Health Committee - The Government's Alcohol StrategyWritten evidence from The Alcohol Harm Reduction Group in County Durham and the Alcohol Strategy Implementation Group in Darlington (GAS 61)

1. 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

1.1 The strategy published by the Home Office, whilst encompassing the broad range of issues, is light on detail. In particular there is no indication of financial commitment, targets and outcomes to tackle alcohol related harm.

1.2 The strategy does not achieve an even balance between prevention, treatment and disorder. Instead the emphasis is on the last of these.

1.3 The document perpetuates the tabloid beliefs that any alcohol problems we have are firmly the result of young people binge drinking and those who make unacceptable choices either by being ignorant or irresponsible. It does not reflect that we have significant numbers in the population who are drinking at increasing and higher risk levels which impacts on wide range of health and social problems.

1.4 The ownership by the DH appears to be small. Whilst we welcome support for Identification and Brief Advice (IBA) and Alcohol Liaison Nurses in hospitals, this does not go far enough. We welcome the need for IBA to be included in the QOF for GPs, though this needs to be actioned imminently in order to prevent further harm. Investment is required across all four tiers of the treatment pathway for both offenders and non-offenders, recovery/aftercare and support for families. Our concern continues to be the lack of identifiable funding available to address the range of problems beyond anti-social behaviour.

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

2.1 We agree that alcohol policy ought to be coordinated across the UK. Work across the north east through our Balance office already ensures that our neighbours share sound evidence based practice. We believe however that the level at which minimum unit price (MUP) is set should be coordinated across the jurisdictions.

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

3.1 The Alcohol Harm Reduction Group (in the case of County Durham) and the Alcohol Strategy Implementation Group (in the case of Darlington) welcomes the strategy’s indication that the alcohol industry needs to do more. However we think that there is a significant conflict of interest when businesses which have an obligation to increase profits for shareholders are involved in shaping public health policy.

3.2 Current responsibility deals have indicated to us that the alcohol industry will not deliver the changes needed unless those changes are supported by legislation. The conflict arises when the alcohol industry’s outcome to maximise sales is put against the need to reduce the amount of alcohol consumed at a population level.

3.3 We are concerned that the strategy reinforces this conflict and seems to rely on organisations which are totally funded by the alcohol industry eg the Portman Group.

4. 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

4.1 The Alcohol Harm Reduction Group (Co Durham) and the Alcohol Implementation Strategy Group (Darlington) supports a minimum price per unit to address the problem of the affordability of alcohol. Evidence from the Sheffield study indicates that the introduction of minimum price would reduce consumption amongst harmful drinkers and young drinkers and at the same time have a minimal effect on those drinking within the recommended guidelines.

4.2 We welcome the commitment to the introduction of a minimum unit price for alcohol. However, we accept the view of many independent experts including the view of the BMA and believe that the proposed 40p per unit level would be ineffective. Our view would be the minimum unit price should be set at 50p and reviewed regularly.

4.3 Our worst case scenario would be if MUP created additional profit for the alcohol industry that was then ploughed back into increasing the sophistication of alcohol marketing. We would like to see how the government would address this issue, including increasing taxation.

4.4 The introduction of a MUP at 50p would have the advantage of better management of alcohol pricing between on and off licence premises, protect small businesses, including the community pub, as well as tackle the issue of pre-loading.

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

5.1 The Alcohol Harm Reduction Group (Co Durham) and the Alcohol Strategy Implementation Group (Darlington) welcomes the strategy’s recognition of the role played by alcohol advertising and marketing which impacts on young people. It is widely known that market research data on 15–16 year olds is used to guide campaign development and many marketing documents make reference to the need to recruit new drinkers. Additionally girls and boys are bombarded by messages that build and reinforce positive associations between drinking and sex. Because most adverts are aimed at young men, women are generally portrayed within limiting gender stereotypes. Researchers have raised concerns about the way in which sexist concepts are being heavily promoted through advertising to young consumers. The danger is twofold—promoting young people to drink more and demeaning women or implying the promise of sex.

5.2 Music and sport sponsorship by the alcohol industry is not specifically included in any advertising code, though clearly has enormous impact—again this needs to be reviewed.

5.3 We also welcome work to develop an effective online age verification system to prevent alcohol advertising and marketing activity being presented to young people on line.

5.4 We continue to be concerned that alcohol advertising is not fully addressed in the strategy and continues to rely on the industry’s self regulation. We would prefer to see a more rigorous approach taken as, for example, in France, where alcohol promotion is restricted to media only accessed by adults.

