SUBMISSION TO THE DEPARTMENT OF JUSTICE, EQUALITY

Submission for Government Alcohol Advisory Group
January 2008
The Irish College of General Practitioners
SUBMISSION TO THE GOVERNMENT
ALCOHOL ADVISORY GROUP
January, 2008.
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Submission for Government Alcohol Advisory Group
January 2008
Table of Contents
1
Introduction
3
2
Policy Context
4
3
Policies that have proven efficacy
4
4
Conclusions
5
5
References
6
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Submission for Government Alcohol Advisory Group
January 2008
1.
Introduction
1.1
The Irish College of General Practitioners welcomes the opportunity to
make a submission to the Government Alcohol Advisory Group,
established by the Minister for Justice, Equality and Law Reform. We
wish the group success in implementing policy that will serve to protect
the health and well-being of the general public.
The establishment of this Group is timely and appropriate because of:

The alarming and further evidence of widespread alcohol related
consequences on health, family and community life including violent
attacks that are drug and alcohol fuelled 1.

The numerous surveys and reports that place Ireland in the unenviable
position of near the top of international scales for alcohol-related harm
and consumption; the worrying trends in relation to alcohol and drug use
particularly by young people 2 ; the binge drinking culture needs to be
addressed urgently.

The tragic deaths and serious injuries that have occurred from
alcohol/drug use as a result of road traffic accidents, attempted suicide
and suicide 3.

The financial and human resource impact of alcohol related problems on
the already over-stretched medical services in general and ‘Accident and
Emergency’ departments in particular 3.

The absence of Government led initiatives and campaigns to reduce the
harm associated with alcohol. Such an absence has led to a vacuum into
which vested interests, including the Drinks Industry in various forms,
can exploit. As a result, we now have the situation where vested interests
are actually taking a lead in ‘Health Promotion’.

The fact that no one Government department has overall responsibility for
alcohol policy. Though this Group is welcomed, it is regrettable that its
scope is so narrow. Piecemeal efforts to sort out our drinking culture are
unlikely to succeed and we strongly call for ‘joined-up’ thinking and the
responsibility of a single government department to specifically deal with
policy on alcohol and drugs.

The widespread reports from GPs of increased physical, social and
psychological harm among patients and their families as a result of
hazardous and harmful use of alcohol and other drugs 4.
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Submission for Government Alcohol Advisory Group
January 2008
2.
Policy Context
2.1.
The Irish College of General Practitioners urges the Advisory Group to
implement necessary change based on the submissions, previous reports
and discussion. Considerable cynicism has accumulated as a result of the
fact that the Government’s own Strategic Task Force on Alcohol (STFA)
report set up by the Department of Health and Children and reported in
20043 has visited all these issues and has already made clear
recommendations many of which have not been implemented. The task
force report should be adopted and implemented in full.
2.2.
The fact that alcohol is a gateway drug and is increasingly used with other
drugs of addiction makes addressing these matters more urgent.
3.
Policies that have proven efficacy
3.1
Under Section 5 of the STFA report, 10 areas are explored to reduce per
capita consumption as follows;










3.2
Regulate availability
Control promotion of alcohol
Enhance society’s capacity to respond to alcohol related harm
Protect public, private and working environments
Responsibility of the alcohol beverage industry
Provide information and education
Put in place effective treatment services
Support non-governmental organisations
Research
Monitor progress and Drink Driving
The specific recommendations in the STFA Report relevant to this
Advisory Group are as follows;


Increase excise duty,
Restrict further increase in the availability of alcohol (number of
outlets, time of sales).
This approach is based on a clear evidence base5,6. The WHO 5 has found
that increasing the price of alcohol is the most effective way of reducing
consumption. The Drinks Industry try to counter this approach but this is
not supported by evidence or even the basic marketing concepts of focus
on product, price, promotion and place7. The ICGP support these
recommendations and would go further and say that that low cost selling
and availability of alcohol in supermarkets, petrol stations etc should be
banned. Enforcement is key to such a policy being successful 8.
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Submission for Government Alcohol Advisory Group
January 2008
3.3
The ICGP would call on the Advisory Group to support a ban on the
advertising of alcohol products in all sections of the media. Evidence
suggests that an outright ban reduces alcohol consumption and alcohol
related harm 8.
3.4
We would welcome limitations being put on special exemption orders and
greater sanctions if conditions imposed in relation to such exemptions are
ignored.
3.5
The Group should consider raising the legal age relating to the sale of
alcohol to 21 years, but also enforce absolutely the current legal age of 18
years.
3.6
Legal sanctions involving significant fines and possible closure for
recidivism in relation to special promotions such as ‘buy 12 get 1 free’ or
‘drink all you like for ---‘ in retail outlets and licensed premises should be
introduced. The industry should not be allowed to self-regulate such
matters 8.
3.7
The group should recommend that the cost of non-alcoholic soft drinks be
reduced to encourage consumer choice based on price. The public often
comment that there is no price incentive to reduce alcohol consumption.
4.
Conclusions
Any genuine attempt to reduce alcohol related harm and per capita consumption
is welcomed. It is hoped that the Advisory Group will adopt the necessary
measures that are of proven efficacy world-wide. The number of outlets that are
allowed sell alcohol and to sell at low cost should be reduced and low cost
alcohol sales as well as promotions should be proscribed. Such measures will
make a significant difference to the suffering that results from alcohol related
harm.
Although probably outside the remit of the Advisory Group the issue of alcohol
advertising and promotion must be addressed. At the very least, the source and
funding of alcohol advertising and promotion should be fully transparent to the
public, including drink aware advertisements and websites.
This is an important area for the Department of Justice to consider as public
support is essential to ensure that any changes in legislation are understood and
accepted.
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Submission for Government Alcohol Advisory Group
January 2008
References:
1. Mongan D, Reynolds S, Fanagan S, and Long J. Health related
consequences of problem alcohol use. Dublin: Health Research Board;
2007.
2. Hibell B, Andersson B, Bjarnason T, Ahlström S, Balakireva O, Kokkevi A,
Morgan M. ESPAD Report 2003: Alcohol and Other Drug Use Among
Students in 35 European Countries. Swedish Council for Information on
Alcohol and Other Drugs, CAN; Council of Europe, Co-operation Group
to Combat Drug Abuse and Illicit Trafficking in Drugs (Pompidou Group);
2004.
3. Department of Health and Children. Strategic Task Force on Alcohol:
Second Report. Dublin: Government Publications; 2004.
4. Anderson R, Collins C, Dalton Y, Doran G, and Boland M. Alcohol Aware
Practice Service Initiative: Final Report. Dublin: Irish College of General
Practitioners; 2006.
5. Chisholm D, Rehm J, Van OM, Monteiro M. Reducing the global burden of
hazardous alcohol use: a comparative cost effectiveness analysis. J Stud
Alcohol. 2004; 65: 782-793.
6. Anderson P, Baumberg B. Alcohol in Europe: a public health perspective.
EU Health and Consumer Protection Directorate General; 2007.
7. Gilmore I, Sheron N. Reducing the harm of alcohol in the UK. BMJ. 2007;
335: 1271-1272.
8. Babor T et al. Alcohol: No Ordinary Commodity: research and public
policy. Oxford: Oxford University Press; 2003.
Prepared by:
Rolande Anderson, Director, ICGP Alcohol Aware Programme
and The ICGP Executive Committee
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