Let's all consult again
Andrew Varley looks at the Consultation Document for the National Alcohol Reduction Strategy
So the National Alcohol Strategy for England and Wales has found its way to the Strategy Unit of the Cabinet Office having been unceremoniously prised out of the dilatory hands of the Department of Health. Perhaps it is only a matter of time before it finds its way, like licensing legislation, into the Department for Culture, Media and Sport – known to at least one senior civil servant there as the Department of Fun.
(See Alert, no.2 2002).
The new consultation is now under way and the Strategy Unit is eager to hear your views.
The Foreword to the consultation document begins with the mantra, now familiar from all government statements on the subject and which appears to have been copied from the drink industry's Portman Group: "Most adults in England drink and the majority drink sensibly. For them, drinking is part of a pleasurable social experience which causes no harm either to themselves or to others. Government has no need to intervene in this enjoyable aspect of life." The authors of the document appear to believe that no-one has a problem with alcohol unless they are in the last stages of cirrhosis, a condition which only a small minority even of chronic alcoholics achieves.
In its anxiety to offend no-one, especially the drink industry, and in its determination to avoid any accusation of perpetuating the nanny state, the government undermines the whole process by minimising the problem. It would have been a far more effective exercise had it used some of the facts set out by Alcohol Concern in its State of the Nation report (see page...)
We do not, however, have too long to wait before the bad news because "there is another, less pleasant side. For some people the misuse of alcohol brings serious consequences for the drinkers themselves, for their families and friends, and for the community as a whole. And this is a legitimate area of concern for a responsible Government." The tone will be familiar to all those who are of an age to remember the sort of condescending school books written for ten year olds thirty or forty years ago. The consultation document continues:
"Misuse of alcohol generates complex problems which need a co-ordinated response. The Government is committed to producing a national strategy for England to tackle the harmful effects of alcohol. The strategy will offer a clear and coherent way forward:
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to identify and where possible prevent the consequences of alcohol misuse;
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to help those who suffer the consequences of alcohol misuse; and
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to manage the consequences, for example tackling disorder and antisocial behaviour on the streets.
The Government has shown its commitment by taking nearly five years to get to this stage. It has dithered as to who is responsible for the production of the strategy, it has made it plain that the drink industry will play a major rôle, and it has now gone back to the beginning and is asking elementary questions, the answers to which have been available for years.
Health Minister Hazel Blears says in her Foreword to the consultation document: "The Prime Minister has asked me to act as the sponsor Minister for a Strategy Unit project on tackling the problems associated with alcohol misuse. In line with the Unit's normal approach the project will bring a cross-cutting perspective and a rigorous analytical approach to the difficult issues raised by alcohol misuse. Over the coming months the Strategy Unit will be working closely with the Department of Health and other Government Departments to develop a national alcohol harm reduction strategy.
"This consultation is a critical first stage in the development of the national alcohol harm reduction strategy."
Cheered as we all must be at the prospect of "a cross-cutting perspective", we might reflect that this "critical first stage" has been gone through before. There already has been an exhaustive consultation process which got us nowhere other than this rerun sponsored by the Strategy Unit. There are mountains of evidence already gathered. According to a spokesman for the Strategy Unit all this will merely be part of the data taken into consideration. The work done over the years by the Department of Health, it appears, will just be one piece of evidence having no more status than the representations of the drink industry. The representatives of the industry were prominent at the launch of the strategy and the session given over to a discussion of its rôle as a "key stakeholder" was chaired by Andrew Cunningham, the senior civil servant at the Department of Fun (his expression) who is the prime mover behind the new Licensing Bill. That Bill, of course, is seen by many as operating primarily in the interests of the industry.
Hazel Blears, like a schoolmistress explaining their task to a recalcitrant group of adolescents, patiently explains that "this document poses a number of questions about alcohol misuse. We would like you to consider and answer these questions, and over the next three months to give us:-
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your views on whether we have identified the key issues;
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your ideas and solutions for future action;
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your thoughts on current practice – what has worked well and what could work better."
And with these words we return to the drawing board. There is a ritual repetition of the mantra – "92 per cent of men and 86 per cent of women in Britain drink alcohol, and drinking plays a mostly enjoyable part in our culture" – and we proceed to the Introduction of the consultation.
"The Government believes that there is a rôle it can play to reduce the harm associated with alcohol misuse, for example by providing information, education and advice about the risks of drinking." It is interesting that this is the first thing which occurs to the authors and it reflects the influence of the industry itself and of its mouthpiece, the Portman Group. The industry is an eager proponent of alcohol education for the simple reason that it is one of the least effective means of dealing with alcohol problems. The most effective – control of density of outlet, statutory regulation, taxation, lower drink drive limits – have already been eschewed, presumably because they are anathema to the industry.