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

6.1 Evidence which indicates the impact on public health of the current levels of alcohol consumption paint a concerning picture, especially when the impact is matched against the need for service provision. Over the period 2002–03 to 2009–10 there have been admission rate increases of 121% in Darlington and 135% in County Durham.

6.2 The Office of 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.

6.3 In its publication Reducing Alcohol Harm, the British Liver Trust states that “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 research that suggests the current death toll from alcohol is equivalent to “a jumbo jet crashing every 17 days”.

6.4 It is estimated that 80% of liver disease is directly related to alcohol and possibly around a quarter of the total attributable mortality. Liver disease is the fifth most common cause of death in England. However, the British Liver Trust warns that this prevalence is growing and “mortality from liver disease could overtake stroke and coronary heart disease as a cause of death within 10 to 20 years”.

6.5 The British Liver Trust states that “there is unequivocal evidence of a relationship between alcohol consumption and liver disease” and goes on to suggest that “liver death rates offer a good measure for the success of any alcohol policy”.

7. 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

7.1 County Durham PCT secured nearly £3 million for alcohol prevention and treatment services over the past four years and Darlington secured nearly £600k. With the move of Public Health to Local Authorities there is a concern that the commissioning of alcohol services is not a mandated, but a discretionary, service. We believe this needs to change. Additionally, the current investment levels need to be maintained and increased over time as the demand also increases.

7.2 There has been an indication that substance misuse services should be jointly provided in future. Whilst this may create efficiencies and provide some resilience for small areas where resources are limited, we believe there needs to be further work to understand the different population group accessing treatment. For example, in County Durham the dedicated alcohol treatment service has 83% of clients with alcohol-only issues.

7.3 As CCGs will be commissioning hospital-based services, there needs to be a clear directive that they should work with Local Authorities to commission across the full treatment pathway rather than expect Local Authorities to fund all activity.

8. 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

8.1 The proposed health reforms include the responsibility for alcohol services moving from NHS to local government. Our current configuration to address alcohol harm already works across the services division. We expect that this opportunity will continue to allow us to develop robust alcohol harm reduction programmes across all sectors.

9. International evidence of the most effective interventions for reducing consumption of alcohol and evidence of any successful programmes to reduce harmful drinking, such as:

9.1 Public health interventions such as education and information:

(a)The cross-cutting approaches in the strategy are welcomed to address alcohol harm. However, whilst we value the provision of education and information, we believe that alcohol campaigns can only be effective when they are a part of wider programmes, as they have been in our social norms work.

(b)In County Durham and Darlington our local approach to alcohol misuse prevention appears to be working. We have worked closely with local secondary schools over the past four years to develop a “social norms” based approach, which uses information from our Healthy Behaviours Survey (last year 77% of pupils from secondary schools involved in the scheme took part).

(c)Results from this work show year-on-year reductions in reported levels of alcohol use, as well as evidence of helping young people to understand that drinking is not as common as they thought. High profile local communications campaigns based on the positive social norm messages have been an important component of this work, as well as clear links to PSHE education delivery.

(d)This strategy emphasises the responsibility of the NHS to address alcohol use during patient contacts. Positive social norm messages can be used to support this as part of a multi-agency approach to early intervention. We are looking to expand our social norms work to include primary schools, further education settings and major employers as part of a partnership approach to addressing alcohol misuse.

(e)The work also provides considerable intelligence to complement local needs assessment work. Undoing the perceived normalisation of young people’s alcohol misuse is one of our biggest challenges. Greater emphasis could be placed on this in the proposed strategy.

9.2 Reducing the strength of alcoholic beverages:

Steps to reducing the strength of alcoholic drinks, and labelling alcoholic beverages to warn of the harm of excess drinking are welcomed, but we question whether they should be left in the hands of the alcohol industry.

9.3 Raising the legal drinking age:

While we recognise the emerging evidence that alcohol can damage the developing brain until the early twenties, we believe that further work is required to educate the public about the dangers of alcohol to young people before such measures are considered.

9.4 Plain packaging and marketing bans:

We would welcome any additional research that shows young people are drawn to brands with eye-catching packaging. Studies show that the younger people start drinking, the more likely they are to develop alcohol problems later in life. However, we believe that this, whilst important, is only one dimension in advertising, and future measures ought to include advertising restrictions including no advertising before the 9pm watershed. We also believe that any advertising should not be associated with glamorous life style choices.

We would stress the importance of acknowledging and implementing what we already know to work. The World Health Organisation (WHO) recommend: “Increasing the price of alcoholic beverages is one of the most effective interventions to reduce harmful use of alcohol.” The policy recommends raising taxes on alcohol, prohibiting promotional pricing and establishing minimum prices for alcoholic beverages.

May 2012

Prepared 21st July 2012