advocating to reduce alcohol harm

Public Health (Alcohol) Bill

Chief Medical Officer Tony Holohan, Minister Alex White, Minister James Reilly and Minister Frances Fitzgerald announcing the measures to be included in the Public Health (Alcohol) Bill

THOUGH it may seem to strange to many, particularly given the high-profile nature of our relationship with alcohol, the measures announced to deal with our harmful drinking mark the first time that alcohol misuse has been addressed as a public health issue by an Irish Government.

Alcohol-related harm in Ireland currently claims three lives a day and costs the State an estimated €3.7 billion annually, putting a particular strain on our already overburdened health services, where 2,000 beds are occupied by people with alcohol-related illnesses every day.

Alcohol also plays a major role in a wide range of other very serious issues for Irish society, such as crime, suicide and child welfare. The harm that is caused by our drinking extends far beyond the individual who is drinking, to impact on families, their own or other people’s, communities, schools, hospitals and businesses throughout Ireland.

At an individual level, the majority of Irish drinkers are still drinking in a harmful manner. Our per capita consumption is 10.7 litres of pure alcohol per person aged 15 and over, a situation that is exacerbated by our unhealthy drinking patterns, particularly the prevalence of binge drinking.

The evidence regarding the need to tackle alcohol-related harm has been overwhelming for a long time and reports have been mounting for years now without anything happening in terms of a national strategy, so it’s very encouraging to finally see this Government announce its intention to take decisive action to tackle what is undoubtedly a major public health issue.

Speaking when the draft Heads of the Bill were announced in February 2015, Minister for Health Leo Varadkar said the proposed Public Health (Alcohol) Bill is part of a suite of measures designed to reduce alcohol consumption and limit the damage to the nation’s health, society and economy.

“Most Irish adults drink too much and many drink dangerously. This has an enormous impact on our society and economy through greater illness and higher health costs, public order and violent offences, road traffic collisions, injuries and absence from work. It is also associated with many suicides and instances of sexual violence, domestic violence and child harm,” said Minister Varadkar.

Pricing

At Alcohol Action Ireland, our public affairs work involves creating awareness of alcohol-related harm and offering policy solutions with the potential to reduce that harm. One of those policy solutions we have been campaigning for is minimum pricing, which will be a central plank of the Government’s alcohol strategy and it has the potential to be a life-saving measure.

The price of alcohol is directly linked to how much people drink across the population and to levels of alcohol-related harms and costs in a country. The World Health Organisation (WHO) has made it clear that there is “indisputable evidence that the price of alcohol matters. If the price of alcohol goes up, alcohol-related harm goes down”.

Minimum pricing sets a “floor price”, beneath which alcohol cannot be sold. It is able to target cheaper alcohol relative to its strength because the minimum price is determined by, and is directly proportionate to, the amount of pure alcohol in a drink.

These strong and cheap drinks being sold at “pocket-money prices” in the off-trade, which now accounts for 60% of all the alcohol sold in Ireland. This is a particular problem in supermarkets, where these drinks are often used as a “loss leader” and slabs of beer, for example, are sold at below cost.

These types of drinks are the alcohol products favoured by two vulnerable groups – the heaviest drinkers among us, who are most at risk of alcohol-related illnesses and death, and our young people, who generally have the least disposable income.

What minimum pricing won’t do is affect the price of alcohol in pubs or restaurants or the majority of alcohol products sold in the off-trade. Therefore it targets those most at risk, while having little or no effect on low-risk drinkers.

Canada is one of several countries that have already introduced minimum pricing. Research findings on the minimum pricing systems operating in two Canadian provinces provide the first empirical evidence of the effectiveness of minimum pricing.

In Saskatchewan province in Canada a 10% increase in the minimum price was associated with an 8.4% decrease in total alcohol consumption, while in British Columbia a 10% increase in the minimum price was associated with a 32% fall in wholly alcohol attributable deaths.

Minister Varadkar said that minimum unit pricing will effectively ban low cost sales of alcoholic products. “This measure has the potential to really impact on people who consume alcohol in a harmful and hazardous fashion and it can do so quickly,” said the Health Minister.

Two issues that are frequently raised in relation to the introduction of minimum pricing in Ireland are fears over cross-border trade and whether or not it would be sanctioned under European law. In relation to the first point, both North and South are working closely together on minimum pricing and both jurisdictions plan to introduce the measure.

A minimum price needs to be set at a level the evidence indicates will reduce the burden of harm from alcohol use. To aid this process a cross-border health impact assessment has been carried out as part of the process of developing a legislative basis for minimum unit pricing in the North and Republic of Ireland. The price will be set when the Public Health (Alcohol) Bill is published and will be at a level that the evidence shows will reduce the burden of harm from alcohol.

The University of Sheffield study (Model-Based Appraisal of Minimum Unit Pricing for Alcohol in the Republic of Ireland, 2013 (2014) noted that minimum pricing would only have a small impact on alcohol consumption for low risk drinkers. Somewhat larger impacts would be experienced by increasing risk drinkers, with the most substantial effects being experienced by high risk drinkers.

MUP is not expected to affect the price of alcohol in the on-trade (pubs, restaurants and clubs). The University of Sheffield study reported that the alcohol products most affected by this policy are those that are currently being sold very cheaply, often below cost prices, in the off-trade, i.e. supermarkets and off-licences.

Questions around the legality of minimum pricing are likely to be answered by a case taken against the Scottish Government by the alcohol industry. Scotland introduced minimum pricing in May 2012, but the bill was challenged by several alcohol industry bodies, who claimed that minimum pricing breaches the UK’s European Union (EU) Treaty obligations because it would restrict trade.

