Health Committee - The Government's Alcohol StrategyWritten evidence from Scottish Health Action on Alcohol Problems (GAS 58)

SHAAP Response to UK Government’s Alcohol Strategy

SHAAP, which was set up in 2006 by the Scottish Medical Royal Colleges and Faculties, is pleased to respond to the Health Committee’s enquiry into the UK Government’s Alcohol Strategy.

Our members have had the opportunity to contribute to the responses submitted by the Alcohol Health Alliance and the Royal College of Psychiatrists and we endorse their views, in particular we welcome the commitment to introduce a minimum unit price for alcohol.

Our experience in Scotland is that an effective Alcohol strategy requires a clear vision, informed by evidence and learning from other countries and strong public advocacy. SHAAP has taken a leading role in this. The medical profession has been prominent in the debate within Scotland and, we believe, has had a key role in raising awareness of the extent of alcohol problems and developing and promoting effective policy and practice solutions.

Effective alcohol strategy requires effective co-ordination and mutual support by Government at all levels, local, devolved, UK and Europe and jurisdictions must work together in order to establish and maintain progress.

1. Minimum Unit Price (page 7)

We believe that a minimum unit price is one of the most effective measures in reducing the harm which comes from the consumption of the cheapest forms of alcohol. SHAAP is convinced by the considerable international evidence on the relationship between price and harm (Wagenaar et al, 2009; Babor et al, 2010) and the studies which have shown that the price of the cheapest type of alcohol, the floor price, is of particular importance (Grunewald et al, 2006).

The initial minimum unit price should be high enough to be effective in reducing harm and should have a noticeable impact for all income groups. An effective monitoring system and a simple implementation system are essential. The impact of minimum unit price should be monitored closely with prompt and good quality data enabling adjustment as required.

We see several advantages to a minimum price set at the effective level across the UK.

2. Multi-buy Discount Ban (page 7)

Scotland has already implemented restrictions on irresponsible promotions in both the on trade and off trade sectors with some evidence of benefit already recorded. SHAAP welcomes the proposal to launch a consultation on multi-buy discount ban but we believe that this should include irresponsible on trade multi-buy promotions.

3. Alcohol Advertising (page 8)

SHAAP welcomes the recognition in the strategy of the negative impact of marketing and advertising but we believe a more vigorous approach is required. The current system of co-regulation with the ASA and the Portman Group is ineffective and the Commons Health Committee has concluded it is failing young people (House of Commons Health Committee 2010). Regulation should be independent of both the alcohol and advertising industries.

4. Changing behaviour at local level—Licensing (page 10)

SHAAP welcomes the recognition that there should be an obligation on licensing boards to assist in protecting and improving public health and that a public health objective should inform licensing decisions. To make a difference this needs to be informed by needs good local data. Local health information, such as alcohol-related hospital admissions, should be informing decisions made by licensing boards. In addition to this we believe that there should be a clear statutory role for health bodies in licensing decisions at local level. Implementing the public health principle in Scotland has required significant advocacy work by SHAAP and others and the effort required should not be underestimated.

5. Treatment and Support—A Stepped Care Approach (page 15 and 22)

We agree with the observations of our colleagues in AHA that the UK strategy is not strong on support and treatment. We endorse a whole population approach along with interventions targeted at those experiencing and at greatest risk of serious problems. A stepped care approach to intervention is consistent with this approach. There has been considerable development of screening and brief intervention in Scotland and our experience can be useful to other parts of the UK. The Scottish SBI programme required central planning, monitoring and support for effective delivery. This was particularly important in securing the involvement of Primary Health Care, the setting with the strongest evidence base and best opportunity to access a broad population. In addition to SBI, ring fenced investment allowed the development of a range of specialist services for those with more entrenched alcohol problems. These developments were in line with the evidence base reviewed by the Scottish Intercollegiate Guidelines Network and the Health Technology Board for Scotland in the early 2000s and since further developed by NICE.

References

Babor T et al (2003). Alcohol: No Ordinary Commodity. Research and Public Policy. Oxford University Press.

Gruenwald P J, Ponicki W R, Holder H D & Romelsjo A (2006). Alcohol prices, beverage quality, and the demand for alcohol: quality substitutions and price elasticities. Alcohol Clin Exp Res, 30(1): 96–105.

Wagenaar A C et al (2009). Effects of beverage alcohol price and tax levels on drinking: a meta-analysis of 1003 estimates from 112 studies. Addiction, 104(2) 179–90.

May 2012

Prepared 21st July 2012