Summary of the WC Alcohol Harms Reduction Policy

In addition to the national-level Liquor Amendment Bill currently in the public comment phase, is the Western Cape Alcohol Harms Reduction Policy Green Paper, also up for public comment.

A green paper is a report for proposed policy, in this case about alcohol-related harms (ARH) reduction. It’s meant for the public to discuss and debate, and will then be used to create policy and laws. Now, until 30 November 2016, is the time that your comments can influence policy. Contact details at the bottom.

Docs in question:

1. Western Cape Alcohol-Related Harms Reduction Policy Green Paper here (92 pages, pdf, 534kb, hosted on westerncape.gov.za);
2. Frequently referred to, 2014 WHO Global Status Report on Alcohol & Health (392 pages, pdf, 5.7mb, hosted on who.int);

Page numbers mentioned in my comments refer to the PDF document’s page numbers.

In a Nutshell

The Western Cape (WC) suffers ARH more intensely than other provinces. Something has to be done about it.

To help raise society and make life better for everyone, it is our obligation as drinkers (and manufacturers, and marketers) to help mitigate the harms of having access to what is essentially a legal drug; alcohol.

Various circumstances lead to the poor choices made in relation to alcohol. Perhaps there is room in this green paper, in conjunction with dealing with the consequences of those choices, to also address why those choices are made in the 1st place. Do we need help to make better choices, or need better alternatives when making said choices?

Regardless, ARH is a social ill, impacting on all of society, and requires a multi-pronged approach. Proposed price increases have been getting a lot of attention, but it’s just one of the prongs. Others include protecting the youth from exposure to alcohol & alcohol advertising, especially links between alcohol and, say, sport achievements; reducing access to alcohol; and strengthening legislation to give the law’s bark some bite, focussing on the illicit trade and drunk driving.

Green Paper Background

In 2015 a workgroup comprising experts from many spheres, policing, academia, medical, etc., were brought together to start work on this green paper. Except for the WHO report from 2014, the report draws often from 2009/2010 statistics.

The report states that in December 2015 there were 9,296 licensed outlets in the WC (which means these WCLA stats are outdated), and about 3,483 unlicensed outlets – thus 12,779 liquor outlets. The WC has a population of 6.2 million. To get an idea of the ratio of outlets to people vs. other provinces, KwaZulu-Natal, for instance, has slightly less legal liquor licenses (presumably roughly the same number of illegal ones), but a population of 11 million.

The current framework, the green paper finds, regulates, enforces and licenses the manufacturing, distribution and sale of alcohol reasonably well, but falls short on considering the ARH to society. This shortcoming forms the basis of the policy.

It is noted that South Africans drink a lot, and in risky patterns, making alcohol the 3rd leading risk factor in death and disability, after unsafe sex and obesity, although alcohol also contributes to those two. ARH affect kids and adolescents, and are linked to increased violence, transport-related deaths, and suicides. It estimates that the nett loss to GDP, after accounting for the alcohol industry’s contribution, is between R165 – R226 billion.

The goal of the green paper is “contributing to the reduction of ARH in the Western Cape”. Chapters 1 – 9 lays out the target policy areas and proposed interventions. Highlights follow.

Chapter 1: Pricing & Economy

While recognising the contribution of the alcohol industry, the findings suggest it is vastly dwarfed by the cost of ARH. Proposed remedies include:

• Banning advertising visible to under 18s is prefered. If this is not achievable:
  • Alcohol industry may sponsor public WC government organised events & collect BBBEE points, but products and companies may not be advertised, marketed or promoted at the events;
  • WC government to lobby national government for levies on marketing to cover cost of counter ARH messages;
• Budget for ARH intervention at health and social service facilities for drinkers who experienced trauma related to alcohol;
• Set maximum limits for trading hours, with consideration for business nodes or tourism;
• Reduce alcohol availability, limit density of on/off consumption outlets, and trading days / hours;
• Lobby national government to increase prices, either by raising tax & excise, and/or minimum unit pricing (reduce prevalence of cheap alcohol, Page 29);
• Incentivise the reduction of alcohol content – apparently drinkers can’t tell anyway (Page 30);
• Implement a tracking system to curb supply to unlicensed outlets & distributors;
• Better police outlets that sell to underage drinkers;

Chapter 2: Unlicensed Liquor Outlets & Illicit Trade

In this section the concern is addressed that there’s a leak of tax and licensing revenue that could be used to help mitigate ARH. Proposed remedies:

