Drinkaware’s social contract is to prevent and reduce the misuse of alcohol and tackle underage drinking and is a citizen-driven social purpose. Our success in staying true to this purpose is in the extraordinary levels of trust and awareness the public has in the charity (86% public awareness ‘to provide trusted information on alcohol’ (Drinkaware Barometer, B&A 2021). As a civil society organisation, Drinkaware’s role is to encourage behaviour change. We are a trusted and known champion of positive behaviour change through improved health literacy and citizen and community empowerment. Which is why our work centres on the theory of change and the behaviour change journey, 1: Improved knowledge (I know & understand what misuse is), 2: Increased motivation (I want/intend to change). 3: Improved capacity/capability to change (I can/have the ability to change and 4. Reduced expectation (I don’t expect/feel the need to drink). And we therefore support any and all co-operative and collaborative opportunities to leverage our trusted relationship with citizen and communities across Ireland, to engage and empower them accordingly.
We would like to commend the ambitious plan and recommendations laid out in the March 13th draft of the ‘Framework to strengthen implementation of the WHO European Action Plan to Reduce the Harmful Use of Alcohol (EAPA), 2022-2025)’ and highlight some areas we believe require additional consideration: –
As the majority of Drinkaware’s engagement and focus is with the general public, and as the public is the principle beneficiary of this proposed Framework, it is vital that the public is an active not passive participant in these plans, and a key stakeholder therefore in all of the focus areas within the plans. There is, however, limited references to public inclusion and consideration in the actions and recommendations, and this needs to be redressed.
Building on the need to identify and incorporate the public’s role within this Framework, greater context is also required. COVID-19 has irrevocably altered consumer attitudes, behaviour and lifestyles. Its impact on all things health-related will have a fundamental influence of the success of these plans, and relevant data, insight and learnings regarding the changing lived experiences of citizens must therefore be included.
The importance and value of greater and broad public engagement, and context, to the success of the Framework and its objectives cannot be underestimated.
In terms of Pricing there is clear and significant merit in securing the public’s buy in, or at the very least, their understanding and appreciation of the logic (and social benefit) being deployed. The rationale for pricing policies needs to be made clear, and the proposed effectiveness and limitations of the policies need to be communicated to the public. This became particularly evident in January 2022 when Ireland implemented Minimum Unit Pricing – there was high interest from the public to understand the policy (almost 18,000 visits to the Drinkaware MUP explainer webpage, between the 1st and 6th of January 2022) but communication around MUP, the objectives and the limitations of the policy were not clearly indicated to the public. At a time where inflation and the cost of living is increasing, it is more important than ever to clearly indicate the rationale for price increases with the public, to ensure that they understand and support pricing policies regarding alcohol products. MUP’s aim is to reduce levels of consumption amongst the heaviest and riskiest drinkers, but “heavy” and “risky” drinking is not widely understood and has not been clearly communicated to the public, There is compelling evidence that pricing is one of the most effective ways to reduce alcohol consumption. But it is not a silver bullet. Legislation alone cannot deliver the sustainable change with regard to reducing alcohol-related harm that Ireland needs, and the public clearly wants.
Furthermore, an additional recommendation/action would be to monitor not just the intended but the unintended consequences of pricing interventions. In particular the conflicting commentary on whether MUP aggravates existing health inequities needs careful measurement and if required mitigation.
Through the Public Health Alcohol Act 2019 Ireland has implemented policies around the availability of alcohol, but more can, and needs, to be done in relation to online sales of alcohol. The regularity of questions on this being asked in media, public and political discourse further illustrates this need. Online sales of alcohol must be regulated to the same standards as off trade sales to ensure that no person under the legal age limit of 18 can procure alcoholic products. Alcohol has no place in childhood and with the average age Irish children have their first drink being 15 years (Drinkaware Index 2019) more must be done regarding children accessing alcohol. Many concerns have been raised over the last few years regarding how online delivery of alcohol facilitates access to alcohol without adequate age verification. Any legislation that addresses online sales and deliveries must include robust protective measures for those under the legal age of alcohol consumption.
There is a potential tension in the recommendation to ‘regulate drinking in outdoor public spaces, where this is permitted’. Over the last two years the Irish public has been actively encouraged to socialise out of doors and therefore the level of gatherings in outdoor settings has increased substantially. Any regulation in this regard would require a very clear rationale based on evidence stipulating why such events, or premises have been decided upon if the policy is to supported and complied with by the public, this refers directly to the background section for focus area 2 which does state ‘availability restrictions also need to be supported by the general public and efforts need to be made to inform the citizens of the public health and social benefits’. This also speaks to the work of Drinkaware, which serves to deliver public health information to the public and provide explanations and context around new legislation regarding alcohol in Ireland.
With regard to digital marketing and the digital environment, some of the recommendations, specifically obliging platforms and/or companies to share their market data, are simply unrealistic. The WHO might be better able to achieve the objectives of these recommendations by engaging with expert organisations already operating in this space such as the (global) Internet Commission (https://inetco.org/) whose Accountability Framework is designed to reveal, counter and redress online harms.
