SARN response to WHO consultation

World Health Organization consultation on the working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce the Harmful Use of Alcohol

Submitted on 9 December 2020

We suggest four key points to strengthen the draft action plan:-

1) The role of economic operators 

We strongly agree that economic operators should “refrain from activities that may prevent, delay or stop the development, enactment and enforcement of high impact strategies and interventions to reduce the harmful use of alcohol.  (They) are encouraged to contribute to the elimination of marketing and sales of alcoholic beverages to minors and targeted commercial activities towards other high risk groups” (p.12).   

However, in some sections of the document, economic operators are given equal standing to other stakeholders, such as civil society and other UN organizations.  Alcohol adversely impacts 13 of the 17 UN Sustainable Development Goals ( yet the alcohol industry has attempted to undermine the focus on alcohol as an obstacle to sustainable development (  Therefore, the role of economic operators should be addressed in a separate section of the document, with attention given to their conflict of interest regarding public health.

2) Emphasis on evidence-based policies (WHO best buys / SAFER)

We strongly support an emphasis on each country implementing evidence-based policies to reduce alcohol-related harm (i.e. WHO best buys / SAFER).  This is especially important in LMICs which are particularly subject to interference from commercial interests.

3) Restricting digital alcohol marketing and protecting minors

One of the most cost-effective policies to reduce alcohol-related harm is to enforce bans on, or comprehensively restrict, alcohol advertising.  The digital marketing of alcohol represents new, high levels of risk, especially for minors. We strongly support statements in this document to regulate digital marketing and social media advertising. This is a global issue, which cannot be solved by any single country, and so it is appropriate that it should be led by WHO. 

4) The role of research / building research capacity

SARN builds capacity in alcohol research at a local, national and international level. SARN members contribute to the research evidence base which allows policymakers to effectively tackle alcohol-related harm, and provides NGOs with robust evidence for advocacy.  We therefore support the objective to “strengthen information systems and research for monitoring alcohol consumption, alcohol-related harm and policy responses at all levels with dissemination and application of information for advocacy, policy development and evaluation purposes” (p.9).  

However, we support a broad interpretation of the objective to focus on research which is “highly relevant to the development and implementation of alcohol policies” (p.18).  This should include qualitative research which is necessary to understand the social context of drinking in high risk groups (as attempting to implement interventions without understanding social and cultural drinking practices will be ineffective) (e.g. Emslie et al. 2017), rapid literature reviews and ‘reviews of reviews’ on emerging issues (e.g. Atkinson et al. 2019;  Fitzgerald et al. 2016), and using innovative methods to understand the lived experience of drinking across the harm continuum (Shortt et al. 2017), as well as more conventional epidemiological research.  


Atkinson A. et al. 2019. A rapid narrative review of literature on gendered alcohol marketing and its effects: exploring the targeting and representation of women.

Emslie, C., Lennox, J. and Ireland, L., 2017. The role of alcohol in identity construction among LGBT people: A qualitative study. Sociology of health & illness39(8), pp.1465-1479.

Fitzgerald, N., Angus, K., Emslie, C., Shipton, D. and Bauld, L., 2016. Gender differences in the impact of population‐level alcohol policy interventions: evidence synthesis of systematic reviews. Addiction111(10), pp.1735-1747.

Shortt, N.K., Rhynas, S.J. and Holloway, A., 2017. Place and recovery from alcohol dependence: A journey through photovoice. Health & Place47, pp.147-155.

Edinburgh hosts European alcohol policy conference

On 20–21 November 2018, Scottish Health Action on Alcohol Problems (SHAAP) hosted the 8th European Alcohol Policy Conference (EAPC). The conference was attended by a variety of stakeholders in the field of alcohol policy from around Europe, including researchers, government officials, civil servants WHO representatives, recovery community groups, and people with lived experience. The conference not only addressed the key issues in the field of alcohol but also shared success stories of approaches that work.

