Dec 11, 2015 - ... Researcher. Phone: 020 7832 6920 ... Of all alcohol sold, very cheap products play the biggest part i
UK Health Forum Response to Welsh Government Consultation on Draft Public Health (Minimum Price for Alcohol) (Wales) Bill Date: 11 December 2015
Contact: Hannah Graff, Senior Policy Researcher Phone: 020 7832 6920
About the UK Health Forum The UK Health Forum (UKHF), a registered charity, is both a UK forum and an international centre for the prevention of non-communicable diseases (NCDs) including coronary heart disease, stroke, cancer, diabetes, chronic kidney disease and dementia through a focus on up-stream measures targeted at the four shared modifiable risk factors of poor nutrition, physical inactivity, tobacco use and alcohol misuse. UKHF undertakes policy research and advocacy to support action by government, the public sector and commercial operators. As an alliance, the UKHF is uniquely placed to develop and promote consensus-based healthy public policy and to coordinate public health advocacy. UKHF is a member of the UK Alcohol Health Alliance.
Statement of Support UKHF strongly supports the introduction of a minimum unit price for alcohol at the suggested initial level of 50p/unit. We strongly support the introduction of a minimum unit price (MUP) for alcohol. The suggested level of 50p/unit for all alcohol sold in Wales would be in alignment with Scotland’s adoption of the policy. Canada has implemented MUP and has already seen an 8% reduction in consumption and a 9% reduction in hospital admissions attributable to alcohol.1 Wales needs comprehensive national policies which reflect the collective recommendations made in Health First: an evidence based alcohol strategy for the UK.2 Public health and public safety need be given priority in public policy making above the influence of the alcohol industry. In addition, we would also encourage Wales to introduce – where able – strict controls on alcohol advertising, promotion and sponsorship (including sports sponsorship) – specifically marketing targeted at or likely to appeal to and impact on children and young people. A comprehensive review of licensing legislation and powers in Wales with the aim of empowering local licensing authorities to tackle alcohol-related health harm by controlling the total availability of alcohol needs to be conducted. Similar research on local powers has been conducted for England.3 UKHF has responded to Questions 1-6 given our remit and expertise on this issue.
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Stockwell, T. 2013. Is alcohol too cheap in the UK? The case for setting a Minimum Unit Price for alcohol. British Columbia. Health First: an evidence-based alcohol strategy for the UK. University of Stirling. March 2013. 3 Martineau, F. P., Graff, H., Mitchell, C. and Lock, K. 2013. “Responsibility without legal authority? Tackling alcoholrelated health harms through licensing and planning policy in local government”. Journal of Public Health. Faculty of Public Health. 2
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Consultation Questions Question 1. What do you think of the proposal to introduce legislation that would introduce a minimum unit price for alcohol in Wales? (i) Do you think this proposed legislation will help strengthen the existing actions being undertaken by the Welsh Government to reduce alcohol consumption and alcohol related harm? Yes. The UKHF strongly supports the introduction of a minimum unit price in Wales as part of the Welsh’s Governments proactive strategy to address alcohol misuse issues and increase awareness of the health harms caused by alcohol. The Welsh Government has publically stated its support for many evidence –based, legislative changes advocated by UKHF and the Alcohol Health Alliance, including the introduction of a fifth licensing objective around the protection of public health and lowering the current drink drive limit. However it is clear, that given many of the issues are currently non-devolved, the single most powerful tool that the Welsh Government has to reduce the burden of alcohol-related harm in Wales is the introduction of a 50p per unit minimum price, which will cut crime and save lives.
