Dead on Arrival? Evaluating the Public Health Responsibility Deal for Alcohol
- The Responsibility Deal is not endorsed by academics or the public health community.
- It has pursued initiatives known to have limited efficacy in reducing alcohol-related harm.
- The evidence on the effectiveness of the Responsibility Deal is limited and unreliable, due to ambiguous goals and poor reporting practices.
- Where evaluation has been possible, implementation has often failed to live up to the letter and/or spirit of the pledges.
- The Responsibility Deal appears to have obstructed more meaningful initiatives with a stronger evidence base behind them.
What is the Responsibility Deal?
The Public Health Responsibility Deal (RD) was launched in 2011 as a voluntary partnership between the government, commercial organisations, public bodies, academics and NGOs to promote public health goals. Through a set of non-binding pledges, these actors – and in particular industry – are expected to take steps to reduce health harms.
The RD is organised into four networks addressing particular challenges, each with distinct sets of pledges: food, alcohol, physical activity and health at work.
This paper evaluates the success of the Responsibility Deal Alcohol Network (RDAN).
11 different pledges were made in relation to alcohol under the RD, each attracting different sets of signatories.
Responsibility Deal Pledges
A1. Alcohol Labelling: “We will ensure that over 80% of products on shelf (by December 2013) will have labels with clear unit content, NHS guidelines and a warning about [alcohol use] when pregnant”. (101 signatories)
A2. Awareness of Alcohol Units in the On-trade: “We will provide simple and consistent information in the on-trade (e.g. pubs and clubs), to raise awareness of the unit content of alcoholic drinks, and we will also explore together with health bodies how messages around [alcohol consumption] guidelines and the associated health harms might be communicated.” (46 signatories)
A3. Awareness of Alcohol Units, Calories & other information in the Off-trade: “We will provide simple and consistent information as appropriate in the off-trade (supermarkets and off-licences) as well as other marketing channels (e.g. in-store magazines), to raise awareness of the units, calorie content of alcoholic drinks, NHS lower-risk [alcohol consumption] guidelines, and the health harms associated with exceeding the guidelines.” (49 signatories)
A4. Tackling Under-Age Alcohol Sales: “We commit to ensuring effective action is taken in all premises to reduce and prevent under-age sales of alcohol (primarily through rigorous application of Challenge 21 and Challenge 25).” (68 signatories)
A5. Support for Drinkaware: “We commit to maintaining the levels of financial support and in-kind funding for Drinkaware and the ‘Why let the Good times go bad?’ campaign as set out in the Memoranda of Understanding between Industry, Government and Drinkaware.” (80 signatories)
A6. Advertising & Marketing Alcohol: “We commit to further action on advertising and marketing, namely the development of a new sponsorship code requiring the promotion of responsible [alcohol use], not putting alcohol adverts on outdoor poster sites within 100m of schools and adhering to the Drinkaware brand guidelines to ensure clear and consistent usage.” (97 signatories)
A7 (a). Community Actions to Tackle Alcohol Harms: “In local communities we will provide support for schemes appropriate for local areas that wish to use them to address issues around social and health harms, and will act together to improve joined up working between such schemes operating in local areas as:
- Best Bar None and Pubwatch, which set standards for on-trade premises
- Purple Flag which make awards to safe, consumer friendly areas
- Community Alcohol Partnerships, which currently support local partnership working to address issues such as under-age sales and alcohol related crime, are to be extended to work with health and education partners in local Government
- Business Improvement Districts, which can improve the local commercial environment” (60 signatories)
A7 (b). Targeted Local Action: “To support our pledge to provide schemes appropriate for local areas that wish to use them to address issues around social and health harms, we will fund and/or support industry action in Local Alcohol Action Areas, by ensuring that suitable existing partnership schemes are in the process of being rolled out in Local Alcohol Action Areas by March 2015.” (10 signatories)
A8 (a). Alcohol Reduction: “we will remove 1bn units of alcohol sold annually from the market by December 2015 principally through improving consumer choice of lower alcohol products” (34 signatories)
A8 (b). Responsible can packaging: “To support our pledge to remove a billion units of alcohol sold annually from the market, we will carry out a review of the alcohol content and container sizes of all alcohol products in our portfolio. By December 2014 we will not produce or sell any carbonated product with more than (4) units of alcohol in a single-serve can.” (8 signatories)
A9. Lifeskills education and alcohol education in schools: “We will financially support the Lifeskills Education and Alcohol Foundation (LEAF) with a minimum of 250,000 thousand pounds as a start-up fund. Subject to favourable reporting and evaluation of delivery, we will seek to increase programme scope through funding from the alcohol industry and others.” (7 signatories)
The Responsibility Deal is not endorsed by academics or the public health community
Despite being designed as a ‘partnership’, the RD for alcohol has been comprehensively rejected by most public health organisations. Six of the most prominent bodies working in the field – Alcohol Concern [now Alcohol Change], British Association for the Study of the Liver, British Liver Trust, British Medical Association, Institute of Alcohol Studies, and the Royal College of Physicians – refused to sign up to the agreement in 2011.
