Health Committee - The Government's Alcohol StrategyWritten evidence from the Royal College of Physicians (GAS 17)

About the Royal College of Physicians

The Royal College of Physicians (RCP) plays a leading role in the delivery of high quality patient care by setting standards of medical practice and promoting clinical excellence. The RCP undertakes a range of public health-related activity, including on the social determinants of health, obesity, tobacco and alcohol. As an independent body representing over 27,000 fellows and members worldwide, we advise and work with government, the public, patients and other professions to improve health and healthcare.

The RCP notes that the British Society of Gastroenterology are submitting a separate response to this consultation, which will provide additional information.

1. Summary

The RCP endorses the Alcohol Health Alliance UK’s (AHA) response to this inquiry and supports the AHA’s comments and recommendations regarding the strategy. In summary:

The RCP welcomes The Government’s Alcohol Strategy and its acknowledgement of the harms associated with current levels of alcohol consumption in England.

The RCP supports the strategy’s clear commitments to address areas such as pricing and licensing and particularly welcomes the commitment to introduce a minimum unit price for alcohol.

However the RCP is concerned about the limited commitments in other areas of the strategy, particularly in relation to restricting alcohol marketing and investing in a range of patient-focused treatment services.

The RCP welcome initiatives that address specific sections of the population, however the RCP is calling for additional investment in services to address the significant proportion of the population who regularly drink at or above published guidelines over a sustained period of time, which can lead or contribute to a range of chronic diseases.

A strong national framework, underpinned by effective governance, quality research and evaluation, will be essential in supporting local authorities and clinical commissioning groups to deliver effective services for their communities in the new public health system.

2. Relationship Between Price and Consumption

2.1 The RCP strongly supports the government’s commitment to introduce a minimum price on alcohol in England and Wales. This step acknowledges the clear relationship between price and the consumption of alcohol and associated harms, which is supported by substantial and robust evidence and modelling.1,2,3,4,5

2.2 Modelling conducted by the University of Sheffield found that increasing levels of minimum pricing show substantial increases in effectiveness. The RCP supports the introduction of a minimum unit price of at least 50p per unit, which the modelling suggests would reduce total alcohol consumption by 6.7%, saving around 20,000 hospital admissions in the first year and 97,000 a year once the policy has been in place for ten years. This would result in direct costs saved in relation to health, crime and workplace impacts in England of £7.6 billion over ten years.5

2.3 The RCP also strongly supports the proposed ban on multi-buy promotions in the off-trade, in addition to the introduction of a minimum unit price. The University of Sheffield modelling shows that increasing restrictions in off-trade discounting (ie through multibuys) will result in a reduction on overall consumption equivalent to that of a 40p minimum unit price.5

3. Addressing Marketing and Advertising

3.1 Evidence shows that exposure to alcohol marketing encourages children to drink at an earlier age and in greater quantities than they otherwise would. The Science Committee of the European Alcohol and Health Forum concluded in 2009 that “alcohol marketing increases the likelihood that adolescents will start to use alcohol, and to drink more if they are already using alcohol”.6

3.2 While the government’s strategy recognises the link between marketing and consumption, the actions outlined focus on working within the current structures and do not go far enough to curb children’s exposure to alcohol advertising.

3.3 The RCP supports a UK adapted version of the French framework, the Loi Evin. The Loi Evin model provides a simple framework that can offer clarity on what marketing practices can and cannot be implemented whilst ensuring that children and young people are protected from an exposure that poses a risk to their health and wellbeing.

4. The Role of the Alcohol Industry

4.1 The RCP welcomes the acknowledgement in the strategy that “industry needs and commercial advantages have too frequently been prioritised over community concerns”.7 However the RCP remains concerned that the strategy reinforces existing roles and structures for industry involvement.

4.2 In line with the World Health Organisation recommendations, while we believe business must play a part and have the opportunity to engage with health issues, health experts must lead on setting policy priorities.8 Although businesses have a role to play in implementing and supporting public health initiatives it is not the place or responsibility of business to define public health policy or to be responsible for public health information, as in many cases this is in direct conflict with their interests and responsibilities to their shareholders and employees.

4.3 The RCP did not sign up to the Responsibility Deal due to a range of concerns, particularly around the alcohol pledges. The RCP continues to engage critically with the Responsibility Deal, and in particular is calling for independent monitoring and evaluation of the pledges and wants to ensure there is a clear timetable for reviewing progress and detail of the action that will be taken if outcomes are not achieved.