"The Government has therefore made a commitment to implement a National Alcohol Harm Reduction Strategy by 2004." Seven years – the drug strategy took a fraction of that time. "This strategy will need to acknowledge the complex nature of the problems caused by alcohol misuse, and recognise that effective action to tackle these problems will need to involve not only Government, but also key organisations such as the police, local authorities, the NHS, Drug and Alcohol Action Teams, voluntary organisations, employers," and, of course, "the drinks industry".
The Prime Minister has asked the Strategy Unit to play a key role in developing the National Alcohol Harm Reduction Strategy. The Strategy Unit's approach is to conduct a rigorous analysis of the evidence base, and apply creative and innovative thinking to new ways of tackling problems. It is able to bring a cross-cutting perspective to areas which span several parts of Government. The danger of leaving it with the Department of Health was that the finished article might, heaven forbid, have been too biased towards public health rather than the interests of the industry.
"The objective of the Strategy Unit's project will be to develop a vision, principles and framework for a strategy on harm reduction for England, working closely with the key Government departments and a range of key stakeholders inside and outside Government. The strategy will then be implemented by the Department of Health, in conjunction with other Government Departments. The project will be completed by the summer of 2003."
Finally, the document asks the question, "What do we want to know?"
Our first task is to determine whether the correct issues have been identified. This consultation is a key part of that process. The responses will be used to clarify the areas of work to be covered, and to help to shape the direction and outputs of that future work.
In addition to developing the principles that should underpin the strategy, we have identified the following areas of enquiry:
i) the cultural and behavioural issues around alcohol use and misuse
ii) health: prevention, treatment and the impact on the NHSiii) crime, disorder and anti-social behaviour: the effects on our
surroundings and community
iv) the implications for vulnerable groups, including children
v) education and communication
vi) the shape of the market and market-based solutions
vii) the economic costs and benefits of alcohol
For all these we want to bring together information on:
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Key facts and figures: what evidence is available? Where are the gaps?
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Trends: which factors created the current situation? What are the likely trends and scenarios for the future?
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Current approaches, both in terms of policy and in terms of delivery of services on the ground. What works well? What could work better? Where are the gaps? How well do policies and organisations join up and what are the barriers to more joint working?
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International comparisons. What can we learn about what to try and what to avoid? How well do these lessons read across to English culture?
Joined up Government? Is the Cabinet Office unaware that there is a strategy already in operation for combating alcohol-related crime? Perhaps they should ask the Home Office. Has the Department of Health kept the effects of alcohol on the NHS a closely guarded secret?
The Strategy Unit has set out to reinvent the wheel. A brief look at some of the questions which form the consultation emphasises this:
"Why should the Government get involved in managing the harmful effects of alcohol misuse? At what point does Government intervention become justified?"
If we are still at the stage of asking basic philosophical questions as to the extent of Government intervention, then the strategy will never appear in the lifetime of this parliament.
"How far is alcohol misuse a matter of individual responsibility and when does Government have a responsibility to intervene, whether through services, legislation or persuasion?"
Questions of this nature provide an excellent platform for the drink industry and allied libertarians to distance themselves from any responsibility.
"Reinventing the wheel" may exaggerate the level of development the Strategy Unit has reached when questions such as the following are considered:
"How do you define alcohol misuse? What factors do you take into account?"
Were we not assured otherwise, it would be easy to believe that the sole aim was to delay the appearance of a strategy beyond the Crack of Doom.
"What drinking patterns should an alcohol harm reduction strategy seek to affect? How susceptible are such patterns to change? Where should Government concentrate its efforts in prevention?"
Look, no-one expects the bright boys and girls of the Strategy Unit to be experts on every one of the knotty problems thrown their way after proving too intractable for ordinary mortals, but they might have discovered that there were answers to the most elementary questions.
Here's another one for the drink industry to get its teeth into:
"How do you define harmful drinking? What factors do you take into account in deciding whether heavy drinking has become problematic drinking?"
And, of course, it is important to mention "health benefits."
"How clear is the evidence both for the health costs and the health benefits of alcohol? Are there key pieces of research of which we should be aware? Where are the gaps in the evidence?"
The evidence on both sides has been in the public domain for years. Is the Government, the Department of Health, and the Strategy Unit unaware of this? It is very disturbing that this "back to basics" approach is taking place. What has been happening for the last five years? Is there such a profound ignorance of the subject within the Government? Or do we come back to the conclusion that the industry was simply not being given enough of a say?