The explicit and implicit influence of marketing on children is well researched and documented, as are the two primary actions to counter this influence: regulation/legislation and media/digital literacy education. Drinkaware’s Alcohol Education Programme comprises 33 lessons in total over three years with 11 lesson themes each year. Included each year is the lesson theme of Influences which aims to help adolescents to become critically aware of significant influences in their lives and how these might affect behaviour and decisions around alcohol. The lessons address the impact of social media and messages around alcohol, marketing and advertising with reference to underage alcohol use, staying safe and the role of alcohol.
Public health information is a key area of work for Drinkaware, and we believe that the public has a right to know the harms associated with alcohol consumption and be informed on how to reduce the risks of these harms. Best practice studies offer helpful guidance on how to Impart this information so that it is embedded as relevant knowledge, and ideally then acted upon. Delivering the right information i.e. factual information, in the right way i.e. in a pragmatic non-dictatorial manner, is more likely to achieve its retention and also to be utilised in people’s decision making. To be effective, any information campaign must be multi-faceted, across multiple platforms and channels, and ideally be conveyed by multiple actors, and in particular by known, respected and most importantly trusted, actors. The suggestion of a communication strategy to coincide with labelling on alcohol products is a welcome one in this regard and must be implemented as requirement.
Drinkaware welcomes the inclusion of nutritional content of alcohol on labels included in the Public Health Alcohol Act 2018. The Drinkaware Barometer 2019 found that 85% of Irish adults feel it is important to provide information on the calorie and sugar content of alcohol. This is evidenced by the popularity of our Drinks calculator tool on the Drinkaware website which received over 300,000 page visits in 2021 alone and over 190,000 completions, where people have used it to determine the calorie and sugar content of the drinks consumed. Our website currently appears across labelling to provide consumers with a link to evidence-based information, tools and advice and is a positive step to support consumers to make more informed and healthier decisions about their drinking habits.
Labels are one tool that can be utilised to deliver health information to the public but there are many other public ‘opportunities to see’ this important information. Drinkaware for example leverages the reach and engagement of social media, outdoor advertising and face-to-face events to deliver this and other more needed information. The provision of same at the points of purchase consideration and sale are also important. So too is alcohol education that starts at a young age, with special attention to the key transition years, and continues throughout life, in communities and workplaces. It is only through broad, consistent and accessible (in language, tone and channel) communication that a population that understands the harms associated with alcohol can be achieved. Alcohol and health information are complex, and human biases endemic, therefore a far-reaching and multi-faceted approach is required. Collaboration and co-operation are vital for public health information, ensuring that those best placed to deliver the message to the public are involved with the creation and dissemination of the materials.
Community action is a turnkey to addressing societal issues, and the collective focus of communities in motivating, enabling and sustaining positive health-related behaviour and attitudinal change is critical with regard to this Framework. Health literacy is a determinant of alcohol consumption and it can and must start young. Interventions are important but primary preventions are critical to halt the trajectory of alcohol-related harms, and to create new social norms that are robust and sustainable.
The Drinkaware Junior Cycle Alcohol Education Programme (JC AEP) has proven its ability to increase the number of students with no intention or interest in drinking alcohol (30% 1st year to 54% 3rd year) but also, its ability to increase the number of those with knowledge of the impact of alcohol on overall health and well-being (from 22% in year 1 to 50% In year 3). Evaluated over a three-year period, under Professor Sinead McGilloway of Maynooth University, the Drinkaware JC AEP a is an evidence based, best practice programme, delivered by trained teachers. The Junior Cycle Alcohol Education Programme was originally informed and shaped by evidence on best practice in alcohol education (Morgan 2016) and also by research conducted amongst parents and students themselves (Drinkaware 2016). It was aligned with the curriculum and designed to incorporate innovative learning methodologies, and concepts such as a whole school approach. The programme’s research-based credentials are augmented by the findings from the longitudinal evaluation. Importantly, the programme has been further adapted and enhanced by the findings and feedback from the students and teachers at each stage throughout the lifetime of the research. Focus area 6 recommends the development of such programmes, including the allocation of resources for evaluation and adaption of the activities in response to findings. Further findings from the evaluation can be accessed here.
The learnings we have gained through the experience of creating and delivering the programme, coupled with the independent evaluation conducted by Maynooth University, offer a compelling ‘let us not re-invent the wheel’ opportunity. Drinkaware believes that effective alcohol education is essential in reducing alcohol misuse and harm and that programmes such as the Drinkaware JC AEP should be utilised by member states as an example of effective alcohol education as outlined in the recommendations included in the Framework. The recommendations outlined in focus area 6 are of great importance, alcohol education is a moral imperative, and citizens have a right to clear, accurate and factual information regarding alcohol.
Worth noting, in addition to the proven independent efficacy of this programme, is that it was developed, delivered and evaluated without any involvement or influence from economic operators.