Health Committee - The Government's Alcohol StrategyWritten evidence from Drink Wise North West (GAS 46)

About Drink Wise North West

Drink Wise North West gives a voice and support to public sector professionals and community members who want to end alcohol harm. We work with the NHS, Local Authorities, the voluntary sector and communities to reduce the negative impact of alcohol—saving lives, reducing crime and cutting the financial and social costs of alcohol. We work on behalf of all 24 of the Directors of Public Health across the North West of England, Local Authority Chief Executives and we have more than 200 Drink Wise North West alcohol champions, who include clinicians, academics and senior police officers. We are hosted by the social enterprise, Our Life, which ensures people are given the opportunity to influence and deliver change on a range of issues to support their community’s wellbeing. www.drinkwisenorthwest.org and www.ourlife.org.uk.

1. Summary

Drink Wise North West welcomes the publication of The Government’s Alcohol Strategy (2012), particularly the proposal to introduce a minimum price for alcohol.

We urge the Government to set the minimum unit price at 50p per unit, and to introduce a “public health levy” to offset any potential profit made by retailers or producers.

We welcome the Government’s acknowledgement that “the alcohol industry has a direct and powerful connection and influence on consumer behaviours”,1 especially that “marketing and advertising affect drinking behaviour.”2

However, we are concerned that there is a need for greater independence from the industry when regulating alcohol advertising, marketing and promotion.

We also recommend stronger proposals to protect children and young people through a Loi Evin approach and greater powers to regulate the newer forms of alcohol promotion and marketing, like social media.

We remain concerned that the Responsibility Deal is given prominence in the alcohol strategy, but industry is actively undermining this work by lobbying against evidence based measures like minimum unit pricing.

The ongoing involvement of industry in public health campaigns is also of concern as it represents a conflict of interest.

Whilst we welcome the emphasis on local action, we believe this should be underpinned by a framework of national leadership, support and advice to support local areas to develop cost effective and best practice based treatment and prevention.

Response to Areas of Interest Outlined by the Inquiry Terms of Reference

2. Establishing who is responsible within Government for alcohol policy in general, policy coordination across Whitehall and the extent to which the Department of Health should take a leading role

2.1 Harmful alcohol consumption is a population level issue which has enormous societal consequences, including lost life, chronic illness, crime and antisocial behavior.

2.2 Recent research shows that addressing the negative impacts of alcohol costs the North West of England at least £3 billion per year (this includes the burden on the NHS, Police, Social Services, as well as the cost to the economy, for instance through lost productivity).3

2.3 The sheer scale of the challenge that excessive alcohol consumption poses, means that alcohol policy necessarily falls under a range Government departments. These include: the Department of Health, Home Office, the Treasury, the Department for Education and the departments of Culture, Media and Sport, Transport, Communities and Local Government and the Ministry of Justice.

2.4 This can mean that co-coordinating alcohol policy effectively is a challenge. We recommend therefore a cross departmental alcohol unit, which could report to the Home Affairs (Public Health) Cabinet sub-committee. The unit could be led by the Chief Medical Officer, who would be well placed to mitigate the differing concerns of various departments.

3. Coordination of policy across the UK with the devolved administrations, and the impact of pursuing different approaches to alcohol

3.1 Alcohol policy should be coordinated across the UK where possible and be based on sound, independent evidence.

3.2 The level at which minimum unit price is set should be coordinated across the UK jurisdictions. The Scottish Government is committed to introducing a minimum unit price for alcohol, which we expect to be set at no lower than 45p per unit. It would be counterproductive if there was a differential minimum unit price in England and Wales.

4. The role of the alcohol industry in addressing alcohol-related health problems, including the Responsibility Deal, Drinkaware and the role of the Portman Group

4.1 Drink Wise North West welcomes the acknowledgement in the strategy that “industry needs and commercial advantages have too frequently been prioritised over community concerns.”4

4.2 The alcohol strategy relies heavily on organisations, which are totally funded by the alcohol industry such as the Portman Group and Drinkaware.