Question 2. What is your view on the evidence presented within the Explanatory Memorandum? While overall alcohol consumption has declined in the last few years, in the UK we are still drinking over 40% more litres per head of population than we were in 1970.4 Alcohol is currently 61% more affordable than it was in 1980. This increased affordability is reflected by increased levels of consumption and alcohol related harms. The majority of alcohol is now sold in supermarkets and off licenses, where it is routinely offered at lower costs to entice people into stores5 – a can of super strength white cider, such as Frosty Jack’s, can currently be sold for about 16p. Of all alcohol sold, very cheap products play the biggest part in driving alcohol-related harm.6 According to the Welsh Health Survey 2014, 40% of adults in Wales said that they drank more than the recommended guidelines on at least one day in the past week, putting their health at unnecessary risk, and meaning that alcohol misuse is not a marginal problem. The true figures are likely to be even higher, as the remaining 58% who drank within the guidelines included all abstaining adults; removal of the 13% of teetotallers would reveal a higher percentage of overconsumption amongst drinkers. Moreover, in surveys of alcohol consumption, respondents regularly underestimate their own drinking. In 2009, researchers at Liverpool John Moores University estimated that the difference between self-reported consumption and actual alcohol sales in the UK was equivalent to one bottle of wine per adult per week, or two million bottles of
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British Beer and Pub Association (2013) Statistical Handbook 2013, London, BBPA. Bennetts R. IAS Briefing Paper: Use of Alcohol As A Loss-Leader. Institute of Alcohol Studies; 2014. 6 Bennetts R. 2014, Ibid 5
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wine each week in Wales.7 Numerous studies have shown that the price of alcohol, and more particularly its price relative to income, is one of the main factors in determining levels of consumption. Question 3. Considering the evidence in the Explanatory Memorandum, what are your views on the likely impacts including, the costs and benefits that introducing a MUP for alcohol might have on: (a) consumers; 80% of alcohol purchases are made by 30% of the population, and this is the group who are the main beneficiaries of discounted alcohol and therefore targeted by MUP to change their drinking behaviour. For those drinking within recommended guidelines, MUP will have little impact financially and moderate drinkers across all income groups would spend just 78p more on alcoholic drinks per year. As lower income households disproportionately suffer the harms of alcohol, they would see the most benefits as a result. University of Sheffield data suggests that routine and manual worker households would account for over 80% of the reduction in deaths and hospital admissions brought about by MUP and yet the consumption of moderate drinkers in low income groups would only drop by the equivalent of 2 pints of beer a year. (b) retailers; and (c) drinks manufacturers; Whether MUP will produce a ‘windfall’ for the supermarkets is unknown - there is a reasonable chance that, if overall consumption falls as a consequence of the introduction of MUP, this might impact on their sales, either on alcohol directly and/or more generally (as alcohol promotions are often used as a device to attract potential consumers into their stores to purchase additional, nonalcoholic products). This might explain leading supermarkets’ opposition to MUP. Conversely, if MUP does significantly increase retailer profits, then the Welsh Government should consider how these monies might be redirected to provide assistance to those affected by alcohol problems. Not all drinks producers and retailers in Wales are against MUP. The National Federation of Retail Newsagents has publically stated that MUP in Wales “would be a step in the right direction” for alcohol policy. Studies estimate that MUP would yield increased profits for off-premise retailers. This might be seen as an additional benefit of MUP – the on-premise trade in the UK has suffered in recent times losing considerable custom by virtue of the current system that allows large supermarket chains to sell very cheap alcohol for off premise consumption. (d) those who buy or sell using online or telephone delivery services; For online retailers or telephone delivery services whose main business relies on the sale of cheap, strong alcohol, MUP may have an adverse impact. However, MUP will not prevent such retailers from introducing or selling higher strength products, merely that they will not be able to sell them below a certain price. (e) local authorities; As noted in the Explanatory Memorandum, local authorities will be required to ensure the new law is implemented and action taken against businesses not complying. This, in our view, is a reasonable requirement and fits with licensing bodies’ current remit concerning the responsible and lawful sale of alcohol. The introduction of MUP will help local authorities make progress in their ambitions to 7
Liverpool John Moore’s University (2009) Off measure: How we underestimate the amount we drink, London, Alcohol Concern.
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create healthier, vibrant communities as well as a safer, more inclusive night-time economy which is not dominated by alcohol. (f) the health service in Wales; and Every single hour a person in the UK dies from alcohol.8 Alcohol is placing an enormous strain on our health service. A steady increase in alcohol-related hospital admissions in Wales over the last 10 years has put frontline health workers in particular under increasing pressure. The introduction of MUP in Wales will facilitate changes to harmful drinking behaviours, meaning fewer individuals will require hospital treatment as a consequence of their drinking. As outlined in the Explanatory Memorandum, a minimum unit price of 50p will provide savings to the NHS of £130 million over the 20 years. (g) other groups; including other public services in Wales? Alcohol does not just harm the individual drinker; it all too often affects innocent bystanders, through its role in child abuse and neglect, domestic violence, family breakdown and crime and disorder. A reduction in alcohol harms as a result of MUP will benefit the police, criminal justice system and fire services. Currently, up to 80% of weekend arrests are alcohol-related, and 53% of police officers’ workload is related to alcohol. Fire and rescue teams also reportedly spend one in five hours dealing with the consequences of drinking. Modeling data produced in July 2013 by the University of Sheffield Alcohol Research Group forecasted that a 50p minimum unit price implemented in England would lead to 50,700 fewer crimes in year 1, and a total cost reduction to health, crime and workplace absence of £5.1bn in the first 10 years.9 Furthermore, a 10% increase in minimum alcohol prices in Canada was associated with a 9.17% reduction in crimes against the person.
