Health Committee - The Government's Alcohol StrategyWritten evidence from the Baptist Union of Great Britain, the Methodist Church and the United Reformed Church (GAS 24)

1. The Baptist Union of Great Britain, the Methodist Church and the United Reformed Church are three of the largest Free Church denominations in Britain, representing around half a million Christians.

2. Our churches have extensive experience of working with those who suffer harm as a result of alcohol abuse and of contributing to the policy debate around alcohol. As a result, we wrote to the Prime Minister in January, together with the Church of England, Christian Nightlife Initiative, Street Angels and others, to express our view of the urgency of implementing a robust minimum unit price for alcohol.

3. This policy engagement is rooted our local involvement: faith groups have a strong local knowledge of the effects of alcohol misuse, and many of our churches provide counselling and other forms of support for problem drinkers.

Summary

4. The main points we wish to emphasise are:

It is welcome that, after some years of supporting research, the Government has acknowledged the need for a minimum unit price. But it is important that the right price is chosen. Studies have suggested that 40p is about the lowest value to make minimum unit pricing worth implementing.

If the drinks industry’s desire to have a sunset clause inserted in the legislation is granted, it is important that the trial period is sufficiently long, and that the price adopted is high enough to show the effect of minimum unit pricing clearly. This would suggest a price nearer to 50p than 40p.

In addition, if a minimum unit price of 45p is established for Scotland at the same time as Northern Ireland and the Republic of Ireland are agreeing a cross-border alcohol strategy, it would be logical for the price for England and Wales to be 45p or more.

Alcohol misuse is primarily a health issue. The Department of Health should have the central role in alcohol policy, coordinating work of other involved bodies in Whitehall including the Home Office and the Department of Communities and Local Government. However, our denominations are clear that, whichever Government departments are responsible, policy should be informed by evidence-based research and guided by medical experts, as well as communities’ understanding of alcohol-related harm.

Responsibility for Alcohol Policy

5. The Department of Health should have the prime responsibility for alcohol policy making in England and Wales (alcohol policy being devolved in Northern Ireland and Scotland). This is because the harm, particularly the physical harm caused experienced by problem drinkers, relates directly to consumption patterns. The health harms of alcohol misuse are its most serious effects; in addition, medical research is best means of gathering and analysing the data which can reveal what incentives will dissuade people from drinking too much of alcohol that is too strong.

6. To achieve this goal, it is important that the Department of Health maintains close relationships with medical experts, so that important research like that of the University of Sheffield’s School of Health and Related Research (scHARR) is understood and incorporated in a timely manner.

7. However, it is clear that the Department of Health will need to work closely with the Home Office in partnership with police forces across the UK. Alcohol-related violence and disorder cost England and Wales £13 billion and the cost to society as a whole has been estimated at £17-£22 billion.1

8. Certain regions, and certain areas within regions, suffer disproportionately from problem drinking. It is important that communities are empowered to adapt price, licensing or advertising to their local context. For this reason, measures in the Alcohol Strategy including the Late-Night Levy and early-morning Restriction Orders are encouraging: we wish to see the Government continue its work to embody its localism agenda in alcohol policy. But it is also vital that local medical statistics are available and our so that communities to understand the nature and scale of problem drinking in their areas.

Devolved Administrations

9. Setting the correct minimum unit price is crucial to the success of the Alcohol Strategy. This likewise relies on coordination between the prices of alcohol in the UK’s nations. This may not necessarily lead to the same unit price throughout the four nations, but the prices chosen should not lead to distortions based on local economic conditions, problem drinking or factors that might lead to cross-border trade.

The Role of the Alcohol Industry

10. We recognise that the drinks industry has a key role. While many churches historically promoted temperance, that stance was associated with the excessive social harm caused by alcohol misuse at that time, and our three denominations are not “anti-drink”.

11. However it is regrettable that some parts of the alcohol industry seem to have chosen to dismiss the extremely solid, measured and even-handed research conducted by scHARR as well as various studies showing the links between alcohol price, consumption and harm. Our denominations would hope to see the drinks industry fulfil its potential in understanding, then supporting, recommendations based on medical research supporting the development of a culture of social responsibility associated with alcohol. This should build on the Responsibility Deal but go much further.

