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The Strategy: after the long wait, humbug and evasion

Liquor-Speak

The long-awaited National Alcohol Harm Reduction Strategy has been found wanting by the Institute of Alcohol Studies. Biased, incoherent and dishonest are some of the terms used to describe a publication which, IAS says, is unworthy of a Government serious about reducing the massive burden of harm related to alcohol. The response points out the fundamental flaw that the document’s language and its thinking are permeated by ‘liquorspeak’ – “the ideas and vocabulary characteristic of alcohol industry statements and initiatives”, and which demonstrate consistent opposition to the findings of authentic scientific research..

The principal aim of liquor-speak is to emphasise the idea that “moderate and social drinking are clearly distinguished from ‘alcohol misuse’; that alcohol-related problems are experienced by only a small minority of miscreants; that there is no linkage between average alcohol consumption in a society and the prevalence of alcoholrelated harm; that policies that restrict alcohol availability are ineffective or counterproductive; that ‘moderate’ drinking is in unqualified terms “good for you”, and that alcohol is not a cause of crime”.

Level of consumption

The IAS’s response states that the “most obvious and also the most telling omission is any proper recognition of the significance of the level of alcohol consumption in the population as a whole.” Although the Strategy makes the statement that present trends indicate that the United Kingdom will, within the next decade, rise to near the top of the consumption league, it fails conspicuously to draw any implication. It might have been hoped that the significance of this possibility would merit attention in a government document designed to deal with alcohol harm reduction.

The IAS points out the contrast between this attitude and “that of most other governments in Europe and elsewhere and also international bodies. For example, the World Bank states:

  • The level of harm from alcohol is related to the pattern, including level, of drinking in a country. Time series analyses in western Europe find that overall mortality rises by 1.3 per cent for every extra liter of pure alcohol consumed per capita. But for Russia, where intoxication and hazardous drinking are more prominent, the corresponding figure is 2.7 per cent.”

As has been stated before in Alert, there is abundant international evidence that “increases in the overall level of consumption are normally accompanied by commensurate increases in prevalence of ‘alcohol misuse’ and in the indices of harm”. The response quotes the example of Ireland where, between the years 1990 and 2002, consumption rose by 41 per cent, an increase accompanied by rises in various types of harm: alcohol poisoning +35 per cent; suicide +23 per cent; cirrhosis +117 per cent; dependence +300 per cent; public order offences +246 per cent; assaults +82 per cent; drink drive offences +114 per cent.

At the same time, reductions in overall consumption are normally accompanied by commensurate reductions in the prevalence of high risk drinking and the indices of harm.

Despite all this the Strategy states that it “recognises that there are both benefits and costs to alcohol use and, therefore, does not aim to cut alcohol consumption by the whole population. Instead, it focuses on the prevention, minimisation and management of the harms caused by alcohol misuse.”

In response the IAS says: “This statement is a non-sequitur. It has never been suggested that the need to control overall consumption is either based upon or implies a denial that there are benefits from alcohol consumption. Contrary to the implication of the statement, there is no good evidence that reducing the overall level of consumption would reduce either economic or health benefits. For example, there appears to be no direct correlation between the population level of consumption and the numbers employed in the alcohol industry. In most circumstances,increases in alcohol taxes increase Government revenue while decreasing the economic burden of alcohol problems. In regard to health, in France substantially lower alcohol consumption has been accompanied by reduced mortality from heart disease.”

Prevention Policies

The response highlights a further major failing, pointing out that the Prime Minister’s comments at the beginning of the Strategy, and indeed the whole document, ignores the ‘prevention paradox’ – the finding that a substantial portion of alcohol problems and the costs associated with them are attributable to people who cannot be described as regular ‘alcohol misusers’. The explanation of the paradox, as has been shown clearly by research, is that, while compared with heavy drinkers, moderate drinkers individually have fewer problems, as there are many more moderate than heavy drinkers in the population they collectively contribute a substantial proportion of the harm. For example, a German study found that about 50 per cent of alcohol-related costs were associated with drinking by people not classified as alcohol dependent or with a diagnosis of alcohol abuse or harmful use.

The idea that the ‘vast majority’ are untouched by alcohol problems not only plays down the fact that alcohol problems are in reality more widely dispersed through the drinking population, it also fails to take into account the effects of alcohol problems on third parties.

According to the IAS, the importance of the Strategy’s rejection of preventative policies, which the research base suggests are likely to succeed in reducing harm, while promoting policies that the research suggests are generally ineffective, cannot be overstressed:

  • “The two key policy choices here concern the price and the legal availability of alcohol. Higher prices of alcohol brought about by increases in tax have been shown to reduce morbidity and mortality from alcohol – related conditions such as liver cirrhosis, the incidence of homicide and other crimes including rape, robbery, assaults, domestic violence and child abuse, and also to reduce drinking and driving and binge drinking. Controls on hours and days of sale of alcohol, numbers of alcohol outlets, and restrictions on access have also been shown to reduce alcohol-related problems”.

On these policies theStrategy states:

  • There is a clear association between price, availability and consumption. But there is less sound evidence for the impact of introducing specific policies in a particular social and political context:
  • our analysis showed that the drivers of consumption are much more complex than merely price and availability;
    • evidence suggested that using price as a key lever risked major unintended side effects;
    • the majority of those who drink do so sensibly the majority of the time. Policies need to be publicly acceptable if they are to succeed; and
    • measures to control price and availability are already built into the system.

