Health Committee - The Government's Alcohol StrategyWritten evidence from the National Heart Forum (GAS 26)

About the National Heart Forum

The National Heart Forum (NHF) is a leading charitable alliance of 70 national organisations working to reduce the risk of coronary heart disease and related conditions such as stroke, diabetes and cancer. NHF is both a UK forum and an international centre for chronic disease prevention. Our purpose is to co-ordinate public health policy development and advocacy among members drawn from professional representative bodies, consumer groups, voluntary and public sector organisations. Government departments have observer status. The views expressed here do not necessarily reflect the opinions of individual members of the forum. The National Heart Forum is a member of the Alcohol Health Alliance.

1. Summary Points

The NHF welcomes The Government’s Alcohol Strategy (the “Strategy”) and its acknowledgement of the harms associated with current levels of alcohol consumption in England.

NHF is concerned that relatively too little emphasis is given to the health hazards of long term excessive drinking, including chronic disease and alcohol dependence, compared to the social problems of binge drinking.

NHF welcomes the commitment to request the CMO review alcohol guidelines, but we would urge the Government to ensure complete independence from the alcohol industry in determining those guidelines.

NHF supports the introduction of minimum unit pricing (MUP) and would like to see a Government levy on any surplus company profits from MUP used to support alcohol harm reduction programmes.

Measures to reduce the impact of alcohol marketing are disappointingly weak or absent from the Strategy. NHF would like to see Government action to introduce a version of the French Loi Evin which strictly limits the nature and volume of alcohol marketing.

We are not satisfied that voluntary actions by the industry will deliver adequate and consistent information on alcohol product labels and would recommend mandatory standardised labelling for all alcohol products.

2. Understanding the Risks of Harmful Alcohol Consumption

2.1 Excess alcohol consumption is an established risk factor for chronic diseases including cardiovascular disease, many cancers (including cancer of the breast, bowel and liver) and liver disease. Smoking and alcohol consumption combined account for three quarters of cancers of the mouth, pharynx and oesophagus. The Strategy is an important step forward in addressing these negative impacts of alcohol consumption in England.

2.2 The Strategy focuses on the effects of young people binge drinking, and the social disorder caused by excessive alcohol consumption. The NHF would like to see this focus to be equitably balanced to better acknowledge the long term health harms of excessive alcohol consumption, including chronic disease and alcohol dependence.1

2.3 There is a large section of the population that is consuming well over the recommended limits, often in their own homes, and storing up problems (and demand for services) for the future.2 NHF is concerned by the low public awareness of the harmful impact of alcohol and the lack of actions and investment 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 illnesses.

2.4 The Government must ensure that the alcohol industry is not involved in the review of alcohol health guidelines by the Chief Medical Officer.

3. Availability of Cheap Alcohol

3.1 Deep discounting and heavy promotion of alcohol in the on- and the off-trade has made drinking more affordable. NHF is encouraged by the recognition in the Strategy that affordability is a major factor in driving levels of excessive consumption and associated health harms.

3.2 The NHF supports the proposal for a minimum unit price (MUP) for alcohol. MUP is particularly important in helping to address alcohol consumption’s contribution to avoidable chronic diseases and will primarily target harmful and hazardous drinkers, with comparatively little impact on the spending of moderate drinkers.3 Once implemented, it will be essential to establish an effective mechanism for reviewing and adjusting the MUP over time to account for inflation and rising disposable incomes. [2.8]4

3.3 The level at which MUP is set must take into account the evidence of effectiveness, specifically, modelling research which shows that an MUP of 45p or 50p/unit will have a significantly greater impact than 40p/unit.5 The decision should also take account of policy in Scotland and certainly be set no lower than the Scottish MUP when this is determined.