In boycotting the initiative, they cited not only the content of the deal, but also the perception that the process of formulating the pledges privileged the alcohol industry at the expense of the health community. According to IAS’ Katherine Brown, the pledges
were largely written by Government and industry officials before the health community was invited to join the proceedings.”
The Responsibility Deal has pursued initiatives known to have limited efficacy in reducing alcohol-related harm
Moreover, there is reason to be sceptical about the effectiveness of the RD on substantive grounds.
The academic literature provides little evidence that the RD’s measures can reduce alcohol consumption and associated harms. A recent independent evidence review, funded by the Department of Health, found that most of the RD pledges “fall into the category of ‘probably ineffective’ or ‘no/ poor/ inconclusive evidence'”.
- Research into the effects of providing [alcohol consumption] guidelines, warning labels and unit alcohol content on alcohol packaging (pledge A1) has found that whilst such information can help to raise awareness amongst consumers of the risks associated with alcohol consumption, existing labelling schemes have had no substantial impact on how much alcohol people actually consume.
- Reviews of the effectiveness of “responsible” alcohol use messages (pledge A6) have given little support to the claim that they reduce consumption.
- While better enforcement of minimum age restrictions is associated with lower alcohol consumption, voluntary training of servers (pledge A7a) to encourage responsible retailing of alcohol has generally been found to be poorly applied in practice. Rather, the most effective age verification programmes involve community mobilisation and stricter use of licensing laws
The evidence on the effectiveness of the Responsibility Deal is limited and unreliable, due to ambiguous goals and poor reporting practices
While the international evidence suggests voluntary industry measures will have little impact on levels of alcohol consumption, it is possible – if unlikely – that such initiatives in Britain might produce a different result due to different implementation methods or context. However, the way the RD has been carried out ensures it is extremely tricky to determine if industry activities are having any effect because of the limitations of data and evaluation.
Where evaluation has been possible, implementation has often failed to live up to the letter and/or spirit of the pledges
The considerations above demonstrate the difficulty of proving or disproving the effectiveness of industry efforts to prevent and reduce harm at a population level. However, it seems clear that industry initiatives, whether or not they are effective, are not being implemented as well as they might be.
- The industry has fallen short of its target to have clear unit content, NHS alcohol consumption guidelines and warnings about alcohol use during pregnancy (pledge A1) on 80% of products. An industry-commissioned audit found 79% of products in the off-trade complied with this pledge, but this fell to 70% of products when weighted by market share. It concluded that the best estimate is that 80% content compliance had NOT been achieved”.
- What this suggests is that the industry has missed its labelling pledge, though it would be unfair not to recognise that progress has nevertheless been made.
- Voluntary industry activities to tackle underage alcohol use (pledge A4) have also often suffered from poor implementation, and there is suggestive evidence that similar issues affect the UK’s ‘Challenge 25’ policy, which requires customers under the age of 25 to prove their age when buying alcohol.
The Responsibility Deal appears to have obstructed more meaningful initiatives with a stronger evidence base behind them
None of the arguments above are sufficient to show that the RD is positively harmful. Indeed, a couple of the pledges, such as restricting marketing near schools and improving labelling, may have done some good – albeit in a limited way that is difficult to demonstrate.
The RD does appear to have had the negative consequence of obstructing more effective policies addressing alcohol harm.
According to a review of evidence underpinning the RD,
the most effective evidence-based strategies to reduce alcohol-related harm are not reflected consistently in the RD alcohol pledges. The evidence is clear that an alcohol control strategy should support effective interventions to make alcohol less available and more expensive.”
This is not necessarily linked to the RD: its launch document explicitly states that “Pledges developed under the auspices of the Responsibility Deal are not intended to replace Government action – they complement it”. Nevertheless, even within the same paper, then Health Secretary Andrew Lansley acknowledged a potential trade-off between the two:
By working in partnership, public health, commercial, and voluntary organisations can agree practical actions to secure more progress, more quickly, with less cost than legislation.”
The Responsibility Deal has never been a genuine partnership, having been boycotted by almost every independent public health group. Many of their objections have been vindicated in the four years since.
The RD has systematically focused on relatively ineffective interventions that are unlikely to reduce alcohol consumption.
It has set up its pledges in ambiguous terms that resist assessment. The alcohol industry has obstructed rigorous evaluation of the RD, through the unreliability of its progress reports, and more damningly through its misconduct in the official evaluation process.
Where independent evaluation has occurred, as with the billion unit pledge or the labelling pledge, the industry has generally failed to show it has met its targets.
And even when the industry has lived up to the letter of its pledges, it has sought to circumvent the spirit of the endeavour.
All of this would be forgivable if the RD were a harmless sideshow. Yet it appears to have been the main element of the UK’s alcohol strategy in recent years (though the current status of the RD is uncertain), and has been used by the industry to resist more effective policies. If this is the case, the RD has worsened the health of the nation, and so must be considered a failure.