“So we believe that a more effective measure would be to provide the industry with further opportunities to work in partnership with the Government to reduce alcohol-related harm.”

The IAS’s response does not mince its words. As far as it is concerned, “this whole section is an exercise in dissembling:

  • “The second sentence of the first statement appears to lack sense. How could the clear association between price, availability and consumption be established except in relation to particular social and political contexts?
  • The second statement is nothing more than a version of the straw man argument – it has never been claimed that price and availability are the only factors involved.
  • In regard to the third statement, theoretically any policy could be implemented ineptly or pressed too far. The argument is not that alcohol problems can simply be taxed out of existence but that without a sensible policy on tax, other preventive strategies will tend to be undermined.
  • The fourth statement is another non sequitur. It is also humbug. The Government has pursued its policy of increasing the availability of alcohol against the wishes of the majority of the population. It has also reneged on its promise to lower the legal alcohol limit for drivers against the wishes of the majority of the population.
  • To the extent that it is true that price and availability controls are already built into the system, this contradicts the implied thrust of all the preceding ones. The last statement offers a false choice. There is no reason why the existence of adequate price and availability controls should preclude partnership between the industry and the Government and, of course, the preceding sentence states that such controls are already built into the system.”

Education

The casual attitude of the Strategy to evidence-based policy is summed up in its comments on education. The Strategy document states: “The first key aim of the strategy is to improve the information available to individuals and to start the process of change in the culture of drinking to get drunk”. The IAS says. “Presumably, the assumption here is that the principal cause of bingeing is ignorance, a proposition for which if there is any evidence in support it is not presented in the strategy document. Nor is there is any real discussion of the significance or implications of the research findings showing that education is of very limited effectiveness in changing actual drinking behaviour.” The drink industry’s enthusiasm for education, which it communicates to Government whenever opportunity arises, may be connected to this ineffectiveness.

Who is responsible for making the strategy happen?

This question is the title of the crucial section of the Strategy. The answer provided is that although the Government – and it is clear from the context that it is the central Government at Westminster that is being referred to - has taken the lead in producing the Strategy, this responsibility is shared with individuals and families and the alcohol industry. There is also a reference to the important role of ‘communities’ in ‘taking ownership of, and enforcing, social norms.’

The response comments: “This perfunctory reference to ill-defined ‘communities’ cannot, however, disguise the fact that the crucial role of civil society in preventing alcoholrelated harm is being almost completely disregarded. It is inconceivable that any effective movement to reduce the harm related to alcohol could occur without the active support and participation of a range of civil society organisations concerned with the main institutional sectors of society such as recreation, transport or the media, or with important social groupings within it, for example, youth organisations, womens’ organisations, family organisations, faith communities. Not one of them gets a mention in the Strategy document. Most bizarrely of all, the table listing the rights and responsibilities of the main actors involved in alcohol policy also omits local authorities, even though the Strategy is complementary to the Licensing Act 2003 which transfers to local authorities the responsibility for alcohol licensing. Also lacking is any reference to the extensive and rapidly growing network of residents’ and amenity societies concerned with the quality of life in town and city centres and which are necessarily heavily engaged in the alcohol, crime and disorder issues which are central to the Strategy’s concerns. For example, the National Organisation of Residents’ Associations in a mere eighteen months of existence has achieved 30 member organisations with a total of over 100,000 individual members.

The IAS response, which highlights the failings, disappointments, and contradictions of the Strategy, concludes on this vital theme of communal involvement in the problem of alcohol harm reduction, especially as regards the effects of the closely related new Licensing Act, which bizarrely appeared before the Strategy:

“The Government’s ambivalence – to put it no higher – towards civil society’s involvement in this area is one of the most important issues to have arisen in the context of the new Licensing Act. The original White Paper, Time for Reform, gave three ‘compelling reasons’ for transferring responsibility for alcohol licensing from the magistrates to local authorities – accountability to local residents; accessibility and the leading role of local authorities in preventing local crime and disorder, much of which is linked to the supply of alcohol. Yet one of the main purposes of the Act is precisely to place severe constraints on both the individual citizen and the local authorities in regard to what actions they are allowed to take in respect of licensed premises. For example, the Act restricts which residents are allowed to make representations about licensing decisions on the basis of where they live, with the result that many people who are profoundly affected by the decisions taken by their local authority will not have the right to make representations. The Ministerial Guidance that accompanies the Act is designed primarily to reduce the discretion of local licensing authorities, and to tell them what they are not allowed to do. For example, the Guidance makes it clear that the new licensing authorities will be expected to increase drinking hours substantially, irrespective of the wishes of the people who elect them. It is of note here that the Government repeatedly denied all requests that residents’ associations be represented on the Advisory Group established by the Department of Culture, Media and Sport to advise on the preparation of the new legislation. The bulk of the membership of this Group was of course provided by the alcohol industry, and a number of the meetings took place at the headquarters of the British Beer and Pub Association.”

Say no more.

The full response is available on the IAS web site or in hard copy from IAS, Elmgren House, 1 The Quay, St. Ives, Cambridgeshire, PE27 5AR