4.3 We are concerned about the involvement of industry in educating the public about the risks of alcohol. This is a clear conflict of interest because the alcohol industry has a responsibility to their shareholders to maximise profit by selling more alcohol.

4.4 Even when there is public health involvement in such organisations (such as Drinkaware), the involvement of industry leads to an inherently specific remit and limited role in public health strategy and action. This is reflected for instance in Drinkaware’s primary focus on young people and binge drinking, which we believe excludes other groups who are at risk of alcohol related death or illness.

4.5 We are also sceptical about the commitment of industry to play a full role in rebalancing the UK’s drinking culture, because many alcohol companies and representative organisations are active in undermining the international evidence base for policies such as minimum unit pricing.

4.6 We argue that any organisation undertaking the important role of public education should be completely independent of the alcohol industry.

4.7 We recommend instead using independent public health experts and evidence when setting behaviour change agendas, or running education campaigns, in line with WHO recommendations.

4.8 If funding is to be leveraged from industry (which we believe is a good idea), then industry should have no say in how this is spent. Instead we would support the establishment of a truly independent charity or blind trust to oversee this work.

4.9 We also believe that education should be reinforced by a regime of national action to tackle price, promotion, product and placement so that it is becomes easier for people to drink less, rather than more.

5. The evidence base for, and economic impact of, introducing a fixed price per unit of alcohol of 40p, including the impacts on moderate and harmful drinkers; evidence/arguments for setting a different unit price; the legal complexities of introducing fixed pricing

5.1 Drink Wise North West strongly supports the introduction of a minimum price per unit and congratulate the Government on this intention.

5.2 This step acknowledges the clear relationship between price and harm. Alcohol is 44% more affordable than it was in 1980,5 and a survey conducted in the North West found that 80% of people said that low prices and discounting increase their alcohol consumption.6

5.3 The Sheffield University study indicates that the introduction of a minimum price would reduce consumption amongst harmful drinkers and young drinkers while having a minimal effect on those drinking within the guidelines.7

5.4 Drink Wise North West strongly supports a level of 50p per unit because this will save more than twice as many lives and avoid an additional 30,000 crimes and more than 50,000 hospital admissions per year than 40p.8 Table A below shows the benefits (per year) after ten years:

Table A

COMPARISON OF THE EFFECTS OF A MINIMUM UNIT PRICE OF 50P AND 40P9

	Deaths	Hospital admissions	Days absent from work	Crimes
Minimum unit price at 40p	1,380 lives saved	40,800 reduction	100,000 less	16,000 avoided
Minimum unit price at 50p	3,400 lives saved	98,000 reduction	300,000 less	46,000 avoided

5.5 We also recommend that a minimum price should be closely linked to general inflationary pressures, and should increase in line with official rates of inflation each year. The experience of some Canadian provinces which have minimum unit pricing, shows us that the price level needs to be regularly reviewed to maintain its effectiveness.

5.6 Drink Wise North West supports the introduction of a “public health levy” on retailers and/or producers should they accrue additional profits due to the introduction of a minimum unit price. This levy could be used to directly fund alcohol health services and we suggest that there is a precedent for this type of approach in Scotland’s Public Health levy.

5.7 We are aware that industry is claiming that a minimum price per unit will lead to an increase in illegal activity. We refute this claim based on evidence given during the passage of the Scottish Bill.10

5.8 However we do support the proposals for improving methods to deter and catch illegal sales of alcohol, such as introducing fiscal marks for beer, supply chain legislation, and a licensing scheme for wholesale alcohol dealers is to be welcomed. In WHO Europe’s recent report “Alcohol in the European Union: Consumption, Harm and Policy Approaches” it says “the level of illegal trade and smuggling predominantly depends on the level of Government enforcement.”

5.9 We also support the proposed ban on multi buys as an effective and complementary policy alongside minimum unit pricing.