However, even if this were true, Article 36 of the EU Treaty makes it clear that public health measures such as minimum pricing are legal, provided they are proportionate. Or, in other words, it does not preclude potential restrictions “justified on grounds of … the protection of health and life of humans”.

In May of 2013 the Court of Session, Scotland’s supreme civil court, ruled in favour of the legality of the Scottish Government’s plans to introduce minimum pricing – the only judgement on the matter so far. This ruling has been appealed and a decision is due from the European courts shortly.

Marketing

The announcement by Government that the marketing and advertising of alcohol in Ireland is to be moved from the current system of voluntary codes and placed on a statutory footing, with a number of restrictions to be placed on current marketing and advertising practices by the drinks industry, is also of crucial importance if we are to change our harmful relationship with alcohol.

Self-regulation of alcohol marketing and advertising has clearly failed and our young people, in particular, through a variety of media, are constantly exposed to positive, risk-free images of alcohol and its use.

Comprehensive studies have shown that children and young people are not only exposed to a large amount of alcohol advertising, but that their behaviour and beliefs are influenced by these positive messages about alcohol and its use, increasing the likelihood that they will start to drink and drink more if already using alcohol.

The Government has said the Public Health (Alcohol) Bill will make it illegal to market or advertise alcohol in a manner that is appealing to children. “It provides for the making of regulations regarding the marketing and advertising of alcohol and includes provisions, inter alia, for restrictions on broadcast marketing and advertising, cinema advertising, outdoor advertising, print media and the regulation of sponsorship by alcohol companies.   It also provides for controls on the content of alcohol marketing and advertising,” according to the Department of Health. The provisions in relation to the marketing and advertising will be reviewed after three years.

It is hoped that these new measures will help to protect our young people from these sophisticated and powerful influences on their drinking behaviour and expectations. However, it is important to note that digital and social media are increasingly important in this regard and are not addressed by these measures.

Sports Sponsorship

There are few things in Ireland that can evoke feelings of passion, pride and unity like sports can. For those who participate in them, particularly our children and young people, they are also healthy activities and ones from which they can learn a lot about important values, such as fairness and teamwork. Unfortunately, our sporting organisations are now also one of the primary vehicles through which the alcohol industry markets its unhealthy products to the people of Ireland.

Sports sponsorship is a key part of the advertising and marketing campaigns of the alcohol industry and pairing a healthy activity, such as sport, with an unhealthy product, such as alcohol, makes that product seem less unhealthy and more acceptable. It also helps creates a culture where children and young people perceive alcohol consumption as a normal everyday part of their lives. Simply put, alcohol sponsorship of sport works in terms of increasing both awareness of products and sales. If it didn’t, the alcohol industry simply would not be spending so much money on it.

In October 2013, the Government referred this issue to a working group, chaired by the Department of An Taoiseach, which eventually recommended that a ban should not be implemented, but instead that the alcohol industry’s existing voluntary code of conduct should be put on a statutory footing.

Alcohol Action Ireland believes that plans to place the existing voluntary code of sports sponsorship conduct on a statutory footing will do more harm than good, and will act as a barrier to alcohol harm reduction among young people, in particular.

The existing code of practice written by, and regulated by, the alcohol industry is ’light touch’ in nature and fails to protect children from exposure to alcohol advertising.   Placing this on a statutory basis effectively rules out any action to protect children from exposure to alcohol advertising for a generation,” said Suzanne Costello, CEO of Alcohol Action Ireland.

“Our legislators need to do what is right for the health and well-being of society and ban alcohol sponsorship of sport, as they previously did with tobacco, for instance. Not to do so would be a failure to protect future Irish generations from the huge amount of alcohol-related harm that we currently experience,” said Ms Costello.

Availability

Separating alcohol from other products in retail outlets will be crucial in helping bring an end to the present situation, where alcohol is being sold as if it is just another every day item a family’s shopping basket, like bread or milk. Alcohol is not a grocery and it’s time we stopped treating it like one.

The Government’s intention to address the widespread availability of alcohol is therefore welcome. This is another area, like alcohol marketing and advertising, where a voluntary code written by industry will be replaced with a statutory code, with Environmental Health Officers given powers to enforce the regulations.

The effectiveness of the new statutory code will be reviewed after two years and if it is not achieving the policy objectives of Section 9 of the Intoxicating Liquor Act (2008), then Section 9 may be commenced, which would see retailers legally compelled to structurally separate alcohol from the other products in mixed retail outlets.

Labelling

The introduction of labelling is also a very positive move, as it will, for the first time, include clear warnings on alcohol products sold in Ireland about the dangers which alcohol poses to our health, as well as information regarding the strength and calorie content of the alcohol product.

The Public Health (Alcohol) Bill will provide that labels on alcohol products will contain:

”¢               Health warnings and advice (including for pregnancy)

”¢               The amount of pure alcohol as measured in grams

”¢               The calorie count

Under the Bill, on-licence holders (e.g. pubs, restaurants) are obliged to provide this information to customers in relation to alcohol products sold on draught or in measures e.g. pints, glasses of wine and measures of spirits. Health warnings and advice will also be included on all promotional material. The Department of Health plans to conduct primary research e.g. through focus groups to inform health labelling to ensure clarity and efficacy of message.

Conclusion

Alcohol misuse is a complex and multi-faceted problem and there is no single solution to it. While the measures put forward for inclusion in the Public Health (Alcohol) Bill are by no means the perfect plan, they are a good start.