When the questions turn to crime and disorder, the likely effects of the new Licensing Bill come to mind. "The most visible effect many of us see from alcohol misuse" , says the preamble to this section of the consultation, "is in our town and city centres: pavements littered with broken bottles and streets too intimidating to pass through. Links between alcohol and disorder are as much a matter for concern as are links between alcohol and crime." This is another curious manifestation of joined up government. The measures which are being enthusiastically promoted by the Department of Fun and the drink industry in the Licensing Bill are precisely those which will lead to an increase in all the unpleasant phenomena listed above. There is a fundamental contradiction between licensing deregulation and the aims of a coherent alcohol strategy.
"What evidence is there about the links between alcohol and crime and the links between alcohol and anti-social behaviour? Are there key studies or pieces of evidence you think we should be aware of?"
The implication, of course is that the Strategy Unit is unaware of any such studies or evidence. Both abound and have been available to the Government for many years.
"To what extent can alcohol convincingly be demonstrated to be a factor in criminal and disorderly behaviour? How much is perception and how much is reality? What fuels the perceptions and are they accurate?"
The industry, abetted by the Portman Group, the body which appears to have the most influence with Government, has long attempted to question the evidence which links alcohol to crime and to disorderly behaviour. This sort of question invites them to renew their attack on the abundant evidence.
"Should we be encouraging different drinking patterns – in terms of time spent drinking, location of drinking etc – in order to tackle alcohol-related crime and disorder?"
Presumably this is a reference of the "Mediterranean style" drinking patterns beloved of the Government and promoted as an aim of licensing deregulation. Ministers may understandably want to recreate the atmosphere of Tuscany in Newcastle or Leicester, but they fail to understand that these patterns are the result of hundreds of years of cultural development, climate, social organisation, and a whole host of intricately related factors far beyond the powers of licensing laws to influence.
"One person's good evening out can be another person's sleepless night. Are there principles to guide the balance of individual rights and responsibilities?"
Yes and they are being ignored in the Licensing Bill.
"Drink-drive policies are generally acknowledged to have been successful. What can we learn from them?"
We can learn that the Government's refusal to lower the limit to 50mgs, contrary to their promise, costs lives.
"Some people may be more vulnerable to the harmful consequences of using alcohol," the document continues. "Certain groups of young people in particular are at higher risk of developing a range of difficulties that include alcohol-related problems (for example children in social care, those excluded from school and youth offenders). Families and carers can play an important role in protecting young people from problems but it is important to recognise that living with a parent or carer with an alcohol problem can itself become a source of vulnerability."
As the authors laboriously enunciate hitherto unrevealled truths. They demonstrate just how new the subject is to them. As one eminent clinician put it, "They are asking questions about which libraries full of books have been written."
In the section called "The shape of the market and market-based solutions", the authors say: "The drinks industry is a major part of the national economy. It provides large numbers of jobs both in supply and distribution; it influences trends and fashion through its advertising; and it provides a substantial portion of tax revenues. Understanding how that market works, what drives it and how it responds to demand is essential to producing an effective strategy."
Is it simply a question of studying how the industry operates? Is there not a question about relating its activities, especially in the promotion of its products to vulnerable groups?
"Do you have any thoughts on the likely evolution of the alcohol industry over the next decade?"
An entire session at the launch of the consultation on the National Alcohol Strategy was given over to this question.
"How far do you foresee research and development creating innovative market-led solutions to the problems of alcohol misuse?"
I should think it as likely as turkeys voting for Christmas.
"How best can Government work with the alcohol industry to reach consumers? What approaches have been shown to be effective in England, the devolved administrations and further afield?"
It is a source of wonder on the continent – where, you will remember, ministers perceive idyllic drinking patterns – that our Government is so hand-in-glove with the industry. But this is the voice of the Portman Group, whose influence was recently deprecated by a major House of Lords committee.
The document does draw attention to the costs of alcohol, pointing out that these are significant "for the economy. It costs the NHS and the police. It costs business money because of lost productivity and in some cases the need to repair alcohol-related damage. And it can be expensive for individuals who drink heavily and may find themselves unable to hold down a job. But it also has benefits. It brings in tax revenue and contributes to GDP. And it contributes to personal and social wellbeing for many. Part of the work on the project will be to form a clear picture of these costs and benefits."
So that's all right then.
One final question asked in the consultation document raises so many questions about the suitability of the Strategy Unit to be carrying out this work:
"Alcohol misuse can increase absenteeism and decrease productivity, whilst moderate consumption of alcohol may be beneficial in terms of reducing stress and tension and facilitating networking in the workplace. What in your view are the links between alcohol use and educational and occupational attainment?"
We actually have an authoritative document, heralded as the "first" step towards a national alcohol policy and so presumably the basis for finding the solution to the many problems associated with alcohol, which advocates and endorses workplace drinking. But perhaps they only had Whitehall in mind.
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How to respond to the consultation: You can send comments to: SU/DoH Consultation Copies of the consultation document can be ordered from: The document is also available in electronic format at: If you have any comments about the consultation process please contact Paul Greening. |