Question 4. Considering the evidence in the Explanatory memorandum, Equalities Impact assessment and the Welsh Language impact assessment, what are your views on the likely impact including the costs and benefits of introducing a MUP for alcohol in Wales on people on low incomes? It is the heavier drinkers in society that favour the cheapest alcohol on the market, typically found in the off-trade, which is targeted by MUP. This is the case irrespective of income. Recent research led by Nick Sheron at the University of Southampton examining the impact of MUP on patients with liver disease has found that even wealthy patients with alcoholic cirrhosis buy the cheapest alcohol available. At all income levels, the spending of those drinking within recommended guidelines will be minimal. Due to existing health inequalities, the harshest effects of alcohol are felt most by those who can least afford it. Even though as a group they don’t consume as much alcohol as more affluent groups, people in the most deprived areas of the country are disproportionately more likely to experience the impacts of alcohol-related crime, are more likely to suffer the impacts of alcohol-related health conditions, and are more likely to die from an alcohol-caused condition.10 Heavy consumers from low income groups stand to gain the most from MUP. 8
ONS, Alcohol-related deaths in the United Kingdom, registered in 2012 - ONS. 2014. Available at: http://www.ons.gov.uk/ons/rel/subnational-health4/alcohol-related-deaths-in-the-united-kingdom/2012/stb---alcoholrelated-deaths-in-the-united-kingdom--registered-in-2012.html. Accessed June 19, 2014. 9 Yang, M., Brennan, A., Holmes, J. et al (2013), op cit 10 North West Public Health Observatory, Centre for Public Health, Liverpool John Moores University. New Local Alcohol Profiles for England reveal the poorest suffer the greatest health harms from booze culture.; 2012.
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Question 5. What effects do you think MUP for alcohol would have on children and young people in Wales generally? The ScHARR modelling also suggests that MUP will reduce the consumption of 11-18 year old drinkers. Legally, children and young people are not able to purchase alcohol, but in reality this group can and does get hold of alcohol, and raising the price of cheap alcohol is one means to protect this group from harm. Previous research from Alcohol Concern and Balance NE has found nearly two-thirds (63%) of 16-24 year olds though that cheap alcohol price promotions encouraged them to drink more than they normally would. Many also said they found it cheaper to drink than to participate in other social activities, such as going to the cinema. In Britain, 2.6 million children live with a hazardous drinker- that’s one in five children- of which 705,000 live with a dependent drinker.11 Problem-drinking can affect all aspects of family functioning and is strongly correlated with conflicts, disputes and domestic violence that consequently has a damaging effect on children. Research indicates that children tend to become aware from an early age of parental alcohol misuse, despite perhaps not fully understanding it. MUP will positively impact on this group by moderating the drinking behaviours of their parents or carers.
Question 6. Do you agree the Welsh Government should review the initial level of minimum unit price (i.e.50p) to maintain its effectiveness? If so, how frequently? Yes. A minimum unit price will only be effective if it is regularly reviewed and updated to take into account the impact of inflation and rising incomes. While 50p is a reasonable starting point, delays in implementation continue to erode the effect of this level, and the original work of Sheffield University showing a marked impact (nearly 3000 lives a year saved) were modelled on 2007-8 prices. A minimum unit price of 50p would now need to be valued nearer 55p. It is essential that MUP should be subject to a regular and vigorous independent review to ensure that its impact does not diminish over time. We would also ask the Welsh Government to explore a mechanism for channelling any extra money received from MUP by retailers into reducing harms of alcohol at a both a local and Wales-wide level.
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Manning, V. et. al. (2009) New estimates on the number of children living with substance-misusing parents: Results from UK national household surveys. Journal of Public Health, 9 (1),pp377-389.
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