3.4 The NHF strongly supports the call for a consultation on multi-buy promotions in the off-trade and suggests that any ban should include multi-buy discounts in the on-trade as well as the off-trade. [2.9]

3.5 We disagree with the Strategy and contend that the Government should introduce a levy on any surplus profits from MUP and use this money to support alcohol harm reduction programmes, barring any industry involvement in its management. We note that when asked about tobacco, there is majority public support for hypothecated price increases (Beyond Smoking Kills 2008). One possible use for funds for such a levy would be to reinvest in specialist alcohol treatment services, an area of need previously identified by the Health Select Committee.6 [2.11]

4. Alcohol Marketing and Advertising

4.1 The Strategy lacks strong Government action to address the gaps and weaknesses in the current controls of the marketing and advertising of alcohol products. A key weakness of current codes is that they fail to protect children and young people from alcohol marketing because they are narrowly framed around “targeting” of marketing messages, not “exposure” to those messages. Marketing channels which are very popular with children and young people are either exempted or fall outside the existing codes and include social networking sites, sports sponsorship and point of sale marketing.

4.2 Self-regulatory organisations like the Portman Group acknowledge the limits inherent in self-regulation, saying that if the rules are too stringent, then signatories may fail to comply with them. The explicit trade off between profitability and public protections severely limits the capacity of voluntary codes to function as proportionate response to the current crisis of alcohol health harm in the UK when more rigorous measures are evidently needed.7

4.3 It is our view that the strongest model of regulating alcohol marketing is one in which government establishes a regulatory framework and robust standards independent of industry, which focus on reducing exposure to all forms of marketing activity.

4.4 The NHF recommend a UK adapted version of Loi Evin—a French regulatory framework that allows alcohol marketing and promotion only in media where adults are at least 90% of the audience. The Loi Evin model—which is the basis for the Private Members’ Alcohol Marketing Bill introduced by Sarah Wollaston MP in 2011—provides a simple framework that can offer clarity on what marketing practices are and are not allowed. Under this model, the promotion of alcohol would be explicitly restricted to: media that adults use; at point of sale in licensed premises; and at local producer events.

4.5 As an interim measure, the NHF calls for an independent evaluation of controls on alcohol marketing and advertising—not one linked to an industry lobby group such as the Portman Group. Excess alcohol consumption is of prime public health importance and the National Institute for Health Research could be an appropriate body to commission an evaluation of industry marketing and advertising practices. [2.12]

5. Industry’s Responsibilities

5.1 The NHF welcomes the acknowledgement in the Strategy that “industry needs and commercial advantages have too frequently been prioritised over community concerns.”8 However, NHF remains concerned that the Strategy reinforces existing roles and structures for inappropriate industry involvement. To address this conflict of interest, the NHF recommends that industry contributes to public health initiatives via a truly independent charity or blind trust. The high extrinsic costs to society caused by alcohol harm are borne by the public purse. It is justifiable that the alcohol industry should be expected to contribute to meeting these costs on the basis that the “polluter must pay”.

5.2 NHF is not satisfied that the provision of adequate, consistent labelling of alcohol products will be achieved through voluntary commitments from the drinks industry. Under the Responsibility Deal, only 80% coverage is pledged by the end of 2013 and this does not yet include calorie labelling. We would like to see Government action to introduce mandatory standardised labels on alcohol products that incorporate unit content, CMO health guidelines and messages, calorie labelling and directions to independent health information.

5.3 The NHF recommends that the Government ensure a fully independent and transparent review of the industry-funded Drinkaware and its effectiveness. [4.10]

5.4 In line with WHO recommendations, business operators should not be involved in setting public health policy priorities.9 All programmes and policies should be subject to proactive monitoring and independent evaluation, including those with private investment.

May 2012

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 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.

4 [ ] indicate associated section(s) of The Government’s Alcohol Strategy.

5 Meier, P et al, 2012. Model-based appraisal of alcohol minimum pricing and off-licensed trade discount bans in Scotland using the Sheffiled Alcohol Poliy Model (v 2). University of Sheffield – Alcohol Minimum Price Modelling Research: Second Update

6 Health Committee, First Report of Session 2009-10, Alcohol, House of Commons 151-I. 2010.

7 Hastings, G, Brooks, O, Stead, M, Angus, K, Anker, T, & Farrell, T 2010. Failure of self regulation of UK alcohol advertising. BMJ, 340.

8 Home Office, The Government’s Alcohol Strategy. 2012:3

9 World Health Organization. The World Health Report 2002: reducing risks, promoting healthy life. Geneva: WHO, 2002.

Prepared 21st July 2012