Health Committee - The Government's Alcohol StrategyWritten evidence from the Association of Licensed Multiple Retailers (GAS 65)

1. The Association of Licensed Multiple Retailers (ALMR) welcomes the opportunity to submit written evidence to the Health Select Committee inquiry on the Government’s alcohol strategy.

2. By way of background, between them our 103 member companies operate nearly 12,000 outlets, employing 350,000 staff (out of a total of half a million in the industry). These outlets are primarily pubs and bars but also include casual dining outlets, licensed accommodation providers and nightclubs. Our annual benchmarking survey shows that food led pubs (classified as where food represents 30% or higher as a percentage of turnover) now represent the largest sector in the industry, accounting for one-in-three of the total. On average, food sales now make up a quarter of the turnover of all pubs, rising to above 50% for food-led outlets. Indeed in 2011, food sales outstripped beer revenues in the retained estate of Birmingham-based pub operator Mitchells and Butlers for the first time.

3. We represent all of the major multiple licensed retailers with hundreds of premises down to the small independent companies operating 50 outlets or fewer under their own branding, predominantly suburban community outlets. These are valuable social and economic assets—community centres, social spaces, tourist attractions and significant revenue generators—as well as providing a well regulated and controlled environment for people to enjoy alcohol responsibly and socially.

4. The ALMR is in the process of absorbing the 250-strong Bar Entertainment and Dance Association into membership, creating one retail voice for licensed hospitality. It is important to note that we do not represent brewers or other alcohol producers. Our members’ retail alcohol products responsibly and ensure they are enjoyed in a supervised environment. They are not responsible for the products themselves and cannot control how they are packaged or what volume of alcohol they contain. This in contrast to the supermarkets who can influence such matters through their supplier relationships, purchasing rights and own brand products.

5. We would make a few opening remarks that we hope the Committee will find useful when considering our specific responses to the terms of reference it has set out below.

6. Launching the Alcohol Strategy, the Prime Minister described pubs as the “safest and friendliest place to drink... an important part of the social fabric of our communities”. The fundamental premise of the strategy is to make supermarkets more expensive in order to benefit and support the pub. Ministers are clear that preloading is the real problem and drives a lot of late night disorder and causes health problems. The Prime Ministers says this is behind more controls—“it is too easy to get drunk on cheap alcohol before they even set food in the pub”.

7. Unlike his cabinet colleagues in the Home Office and Number 10 the Health Secretary was mute on the role the pub might play in helping improve our relationship with alcohol. Instead he highlighted that “last year there were 1.2 million admissions to hospital associated with alcohol”. Obviously alcohol is a factor and any death from misuse is one death too many, but we consider that we have to put these figures in context. For example, the majority of deaths from liver disease are not directly attributable to alcohol—indeed the proportion that is alcohol related is actually falling. We are in danger of failing to tackle this significant health problem by focusing on alcohol to the exclusion of all other lifestyle risk factors.

8. The health lobby argues that a 10% increase in price reduces consumption by 5%, but we and the rest of the industry focus on the more sophisticated arguments of using policy levers to switch consumption patterns. Encouraging people to drink in pubs means that they consume measured quantities served by supervised by trained staff.

9. Recognition of this by Government in the alcohol strategy is a start, but a VAT cut for eating and drinking out would help make that a reality, and that continues to be a priority.

10. Our response to the Committee’s specific terms of reference is as follows:

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

11. The ALMR welcomes the Committee’s interest in this area as it notes that the Prime Minister himself launched the Government’s Alcohol Strategy and there are a number of Government Departments pursuing policy and regulatory initiatives which specifically reference the positive contribution pubs and bars can make to local economies and communities across the UK. These include the recently published National Planning Policy Framework and the Government’s response to the Portas Review of the High Street.

12. Primary Care Trusts and Local Health Boards are now responsible authorities with a direct say in local licensing matters, so it is important that the Department of Health at a national level recognises firstly, the basis on which alcohol related admissions are calculated and secondly, why people end up in our hospitals in the first place.

13. The Department of Health has recently released guidelines that will see the number of hospital admissions counted as alcohol-related fall dramatically.

14. The previous guidelines called for all diagnoses to be counted towards admissions statistics, so if someone admitted for a particular health problem also had a problem categorised as alcohol-related (like hypertension or cardiac arrhythmia) then the admission would count as alcohol-related. The new guidance will mean only the primary diagnosis will be counted in the admissions statistics.

15. Previously, diagnoses “partially attributable” to alcohol made up the bulk of all alcohol-related admissions. There were 194,800 admissions in 2009–10 where the primary diagnosis was either partially or wholly attributable to alcohol, less than 20% of the widely reported figure of one million which the Secretary of State identified. Only 68,500 admissions were wholly attributable to alcohol—representing an increase of 52.2% from 2002–03—and this increase can be at least partially explained by a general rise in admissions (of 27%) and the four hour A&E target resulting in the creation of alcohol wards for those not in danger but too drunk to be released.

16. On the second matter, we are very concerned that at present all too often the blame for alcohol related admissions to hospital is laid at the door of the nearest pub, bar or nightclub. This is despite the well-documented habit, particularly among young people, of “preloading” and the continued availability of alcohol in the off trade and “fast food” establishments late at night—after many of our members’ premises have closed.

