Submission for Government Alcohol Advisory Group January 2008 The Irish College of General Practitioners SUBMISSION TO THE GOVERNMENT ALCOHOL ADVISORY GROUP January, 2008. -1- 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 -2- 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. -3- 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. -4- 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. -5- 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 -6-
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