6. The effects of marketing on alcohol consumption, in particular in relation to children and young people

6.1 In the BMA’s Under the Influence report it states that: “a substantial body of research has found that alcohol advertising and promotion influences the onset, continuance and amount of alcohol consumption amongst young people.”11

6.2 The Health Select Committee (2010) also found that the current regulatory framework for alcohol marketing is not adequate.12

6.3 Therefore, we are concerned that the strategy does not, in our view, contain robust proposals to reduce children’s exposure to alcohol advertising and marketing.

6.4 Instead, it relies on working with a partially self regulatory system, which again is constrained by the conflict of interest that industry’s overwhelming aim to make profit by encouraging people to drink more poses.

6.5 We also believe that the current system has not evolved adequately to take account of the decline in “traditional” advertising to other forms of marketing such as football sponsorship, promotions, musical festivals and viral and social media marketing where the potential exposure of children is even more problematic.13

6.6 We argue, in line with WHO and BMA that all regulation of alcohol advertising and marketing should be wholly independent of the alcohol industry. An independent body should be set up to perform this function and it should have sufficient resources and expertise to be able to look at the newer forms of alcohol marketing and promotion, as well as more traditional advertising routes.

6.7 To protect young people, Drink Wise North West also supports an approach to alcohol advertising similar to that taken in France via the Loi Evin, whereby the promotion of alcohol would be restricted to media that adults use.

7. The impact that current levels of alcohol consumption will have on the public’s health in the longer term

7.1 Someone is admitted to hospital every four minutes in the North West.14

7.2 The Office for National Statistics estimated that in the UK there were 8,664 alcohol-related deaths in 2009, which is more than double the 4,023 recorded during 1992.15 By way of a comparison 1,738 people died due to drug misuse in 2008.16

7.3 In its publication “reducing alcohol harm” the British Liver Trust states “The challenge of alcohol misuse is reaching epidemic proportions in the United Kingdom; with the average intake of alcohol rising steadily, NHS admissions from alcohol increasing” and cites the research that suggests that the current death toll from alcohol is equivalent to “a jumbo jet crashing every 17 days.”17

8. Any consequential impact on future patterns of service use in the NHS and social care, including plans for greater investment in substance misuse or hepatology services

8.1 A recent report found that in the North West the costs of alcohol to the NHS were almost £650 million per year and costs to social services were more than £231 million per year.18 This shows that huge savings can be made if we can reduce alcohol consumption and correlating harm.

8.2 Local leaders and professionals across the North West are all keen to make sure that they tailor services for local need but with the best national advice, guidance and support.

8.3 For this reason local areas in North West have invested in Drink Wise North West to help them to “scale up” interventions that are effective and to help them to identify where it is more cost effective to work together. This work has for instance led to an identified £36 million of NHS savings in the next two years in the North West. We believe there is merit in this model being explored nationally.

8.4 We also contend that Public Health England and the NHS Commissioning Board should play a role in developing a shared national framework for tackling alcohol harm, which provides the leadership, support and advice that local areas need to develop cost effective and best practice based local treatment and prevention plans.

9. Whether the proposed reforms of the NHS and public health systems will support an integrated approach to future planning of services for people who experience alcohol-related harm

9.1 As public health responsibilities, including alcohol services, are moving from the NHS into local government we believe that this presents a revitalised opportunity to develop robust alcohol-harm-reduction programmes across a range of partners.

9.2 However, we recommend that there is clearer guidance/leadership around the role of GPs and others in commissioning alcohol related services in particular.

9.3 There is a real danger that CCG’s and other commissioners (like the Police) assume that alcohol is covered entirely by the public health budget.

9.4 We appreciate that it is primarily up to local leaders to make the case through effective local advocacy and partnership working, however we believe the government, as well as Public Health England and the NHS Commissioning Board, can provide an essential leadership role to promote the pooling of resources.

May 2012