• Bring illiicit traders into the regulated space in a responsible, sustainable manner to give retailer benefits, while collect tax for the good of society.
• The application process for liquor licenses must be simplified (Page 33);
• Rezone outlets for liquor sales where appropriate;
• Prioritise upstream interventions that target suppliers of the illicit trade;
• Create awareness of alternative economic opportunities;
• Legislate efficient & effective disruption of their supply chain;
• Enable liquor enforcement units with more resources;

Chapter 3: Enforcement

Enforcement is recognised as important in reducing ARH. Some proposals:

• Innovative strategies should be implemented, such as the “last drinks survey“, successful in New Zealand to establish where drinkers involved in an alcohol related incident had their last drink – useful in analysis to identify and address possible problems;
• Lobby for well-prepared police dockets, to raise success of prosecuting illicit traders, making it an effective deterrent;
• Increase trained liquor law enforcement officers;
• License holders and managers to be on-site at all times, with proper training and tested on the WC Liquor act, so that they are aware of the applicable laws and obligations of their establishment under the license.
• Legislation for mobile testing breath and/or blood by legally admissible devices to be legally admissable, to reduce number of drink-drive cases withdrawn due to backlog of blood analysis from chem lab (Page 40);
• Diversion or alternative dispute resolution for lower-level alcohol transgressions like being drunk and disorderly. Still a serious issue (61% of pedestrians killed in WC in 2010 had alcohol present), but alleviates court backlogs for other serious matters. Community service or rehab treatment are suggested.

Chapter 4: Alcohol & Road Enviroment

That South Africa has a consistently high prevalence of alcohol related road fatalities is inescapable (Page 42, statistics). Some remedies proposed:

• Restrict liquor licenses in areas with high number of related incidents;
• Impose restrictions on sales by outlets on national roads;
• Implement a graduated alcohol limit for drivers (Page 44, interesting ideas);
• Zero tolerance for young or new drivers;
• Legislation to introduce blood alcohol limits for pedestrians on certain roads during particular hours (Page 45);
• Introduce alcohol interlocks for certain road vehicles, where a breath sample is required to start the vehicle – considered for all public transport, school and government vehicles, goods vehicles over a certain weight, and for convicted drivers (Page 46);
• Include ARH education as part of vehicle license testing;
• Interventions for 1st time DUI offenders;

Chapter 5: Health & Social Services

A section implores all of society to get involved, with services that focuses on the individual, but within the context of their families and communities. Proposals include:

• Equitable distributed emergency services for ARH (Page 48);
• Boost prevention, early intervention, detoxification and aftercare;
• Interventions at antennal clinics to reduce likelihood of alcohol-exposed pregnancies;
• Establish screening & referral services at schools in the province’s high risk areas;

Chapter 6: Community-based Action

Here the Green Paper aims to flesh out and strengthen specific and unique community resources, partnerships and capacity building to help reduce ARH. It proposes:

• Expand community-based model for substance abuse treatment & rehab (Page 52);
• Boost municipal capacity to coordinate community programs;
• Increase community input (Page 54/55);
• Roll out successes achieved in programs implemented in Khayelitsha, Gugulethu & Nyanga and Paarl East (Page 55);

Chapter 7: Education & Awareness

The section suggests society as a whole take part to create awareness, and educate about strategies for reducing ARH and interventions available to the public. Proposals include:

• prioritising provincial and location action groups as platform for communication;\
• leveraging after-school space for education targeted at youth;
• improve ease of access to education materials;
• continuing education of ARH relating to pregnancy;

Chapter 8: Collect, Monitor, Evaluate

Starting on page 62, the need for efficient data management is highlighted. It proposes:

• that the WCG lobby national government for a structure – national, provincial, local – that collects data to assist in monitoring and evaluation;
• WCG should investigate feasibility of a purpose-built surveillance system;
• Draw data related to alcohol economy and ARH for the purpose of informing reduction strategies;

Chapter 9: Institutional Arrangements

This section recognises that institutions play and important role to support, implement and police this policy. It is suggested that:

• an efficient & effective structure is selected from 4 proposed models: current, hybrid (preferred), commission or in-house (Page 67);
• cost of administrative burden & liquor license application be shifted to applicant (Page 69);
• an on site manager require certain qualifications;
• applicant must obtain municipality approval for activities related to the application;
• relationship between liquor licensing, trading hours, lighting and pedestrian infrastructure to be introduced;
• application fees be based on actual processing costs (Page 70);
• renewal fees be based on volume categories;
• updating license categories in line with technology to reflect 10 different categories, including off-consumption for electronic sales, market license, event license and short-term license; (Page 70);

Conclusion, Bibliography and Annexes make up Page 73 – 91.