to consult on the introduction of a health-related objective within alcohol licensing in England and Wales are welcome. Experience in Scotland shows that having a public health objective enshrined in licensing legislation enhances local licensing bodies’ powers to restrict availability on the grounds of protecting health.

1.5 However, Alcohol Focus Scotland has concerns that, by focusing heavily on binge drinking and crime and disorder, the strategy misses a critical opportunity to consider alcohol harm as primarily a public health issue affecting the whole population. With over a million alcohol-related hospital admissions in 2010112 and a 450%3 increase in liver cirrhosis rates in the last 30 years, the health harms caused by alcohol are being experienced by increasing numbers of people who would class themselves neither as “binge” nor “irresponsible” drinkers.

2. Minimum Unit Pricing

2.1 The inclusion of minimum unit pricing in the Strategy provides an historic opportunity to put in place a policy measure that many leading health organisations including the World Health Organisation, the National Institute for Clinical Guidance and the Medical Royal Colleges believe will be effective in saving lives and reducing harm.

2.2 In addition to the health gains, effective alcohol policy can significantly reduce the costs to the public purse of alcohol-related harm. In 2003, alcohol harm was estimated to cost around £20bn each year and there is evidence to suggest that this cost has continued to rise.4 Much of this burden could be avoided if people drank less. There is extensive and robust evidence confirming that there is a consistent relationship between price and consumption (when the cost of alcohol goes down, people drink more and when the cost goes up, people drink less) and that the most effective and cost-effective way to reduce alcohol consumption in the population is controls on price and availability.5 Consequently, controls on price and availability have been identified by the World Health Organisation as one of the most effective measures that governments can implement to reduce the harm caused by alcohol: “Of all alcohol policy measures, the evidence is strongest for the impact of alcohol prices as an incentive to reduce heavy drinking occasions and regular harmful drinking. The gains are greatest for younger and heavier drinkers and for the well-being of people exposed to the heavy drinking of others”.6

2.3 To date, the policy mechanism that has been used to increase the price of alcohol is taxation. More recently, minimum unit pricing (MUP) has emerged as a measure that would be complementary to duty increases and also more effective in targeting the cheapest alcohol products, which are often drunk by the most vulnerable groups in society. MUP has also come to the fore because in recent years, duty increases have not always been passed on to consumers. Some supermarkets have even advertised “tax busting prices” following duty increases with the ten big supermarkets admitting to the Competition Commission that they use alcohol as a “loss leader” to drive footfall.7

2.4 As MUP is a relatively new policy measure, the estimates of the potential health gains come primarily from econometric modeling studies. Modeling is a recognised tool that is used regularly by governments to estimate the effects of new policies. For example, modeling was undertaken to estimate the effects of a minimum wage prior to adoption of the policy.

2.5 However, further evidence of the effect of minimum pricing is now available with the publication of an evaluation of minimum pricing schemes in two Canadian provinces in early 2012. The overall conclusion from the study was that “increases in minimum prices of alcoholic beverages can substantially reduce alcohol consumption” with minimum pricing reducing alcohol consumption by between 3% and 5% in the two provinces in which it was implemented.8

2.6 A combination of the significant evidence base linking alcohol price, consumption and harm, the growing interest in implementing a pricing measure that specifically targets the cheapest products, and concerns that retailers don’t always pass on duty increases, has resulted in governments in a number of jurisdictions actively exploring MUP. In the Scotland, the Alcohol (Minimum Pricing) Bill (Scotland) is expected to be agreed by the Scottish Government by June 2012. Northern Ireland has recently consulted on the issue, Ministers in Wales have indicated their interest in implementing MUP and a number of local authorities in the North of England have sought to introduce MUP through local bye-laws. Internationally, governments actively considering MUP include the Republic of Ireland, Australia and New Zealand.

2.6 The price of alcohol provides a clear message about where alcohol is positioned in the “culture” of a society. The “culture” that we have created today is one of low cost and easy availability of alcohol. History teaches us that this culture of access and excess is one that has developed over a relatively recent period of time. During the first half of the 20^th century, drinking to excess was almost entirely unknown as the conclusion from the Royal Commission on Licensing in 1931 demonstrates. At that time there were significant controls on the price and availability of alcohol. These have been steadily eroded over the last forty years as successive governments have embarked on a process of deregulation and liberalisation. Successful changes in culture in areas such as smoking, seat belt use and drink driving have come about through a combination of regulation, enforcement and public information. Without action on price, any other measures to reduce consumption and harm will be swimming against a very powerful tide. If we want to change “culture” then price is a very good place to start.

Ban on multi-buy discounts

2.7 Experience in Scotland shows that to ensure maximum effectiveness, the ban on multi-buy discounts should be implemented alongside minimum pricing and across the UK. A ban on multi-buy discounts came into force in Scotland on 1^st October 2011 with the implementation of the Alcohol etc. (Scotland) Act 2010. During the first weekend of the new legislation being implemented, a number of the major supermarkets sought to undermine the spirit of the Act by encouraging online purchasing of alcohol from distribution centres in England.9

2.8 Moreover, many of the major supermarkets slashed their prices when the ban came into effect in Scotland. The Grocer magazine published figures which showed that whilst supermarket multi-buys had disappeared, the number of products on price reduction promotions in the first four weeks following the ban period rocketed from 753 to 1,178.10 Whilst legal, these practices call into question the large supermarkets’ claims to be responsible retailers and reinforce the case for a ban on multi-buy discounts to be introduced in conjunction with minimum unit pricing.