5. Greater Investment in Effective Services

5.1 There is a clear need to provide care for a large and growing group of patients with alcohol-related health problems. Presently a lack of coordinated action means that care is imperfect and spending is poorly targeted and ineffective, very few hospitals have dedicated alcohol services and only 5.7% of dependent or harmful drinkers access treatment, compared to 67% of dependent or harmful drug users.9

5.2 The RCP welcomes the strategy’s actions relating to specific concerns such as those related to under 18 Accident and Emergency admissions and the rehabilitation of offenders. The strategy also acknowledges the benefits of early intervention and treatment services, but offers few commitments in this area.

5.3 The RCP is calling for additional investment in strategies and services to address the significant proportion of the population who regularly drink at or above published guidelines over a sustained period of time, which can lead or contribute to a range of chronic conditions such as liver disease, heart disease and cancer.

5.4 The RCP is calling for the full implementation of the NICE guidelines relating to alcohol dependence, which provide an excellent, evidenced-based guide to effective intervention, treatment and referral systems that involve a wide range of health professionals.1,2

5.5 The RCP recommends that there should be a multidisciplinary “alcohol care team”, a seven day alcohol specialist nurse service and an “assertive outreach alcohol service” in every district hospital. Transitions between teams and services should be quick and seamless in order to increase the efficiency and cost effectiveness of the service.10

6. A National Framework to Support Locally-Driven Public Health

6.1 The RCP believes there is potential to work more closely with local authorities to drive change and innovation, and deliver services targeted to the needs of local communities. However, with the changes to the public health system come risks that must be mitigated. These include: unjustifiable variation, piecemeal and fragmented service provision, an absence of quality evaluation metrics, and a lack of information sharing and best practice.

6.2 A national service framework on alcohol, which could be adapted to local needs, would be an effective way of keeping costs down, sharing best practice and getting the best value for money. A framework could be led by a dedicated alcohol team within Public Health England, with established experts leading the research work at the highest level, setting out principles for action, rather than prescriptive plans. The RCP recommends that an expert, influential and independent director of public health—supported by robust data analysis and outcome monitoring systems—will be essential.

7. Coordination of Alcohol Policy

7.1 Policies relating to alcohol fall under a broad range of governmental departments. There is therefore a particularly strong case for a cross-departmental unit on alcohol, and the RCP suggests that such a unit could be led by the Chief Medical Officer—reporting to the Home Affairs (Public Health) Cabinet Sub-committee.

7.2 A cross-governmental alcohol unit could maximise the impact of the different strands of the government’s strategy and ensure there is rigorous evaluation applied to all aspects of the strategy. The unit would also be well placed to coordinate policy with the devolved administrations. Greater consistency around policies relating to the price, availability and promotion of alcohol will be important in ensuring success across the UK.


1 National Institute for Health and Clinical Excellence. Alcohol-use disorders: preventing the development of hazardous and harmful drinking: PH24. London: NICE, 2010.

2 National Institute for Health and Clinical Excellence. Alcohol-use disorders: diagnosis, assessment and management of harmful drinking and alcohol dependence. clinical guideline 115. London: NICE, 2011.

3 WHO Expert Committee on Problems Related to Alcohol Consumption. Second report/WHO expert committee on problems related to alcohol consumption. WHO technical report series; no. 944. Geneva: World Health Organization, 2007.

4 Wagenaar A. C., Salois M. J., Komro K. A. Effects of beverage alcohol price and tax levels on drinking: a meta-analysis of 1003 estimates from 112 studies. Addiction 2009; 104: 179–90.

5 Purhouse, R et al, 2009. Modelling to assess the effectiveness and cost-effectiveness of public health related strategies and interventions to reduce alcohol attributable harm in England using the Sheffield Alcohol Policy Model version 2.0. Report to the NICE Public Health Programme Development Group.

6 Anderson P, C. D. Effectiveness and cost-effectiveness of policies and programmes to reduce the harm caused by alcohol. Lancet , 2009: 373:2234–46.

7 Home Office, The government’s alcohol strategy. 2012:3.

8 World Health Organization. The World health report 2002: reducing risks, promoting healthy life. Geneva: WHO, 2002.

9 Department of Health. Alcohol needs assessment research project (ANARP). London:Department of Health, 2004.

10 The British Society of Gastroenterology and the Royal Bolton Hospital NHS Foundation Trust . Alcohol care teams: to reduce acute hospital admissions and improve quality of care. London:NHS Evidence, 2011.

May 2012

Prepared 21st July 2012