12. Observation of the way that medical advice has been undervalued during the health debate in recent years has led to perceptions that the interests of the alcohol industry have had a disproportionate effect on alcohol policy making. The industry has the potential to contribute to socially responsible alcohol consumption, but it should not be able to influence or determine alcohol policy as such, which is fundamentally a medical and social issue.

A Minimum Price Per Unit of Alcohol

13. The most comprehensive UK-wide research of the likely results of introducing minimum unit pricing at different prices remains scHARR’s research of 2008. No comparable national study has been released subsequently, though the 2009 Scotland-specific survey contains data relevant for the debate around a 45p minimum price.

14. The misleading and inaccurate suggestion that such studies are “just modelling” and do not count as evidence for minimum pricing has rightly been rejected by health and research experts. The in principle case for minimum price has been made successfully and accepted by those competent to judge the research. However it is likely that the scHARR figures need to be updated.

15. The figures used by Government as initial context for the Strategy differ from some previously suggested. Recent research argues that a unit price of 40p would save 170 lives in the first year, rising to 900 a year over a 10 year period.2 While these health gains would be enough to justify a 40p unit price, other studies have suggested different outcomes, but it is clear from the scHARR study that the health benefits of a 50p unit price were substantially higher. 40p is around the lowest minimum unit price that should be considered and 50p should be given lengthy consideration.

16. To avoid unhelpful controversy around figures, it would be useful to have upper and lower limits for the expected results on health, accidents, crime and all other relevant variables, for different categories of drinker.

17. Nonetheless, previous research strongly suggested that 40p is approximately the lowest figure that would justify minimum unit pricing as opposed to other possible policies. While basing policy proposals on the absolute lower limit is useful, there are reasons for suggesting that nearer 50p would be better.

Scotland is discussing 45p and it would seem sensible that England and Wales should price alcohol equally or higher, rather than lower

The danger of a 40p price is that it will not make a sufficient difference to current pricing to make the case for minimum unit pricing one way or the other. This would be disastrous as all agree that it will be important to review the results of this policy

An article recently published in the British Medical Journal suggested that while a 40p minimum unit price would lead to 1,149 fewer alcohol-related deaths and 38,900 fewer hospital admissions, a 50p minimum price would double these beneficial results with around 2000 fewer deaths and 80,000 fewer hospital admissions.3

18. It has often been alleged that minimum unit pricing would be illegal under European competition law. The case has yet to be tried in a court of law, and there is little evidence for the claim. In any case, the nation’s health needs must take precedence of concerns around unresolved points of law. The legal challenge must be faced once it is understood that minimum unit pricing is a vital element in the Alcohol Strategy

The Effects of Marketing Upon Alcohol Consumption

19. The Alcohol Strategy contains a commitment to work with the Portman Group to ensure that brands which contravene advertising protocols are taken off the market. This is encouraging, especially as marketing targeted at young people has been implicated as a significant cause of problem drinking. But there are wider concerns:

problem drinking is a cause of parental neglect of children, as mentioned in the letter written by a coalition of churches and charities to the Prime Minister in January 2012;4 and

in some respects, alcohol advertising may not only influence but also reflect elements of the UK’s drink culture which need to be addressed—to focus on solely on advertising rather than the deeper question of the role alcohol plays in our society would risk treating symptoms rather than root causes.

Longer Term Impacts

20. In February 2012, leading medical experts predicted over 200,000 preventable deaths over the next 20 years as a result of alcohol misuse. Binge drinking and the role of alcohol in obesity are also significant public health issues.

21. To meet this challenge and build on the joined-up approach that the Alcohol Strategy implies, it is important that the concept of the public’s health is expanded to include a stronger emphasis on harder to quantify harm including mental health, career and wellbeing.

Impact on NHS Care

22. Historically, some professionals in the substance abuse field have felt that drug treatment was significantly better resourced than alcohol treatment—perhaps because of law enforcement priorities. Yet current levels of drinking and problem drinking suggest the need to recognise that, from a rational and medical perspective, alcohol is itself a drug, but one that happens to be legal and traditional. Thus, as the Alcohol Strategy is implemented it will be important to ensure that alcohol treatment is adequately funded and that the social stigma or sense that problem drinking is primarily an individual moral failing is combated.

23. We hope that these brief comments will assist you in your inquiry.

May 2012