17. Figures from the Centre for Public Health, Liverpool John Moores University, suggest that those who drink at home are two and half times more likely to have been in a fight in the last 12 months, and pre-loading is more strongly associated with being involved in nightlife violence than the total amount of alcohol drunk. Police Guidance (first issued in 2006) instructs that anyone “found to be drunk and incapable should be treated as being in need of medical assistance and an ambulance called” with custody used only as a “last resort”.

18. People pre-load on alcohol because it’s much cheaper to buy it in the supermarket than in a pub or bar. Alcoholic drinks can be as much as 10 times more expensive to purchase in a pub or bar than they are in the supermarket or off licence. A glass of wine that costs £4.86 on average in the on trade would be the equivalent of £0.64 purchased from the off trade. This is eight times more expensive. Six years ago it would “only” have been three times more expensive.

19. Increasing excise duty faster than the rate of inflation via the “escalator” and allowing supermarkets to use their tax free status on food to subsidise loss leading alcohol promotions have had the combined effect of driving consumers to purchase their alcohol from the off trade. The outcome is that over 70% of all alcohol in this country is now purchased through the off trade. This is set only to increase. The latest Beer Barometer published by the British Beer and Pub Association in April 2012 shows pub beer sales down 6% in the first quarter of 2012, compared to a 5% increase in off-licence sales. The overall consequence is to bring down the average price paid for alcohol and this will not help promote responsible consumption.

20. In terms of the extent to which the Department of Health should take a leading role—we consider that assessing our industry through a one dimensional regulatory framework—whether it be alcohol harm or alcohol crime and disorder, simply does not do justice to today’s modern pubs and bars and what they have to offer.

21. With food led pubs in the ascendancy our larger members are playing an active role in the Department of Health’s Responsibility Deal not just through delivering the pledges agreed on alcohol but on food as well. We would like to see more of an explicit recognition of our members’ ability to drive change through their establishments and the benefits that consumers up and down the country have experienced.

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

22. We are following closely the Scottish Executive’s progress in legislating for a minimum unit price of alcohol. Like Scotland, the UK Government’s alcohol strategy recognises that minimum unit pricing is only one component of a number of measures that could be introduced to prevent the selling of alcohol at “pocket money prices”. While there are differences of opinion among members regarding the efficacy of minimum pricing alone we support a multi-layered approach to tackling the problem.

23. In this context, the Alcohol Strategy also raises the prospect of revisiting the existing Code of Practice on promotions, price and advertising. The licensed trade is already governed by five measures under the Code. There is the opportunity to level up the playing field between the on-trade and the off-trade by using the remaining slots available to address shortcomings in the off trade.

24. In addition we consider that local authorities need to be encouraged to use their existing powers under the 2005 Act better to control supermarket sales and promotions. They already have the power to impose restrictions on siting, hours of opening and bulk purchasing (such as existed under the previous licensing regime), but current Government Guidance indicates suggests that off-licences should be subject to light touch regulation and should be granted in the terms they are requested. We believe that this should be amended so that applications are to be scrutinised in the same way as those for pubs and bars.

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

25. The licensed trade takes its responsibility in addressing alcohol related health problems very seriously. Our larger members are active participants in both the food and alcohol components of the Department of Health’s Responsibility Deal. We are also working with our smaller member companies to explore how best they can implement similar initiatives learning from best practice from within the trade.

26. Drinkaware is a producer-funded initiative with messaging on responsible drinking delivered by our members at point of sale. Overall the alcohol industry contributes £5.2 million in funding to Drinkaware initiatives with retail members providing £1 million of that. Furthermore, that sum is more than matched by “in kind” support resulting from the in-house costs involved in advertising and promoting Drinkaware messages and campaigns to those that visit our premises, and in social media communications.

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

27. We would like to draw the Committee’s attention to the latest General Lifestyle Survey published by the Office for National Statistics in February 2012 which states that between 2005 and 2010 average weekly consumption of alcohol fell steadily from 14.3 units to 11.5 per adult. The proportion exceeding the recommended weekly limit fell from 31% to 26% (men) and 21 to 17 (women). Those admitting to heavy drinking fell by about a third and 87% of people say that they are giving themselves three alcohol-free days a week—in line with the latest recommendation from the British Medical Association.

28. While we recognise that we have to tread carefully with statistics around self-reported behavior these figures are supported by alcohol sales data. This has fallen, in both value and volume, from about 11.6 litres of pure alcohol per adult per year in 2004, to about 10 litres in 2011.

29. This will have a knock on effect on alcohol related admissions. Those who present with chronic liver disease represent the consequences of excessive alcohol consumption over a number of years. There is every reason to suppose that figures will fall over the long term as the consequence of falling alcohol consumption.


30. The Alcohol Strategy emphasises tackling the problem of excessive drinking from “every angle” and we need a government that wants to work in genuine partnership with our industry.

31. This will be a partnership that helps us exercise our supervisory duties by helping pubs invest and modernise to attract a more diverse community through their doors; one that levels up the playing field between pubs, bars and supermarkets by narrowing the price differential and limiting the unconditional availability of alcohol in shops; one that provides us with certainty that politicians really do appreciate just how much we can be both a force for good on local high streets and in local communities as well as an engine of growth and job creation in our local economies.

32. If this country wants a grown up relationship with alcohol then politicians and regulators should explore ways of using policy and fiscal levers to encourage more people to drink in supervised pubs rather than in the unsupervised environment of the home.

May 2012

Prepared 21st July 2012