Aneurin Bevan University Hospital Board

Response to the Health, Social Care and Sport Committee on the Public Health (Minimum price for Alcohol) (Wales) Bill

 

1.   Introduction

 

Aneurin Bevan University Health Board (ABUHB) welcomes the opportunity to respond to the Health, Social Care and Sport Committee consultation on the Public Health (Minimum Price for Alcohol) (Wales) Bill.

 

ABUHB strongly support the implementation of the minimum unit pricing for alcohol in Wales and have articulated the same opinion in previous consultation submissions, which include a comprehensive response to the Public Health (Wales) Bill in 2015.  ABUHB’s position supporting the implementation of MUP in 2015 has been strengthened by further evidence which has since been published, and highlighted below.

 

As outlined in ABUHB’s submission in 2015:

 

·         There is evidence that excessive alcohol consumption significantly increases short and long term harms to health.  Evidence indicates that increased consumption is linked to increased harm: there is a dose-harm response[1].  The UK Chief Medical Officers report reinforced this, concluding that the risk of developing health problems increases with the amount of alcohol consumed on a regular basis[2].

 

·         There is clear evidence linking the affordability of alcohol with the quantity of alcohol consumed (and thus resultant alcohol harms).  More than 100 international studies clearly demonstrates a link between the affordability of alcohol and alcohol consumption[3]. Alcohol has become steadily more affordable in recent years, with there being a real term reduction in the cost of alcohol[4].

 

·         There is strong evidence to support decreasing the affordability of alcohol to reduce consumption and thus reduce harm from alcohol[5]. When the price of alcohol increases consumption by most drinkers reduces including, critically, consumption by hazardous and harmful drinkers[6]. When alcohol consumption in the population declines, rates of alcohol related harms also decline[7]. The intervention for increasing affordability with the strongest evidence is Minimum Unit Pricing (MUP) of alcohol[8].

 

In conclusion robust evidence indicates that:

 

(i)                  alcohol consumption levels are linked with levels of harm

(ii)                 affordability is one of the key drivers of alcohol consumption, and

(iii)                MUP is the most effective price mechanism to reduce the affordability of alcohol

 

Since the ABUHB consultation submission in 2015 there has been additional published evidence which provides further insight into the harms caused by alcohol.  This includes an extremely comprehensive review of the evidence of the health harms associated with alcohol consumption resulting in new low risk drinking guidelines published in 2016: the UK Chief Medical Officers’ Low Risk Drinking Guidelines, published in 2016.  Other reports which ABUHB considered are: Public Health Wales (2015) ‘Adverse Childhood Experiences and their impact on health-harming behaviour in the Welsh adult population’, Alcohol Health Alliance (2016) ‘Cheap Alcohol, the Price We Pay’.

 

 

 

2.1 Terms of Reference

 

The general principles of the Public Health (Minimum Price for Alcohol) (Wales) Bill and the extent to which it will contributed to improving and protecting the health and well-being of the population of Wales, by providing for a minimum price for the sale and supply of alcohol in Wales and making it an offence for alcohol to be sold or supplied below that price.

 

ABUHB support the general principles of the Public Health (Minimum Price for Alcohol) (Wales) Bill after considering the following evidence:    

 

 

Alcohol consumption linked to affordability

 

Evidence indicates that recent decades have seen increases in alcohol consumption and health harms associated with alcohol consumption in Wales. These increases in consumption and harms are associated with real terms reductions in the cost of alcohol (alcohol being more affordable).  Introducing a MUP for alcohol would be a targeted measure of increasing the price (and therefore reducing affordability) of alcohol.  This approach would target those at greatest risk of harm from their drinking: heaviest drinkers and those at particular risk from alcohol related harm such as young people.

 

There is strong evidence that alcohol affordability is one of the main determinants of alcohol consumption and resultant level of alcohol harms. More than 100 international studies clearly demonstrate a link between the affordability of alcohol and alcohol consumption[9]. There is overwhelming evidence to support policies which reduce affordability[10].

MUP is based on two fundamental principles:

1.   When the price of alcohol increases, consumption, especially by the heaviest drinkers, goes down, and:

2.   When alcohol consumption in the population declines, the rates of alcohol related harms decline[11].

 

Health harms from alcohol consumption

 

Drinking alcohol increases the risk of developing over 60 different health problems[12] as well as increasing the risk of causing a range of harms to others[13].  Worldwide, the harmful use of alcohol ranks amongst the top five risk factors for disease, disability and death[14]. Recent decades have seen increases in alcohol consumption and associated health harms across Wales[15]. These harms are preventable.  Alcohol misuse is detrimental, not only to the drinker, but also in the harm to their family and local community.  Alcohol misuse places an avoidable burden on public services. The estimated to cost the Welsh nation is £1 billion per year[16] (Alcohol Concern Cymru, 2013), with the cost to the NHS in Wales for alcohol related hospital admission in 2012-13 being £109m alone[17].

The anticipated benefits of MUP: the modelling

The OECD report[18] stated that “approximately four in five drinkers would decrease their risk of death by cutting their alcohol intake by just one unit per week”.  A model-based appraisal of MUP in Wales conducted by the Sheffield Alcohol Research Group for a MUP of 50p estimated that there would be a reduction in alcohol consumption for the overall population per person of 4% (30 units per drinker per year).

The Sheffield Alcohol Research Group, Sheffield University, applied the Sheffield Alcohol Policy Model (SAPM) in Wales and estimated that a 50p MUP would result in:

·         53 fewer deaths a year

·         1,400 fewer hospital admissions a year

·         3,684 fewer criminal offences a year

·         10,000 fewer absent days from work a year from heavy drinking

The SAPM indicates savings of £131 million over 20 years relating to direct costs to healthcare services over 20 years. The authors concluded that the societal value of these impacts totals £882 million over the 20 year period. This figure includes savings from healthcare costs, reduced crime and policing, reduced workplace