This survey forms part of the stakeholder consultation process on minimum pricing of alcohol in Northern Ireland and provided an opportunity for comment on plans to crack down on the availability of cheap alcohol.
A number of key questions on the introduction of pricing interventions which which are intended to tackle problems associated with the availability of cheap alcohol in Northern Ireland have been developed.
These include questions on:
- the introduction of a minimum price per unit of alcohol;
- banning or below-cost selling of alcohol;
- banning sale of alcohol below level of Duty and VAT; and
- increasing taxation to address the harms of problem drinking.
A number of key questions in relation to a proposal to introduce a social responsibility levy have also been identified.
The Department of Social Development was keen to hear views on the proposals from everyone including consumers of alcohol, trade associations, criminal justice workers or those who run or work in pubs, clubs, supermarkets or other outlets selling alcohol.
COMMENTS ON DEPARTMENT OF SOCIAL DEVELOPMENT
MINIMUM UNIT PRICING OF ALCOHOL
The Royal College of Physicians of Edinburgh (RCPE) welcomes the opportunity to respond to this consultation on behalf of our Fellows and Members in Northern Ireland. Scotland has very similar challenges with regard to excessive consumption of alcohol, and the College is a founding member of the Scottish Heath Action on Alcohol Problems (SHAAP) which aims to influence public health policy through raising awareness of the dangers of excessive consumption. SHAAP has been at the forefront of College efforts to achieve legislation on minimum pricing in Scotland. Further information on the work of SHAAP is available at http://www.shaap.org.uk/.
The level of alcohol related harm is directly linked to the level of per-capita consumption, and one means of reducing this harm is to make alcohol less affordable. This College and SHAAP support the conclusions of this consultation. The arguments adopted parallel those advanced by RCPE and SHAAP in advocating a minimum pricing as part of the Alcohol Bill in Scotland. More detailed discussion of minimum pricing is available in the SHAAP publication “Getting the Price of alcohol Right” (October 2010).
Comments on the consultation questions follow:
To what extent would you agree with the introduction of minimum pricing per unit of alcohol into Northern Ireland?'
The College supports the call in Scotland for minimum pricing and believes this could have a similar positive impact in Northern Ireland.
To what extent do you agree with the proposed principles on which a minimum pricing scheme for alcohol products may be established?
The College agrees that these are sensible principles for a minimum pricing scheme.
To what extent would you agree with the banning of below cost sales in Northern Ireland?
The College believes that, from a health perspective, the benefit would be limited or absent, and understands that a ban would also bring significant implementation difficulties.
To what extent would you agree with a ban on the sale of alcohol below the rate of duty plus VAT in Northern Ireland?
See above - the health benefit would be limited and this measure would be ineffective in isolation. However, the principle of controlling inappropriately low sales prices is to be supported.
To what extent would you agree that increasing taxation (a matter for UK Government and not the Northern Ireland Assembly) should be used to address the harms of problem drinking?
The College believes that increasing taxation, although attractive in terms of revenue to the exchequer (rather than increased industry profits), is a blunt instrument if used in isolation; it increases prices across the board rather than targeting inappropriately cheap brands. Also, there is no guarantee that increases in taxation will flow through to retail prices. Taxation increases used with a minimum pricing policy will be more effective at limiting consumption for those at risk.
To what extent would you agree with the introduction of a social responsibility levy in Northern Ireland?
The imposition of a social responsibility levy to offset some of the costs of alcohol related damage in the community is a commendable aim which probably requires further research and consultation before it can be implemented in an equitable and effective way.