3. Marketing

3.1 The alcohol industry spends £800million each year in the UK marketing their products.11 Young people are particularly vulnerable to alcohol harm with evidence linking regular heavy drinking in adolescence with impaired brain development.12 Evidence also confirms that alcohol marketing increases the likelihood that young people will start to use alcohol, and to drink more if they are already drinking.13 There is a particular concern about social media which is heavily used by children and young people and is largely unregulated.

3.2 The Health Select Committee reported in 2010 that the current regulatory framework for alcohol marketing was inadequate.14 The current controls which are in place to limit children’s exposure to alcohol marketing are clearly failing with a study funded by the Medical Research Council showing that 96% of 13 year olds in the UK were aware of alcohol advertising and on average had come across it in more than five different media.15

3.3 Of the £800million spend on alcohol marketing, it is critical to note that around £550million of this is spent on football sponsorship, promotions, music festivals and online marketing and promotions16 where the potential exposure of children is even more problematic.

3.4 Indeed in 2007, the alcohol industry increased its marketing spend on social media by 70%.17 This has worrying implications with regards to the exposure of children and young people to alcohol marketing when you consider the growing presence of alcohol companies on social networking sites such as Facebook and Twitter. Research from Ofcom has shown that almost half (49%) of children aged between 8 and 17 years old who use the internet have set up their own profile on a social networking site.18

3.5 In September 2011, Diageo struck a multi-billion dollar deal with Facebook, which makes Smirnoff, according to its producer Diageo, “the number one beverage alcohol brand on Facebook worldwide”. Diageo report that Facebook activity in the US has increased sales by 20%. This online activity is only set to increase, as the company boasts of training 950 marketers to build social media capabilities to generate “significant returns on investment”.

3.6 Although Facebook argues that pages set up by alcohol advertisers are “age-gated” and only accessible to those over 18, these “age-gates” are far from infallible and can be bypassed simply by inputting a fake birth-date. Perhaps most worrying is that Facebook accounts are hidden from parents, providing companies with a direct and uncensored communications channel to children and young people.

3.7 Importantly, children and young people are not just at the mercy of “official” marketing. Fans of alcohol products are increasingly becoming brand advocates by setting up fan pages and passing alcohol adverts between themselves, further normalising consumption and increasing pressure on young people to drink and drink more.

3.8 Alcohol Focus Scotland believes that the implementation of a UK adapted Loi Evin would provide a good starting point to begin to protect children and young people from alcohol marketing. This framework provides guidance on marketing practices and how best to ensure children and young people are protected from an exposure that poses a risk to their health and wellbeing. The Loi Evin has been upheld by the European Court of Justice which found the measure to be proportionate, effective and consistent with the Treaty of Rome.19

3.9 However the area which requires most urgent and robust action is online marketing. It is of grave concern therefore that the strategy proposes the extension of the ASA’s powers and work with the alcohol industry in relation to age verification as the key actions required to address this area of concern.

3.10 Alcohol Focus Scotland do not believe that the ASA have the specialist expertise required to tackle this new and expanding area of marketing and instead calls for a ban on advertising on social media sites, where the alcohol industry has guaranteed exposure to children and young people.

3.11 Further Alcohol Focus Scotland calls for an independent body, with no representation from the alcohol industry, to monitor children and young people exposure to alcohol marketing. This independent body should give particular and urgent attention to ensuring online, digital and social media is adequately regulated and monitored.

4. The Role of the Alcohol Industry

4.1 When considering the role of the alcohol industry in the development of alcohol policy, the following statement from the 2010 report by the House of Commons Health Committee on alcohol should be considered: “It is time the Government listened more to the [Chief Medical Officer] and the President of the [Royal College of Physicians] and less to the drinks and retail industry. If everyone drank responsibly the alcohol industry might lose about 40% of its sales and some estimates are higher. In formulating its alcohol strategy, the Government must be more sceptical about the industry’s claims that it is in favour of responsible drinking”.20

4.2 Whilst the strategy acknowledges that “industry needs and commercial advantages have too frequently been prioritised over community concerns”, Alcohol Focus Scotland has concerns about the emphasis that the strategy gives to the involvement of the alcohol industry in relation to the development of alcohol policy and self regulation.

4.2 The World Health Organisation has considered the extent to which governments must be mindful of the issue of conflict of interest between public health and commercial vested interests. The fifty-three Member States of the World Health Organisation’s European Region endorsed the European Alcohol Action Plan in September 2011 which included a clear statement on conflicts of interest:

The Regional Office will strengthen its processes of consultation and collaboration with NGOs and relevant professional bodies that are free of conflict of interest with the public health interest….guided by the principles that public policies and interventions to prevent and reduce alcohol-related harm should be guided and formulated by public health interests and based on clear public health goals and the best available evidence.21

4.3 Alcohol Focus Scotland further notes the view that it is an “ethical responsibility of the entire industry—alcohol retailers, alcohol producers and both the on-trade and off-trade—to promote, market, advertise and sell their products in a responsible way”. It is of significant concern however, that the strategy has reinforced the role of self-regulation given that the evidence indicates that this is ineffective.22 In keeping with the guidance summarised above, Alcohol Focus Scotland is of the view that whilst commercial vested interests can be involved in the implementation of alcohol policy, their involvement should be confined to areas which pertain specifically to their role as producers and retailers of alcoholic beverages. For example—labeling and server training. They should not be involved in the identification of public health goals to inform alcohol policy given the obvious conflict of interest and the fact that their expertise is in producing and selling alcohol and not in protecting and improving public health.

May 2012