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EXECUTIVE SUMMARY
Background and Introduction
1. In June 2008 the Scottish Government published a discussion paper setting out its strategic approach to tackling alcohol misuse: ' Changing Scotland's Relationship with Alcohol: A Discussion Paper on Our Strategic Approach'. 1 The discussion paper set out key actions already underway; existing commitments for action; and new proposals on which views were sought. It set out ten questions within the context of seven themes:
- further action to end irresponsible promotion and below-cost selling of alcoholic drinks in licensed premises;
- the introduction of minimum retail pricing of alcohol;
- what particular information parents would find helpful in relation to alcohol;
- raising the minimum age for off-sales purchases to 21;
- the introduction of a 'social responsibility fee' applied to some alcohol retailers to offset the costs of dealing with the consequences of alcohol misuse;
- further restrictions on promotional material in licensed premises; and,
- the desirability of separate checkouts for alcohol sales.
2. The consultation on the discussion paper ran from 17 th June to 9 th September 2008. Hexagon Research and Consulting was commissioned by the Scottish Government to undertake an independent analysis of written responses to the discussion paper.
Analysis of Respondents
3. A total of 472 written responses to the discussion paper were submitted to the Scottish Government. This included 259 responses from individuals, 207 responses from organisations and six combined or group responses. In addition, Scottish Government Ministers received 53 letters or emails on issues relating to the discussion paper from members of the public.
4. The 207 organisations that submitted responses were broken down into 26 groups. All organisational responses have been considered in the analysis but in order to provide comparative information about the views of key sectors, three main groupings of organisations were identified:
- Health promotion and addictions groups (62) - including 20 Alcohol and Drugs Addictions Teams, 19 addictions and lifestyle groups, eight NHS Boards, 11 professional bodies / Royal Colleges;
- Trade and business sector organisations (58) - including 17 small retailers, nine large retailers, six retail associations, 13 producers, and 10 miscellaneous trade and business organisations; and,
- Local Government and related bodies (41) - including 13 Councils, COSLA, 10 Licensing Boards, six Licensing Forums, four professional associations and three Community Councils.
5. In addition, responses were received from 46 'other' organisations, including national agencies and forums, youth organisations, voluntary groups and charities.
Key Findings
Ending irresponsible promotion and below-cost selling of alcohol
6. Most individual respondents commented on the principle of ending irresponsible promotions and below-cost selling rather than on the specific measures outlined in the discussion paper. A majority of individual respondents who expressed a view were in favour of the principle of ending irresponsible promotions and below-cost selling (43%) or expressed support for at least one of the measures included in the discussion paper (11%), whilst a significant minority (38%) expressed opposition to these proposals.
7. Overall, two thirds of organisations (66%) that responded to this question supported the principle of restricting promotions and preventing the sale of alcohol as a loss-leader or supported all three of the measures presented in the question. A further 7% expressed support for at least one of the measures. Just under one in five organisations (19%) were opposed to these proposals. Respondents from the health and local government sectors were overwhelmingly in favour (93% and 82% respectively supported the proposals in principle or all three measures), but a majority (56%) of alcohol trade and business organisations were opposed.
8. Amongst both individuals and organisations that commented on the details there was more support for the proposal to end below-cost selling than for restricting promotions.
Minimum retail pricing
9. Although the discussion paper asked respondents to comment on the principles on which a minimum retail pricing scheme for alcohol should be based, most respondents commented on whether a scheme should be established. There was no consensus amongst individual respondents with 49% in favour of introducing minimum retail pricing and 43% against. Two thirds (65%) of organisations were in favour, while just under a quarter (23%) were opposed. However, 90% of health organisations were supportive of establishing minimum retail pricing, as were 84% of local government bodies, whilst 61% of trade and business sector organisations were opposed.
10. Most of the organisations that supported minimum retail pricing for alcohol did not comment on the proposed principles on which a scheme should be based outlined in the discussion paper but the majority of those that did suggested that minimum prices should be based on alcoholic strength and should apply across both off and on-sales. Those respondents in favour of the proposals supported the rationale put forward in the discussion paper, e.g. that the increasing affordability of alcohol is one of the main drivers in higher consumption and harm. Reasons given by those who expressed opposition to minimum retail pricing included minimum pricing being perceived as a form of taxation, opposition to the Government setting prices and to the likely impact of increasing the price of alcohol on 'responsible' drinkers and people on low incomes.
What information would parents find helpful in relation to alcohol?
11. One third of individual respondents who answered this question suggested that parents generally need more information and statistics about the harmful effects of alcohol misuse and / or the recommended guidelines for alcohol. The next most common suggestion was that parents should set a good example to children by drinking sensibly and not misusing alcohol and / or that there should be a cultural shift promoting sensible drinking. The third most frequent suggestion was that there should be more effective education about alcohol and its potentially harmful effects as part of the school curriculum, possibly using peer education or broader 'lifestyle' education.
12. These three broad areas were also the most common suggestions made by organisations, several of which made detailed and significant contributions to this part of the consultation, including Learning and Teaching Scotland, the Association of Directors of Social Work, Royal Colleges and several trade sector bodies.
Raising the minimum legal age for off-sales purchases to 21
13. A clear majority of individual respondents (62%) expressed opposition to the proposal to raise the minimum legal age for off-sales purchases to 21. This proposal was also opposed by a large majority (63%) of the organisations that responded to this question. The health sector was the only sector with a majority of respondents in favour (52% in favour; 36% opposed). All nine youth organisations that responded to the discussion paper expressed strong opposition.
14. The most common reasons given by respondents for opposing this proposal included that it 'demonises' all young people, not just those who drink irresponsibly and cause problems, that the minimum legal age for most things is either 16 or 18, that it represents an erosion of civil liberties for young people, and that the emphasis should be on enforcing current laws and using proof of age schemes to reduce 'under-age drinking'. Many organisations that opposed the proposal questioned the evidence cited in the discussion paper.
15. Most organisations that supported the proposal expressed support for the reasons outlined in the discussion paper and saw this measure as one part of an overall strategy. Several organisations also felt that the measure would contribute towards reducing street drinking, anti-social behaviour and associated crime.
Social Responsibility Fee
16. Although the discussion paper sought views on the detail of how a social responsibility fee should be applied, the majority of respondents expressed their view on the principle of whether a fee should be introduced. There was no consensus amongst individuals on whether a fee should be introduced - 48% were in favour and 44% against. However, large majorities of respondents were opposed to the proposals to apply a social responsibility fee to Occasional Licences (64%) and 'other' premises (63%).
17. A small majority (54%) of organisational respondents were in favour of a social responsibility fee. As with most other questions there was a clear difference in the views of health and local government sector bodies that overwhelmingly supported the proposal (82% and 71% respectively) and trade and business sector respondents, a large majority of whom opposed it (81%).
18. Few organisations in favour of the introduction of a fee commented in detail on the possible criteria for introducing it. However, a majority of those that did supported all premises being subject to paying the fee and the fee being based on alcohol sales or turnover. Opposition to introducing a fee, in particular from trade and business sector organisations, centred around views that it will be 'just another tax', that it taxes the supplier of alcohol rather than those who are misusing it, and it could penalise all traders to compensate for a minority who allow the misuse of alcohol to take place.
Further restrictions on promotional material in licensed premises
19. Again respondents tended to comment on the principle of restricting promotional material in licensed premises rather than on the three specific proposals raised in the discussion paper. A small majority (52%) of individual respondents who expressed an opinion opposed the proposals to further restrict promotional material in licensed premises. A larger majority of organisations (56%) supported the proposals in principle. There was a clear divide in views between the health and local government sectors (respectively 92% and 71% in favour) and the trade and business sector (86% against).
20. Many of the respondents who supported this proposal did so from the point of view that alcohol should be treated differently from other products, that restricting promotional material would discourage impulse buying, and that it would reduce the impact of advertising on young people. Respondents who opposed the proposals gave two main reasons: restricting promotional material would restrict 'freedom of choice' and it would have little impact in reducing alcohol misuse or binge drinking.
21. Several producers and retailers, including whisky distilleries with visitor centres and the Scottish Whisky Association, also noted that tight restrictions on promotional material could affect their ability to promote specialist products, including Scottish products.
Separate checkouts for alcohol sales and minimum age of checkout staff
22. Almost two thirds (64%) of individual respondents opposed the proposal to introduce separate checkouts for alcohol sales. Views amongst organisations were more evenly split with 50% opposed and 47% in favour. While the majority of health and local government organisations were in favour (76% and 64% respectively), the trade and business sector was overwhelmingly opposed to the proposal (92%).
23. Respondents opposed to separate checkouts were concerned about the inconvenience of separate checkouts for people buying alcohol along with their weekly grocery shop, the demonising of alcohol without necessarily reducing consumption, and that the proposal would stigmatise responsible drinkers. Several organisations expressed some doubt as to whether there is sufficient evidence to support separate checkouts which may prove controversial to implement. Those in favour of this proposal expressed support for separate alcohol checkouts as an important indicator that alcohol can no longer be treated as an ordinary commodity by retailers or consumers.
24. Almost three-quarters of individual respondents (74%) and organisations (72%) who expressed an opinion were in favour of a minimum age of 18 for alcohol checkout staff. Large majorities of health and local government sector organisations were in favour (93% and 73% respectively) whilst 50% of trade and business sector respondents were in favour and 44% against.
25. Most of the respondents that supported this proposal, including some trade and business sector organisations, agreed with the reasoning outlined in the discussion paper ( e.g. that younger checkout staff may find it more difficult to challenge customers who appear under 18). Some large retailers opposed the proposal pointing out that staff under the age of 18 can only sell alcohol if supervised by an older staff member. Several of the small retail stores that responded to the consultation also stated that they have difficulty recruiting staff who are over 18 for part-time sales jobs.
Other responses and surveys
26. The Scottish Government's Summit on Underage Drinking provided a range of views and suggestions from professionals and young people on why young people drink; the need for prevention and education to change attitudes to alcohol misuse and drunkenness; measures to reduce access to alcohol; and, the role of parents and carers in educating young people about alcohol use. A survey of around 500 young people by Young Scot on behalf of the Scottish Government found young people to be evenly divided on the proposal to raise the minimum purchase age in off-sales to 21 with 34% in favour compared with 36% opposed.
27. A number of other consultation exercises were carried out by stakeholders and submitted to the Scottish Government in response to the discussion paper, including by two MSPs, the Scottish Prison Service, East Renfrewshire Community Health Partnership, and Dundee Drug and Alcohol Action Team. Two public petitions were submitted to the Scottish Parliament urging the Scottish Government to drop or reconsider its proposal to raise the minimum purchase age in off-sales. Several organisations also provided details of surveys they conducted amongst their stakeholder groups or customers.
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