The six themes of the conference were youth, justice, recovery, health, gender, and economics. There was a great deal of discussion between presenters and audience members during the two days and particularly important was the added value of the experiences shared by people in recovery. A short film made for the purpose of the conference made the very point that only by listening to people in recovery can we support people to access recovery services and sustaining recovery.

One key celebration of the conference was the Alcohol Policy Award, which was given to Estonia due to their progress in new alcohol control measures. In recent years, political support has led to implementing policies that address the WHO ‘best buys’, including tax increases, regulations of alcohol marketing, and restricting the availability to alcohol in shops. You can read more about the award here.

© SHAAP/Malcolm Cochrane Photography

Another key feature of the conference was the launch of the new Alcohol Framework, which was announced by the Minister for Public Health, Sport and Wellbeing Joe Fitzpatrick. The Framework sets out 20 actions to reduce consumption, change population attitudes and encourage positive choices, and supporting families and communities.

Whilst having a European Perspective, the Scottish contribution to the conference was prominent. Of note was that the Alcohol Policy Team at the Scottish Government was awarded recognition for their “outstanding contribution to NCD prevention and control”, by WHO on behalf of the UN Interagency Task Force on the Prevention and Control of Noncommunicable Diseases (UNIATF). Furthermore, PhD student Annie Taylor from Edinburgh Napier University won prize for best poster at the 8EAPC for her poster on alcohol and pregnancy.

A report of the conference along with videos will be made available on SHAAP’s website in due course.

© SHAAP/Malcolm Cochrane Photography

New Video from Glasgow Caledonian’s Substance Use and Misuse Team

The Substance Use and Misuse Research Group at Glasgow Caledonian University has recently released a video to highlight some of  the current research interests of the group.

The research group, led by Dr. Carol Emslie, aims to understand the social context of substance use and develop interventions to reduce harm. Areas of interest include but are not limited to: gender and alcohol consumption across the lifecourse, alcohol-related violence, smoking cessation, substance dependence and stigma, exploring and reducing inequalities in substance use, and substance use, media and subculture.

If you would like further information about the research being undertaken by members of the Substance Use and Misuse group please have a look at their website and/or twitter feed. Alternatively, you can contact

Hollywood Magazine, 4th Feb: Amid a ‘refresh’ of Scotland’s alcohol strategy, are we going in the right direction?

Thanks to SHAAP for their weekly media monitoring.
This article was taken from Hollywood Magazine, 4th Feb.

Scotland’s relationship with alcohol is changing, though, evidently, slowly. Despite increased awareness of the harm caused, the latest evaluation of Scotland’s alcohol strategy suggests public knowledge and attitudes around alcohol haven’t really budged in the last ten years.

The latest effort came a few weeks ago as chief medical officers across the UK unveiled new guidelines advising men and women to consume no more than 14 units in a given week, a change brought about by fresh evidence of the link between alcohol and cancer.

“Actually, it doesn’t matter what you set it at,” says Dr Richard Cooke, senior lecturer in health psychology at Aston University. “If you’re going to use units, nobody knows what a unit is. Alcohol researchers know what a unit is, scientists know what a unit is, the general public, they’ve no idea what a unit is – they don’t use units to think about their drinking.”

Awareness of units is in fact high, according to work by Stirling and Sheffield universities, though the ability to measure and count intake is poor. That stems from a myriad of factors, including an increase in the strength of most wines plus a greater variety of beers and ciders now on offer.

The fact more drinking now takes place at home also complicates the picture. Almost three-quarters of alcohol sold in Scotland in 2014 was via off-sales, the highest market share since recording began two decades earlier. “We’re a nation of take-home drinkers,” remarks Paul Waterson, chief executive of the Scottish Licensed Trade Association (SLTA).

December’s European Court of Justice ruling on minimum unit pricing was claimed as a victory by both sides in the protracted legal wrangle. Irrespective of which side the Court of Session now comes down on, another legal battle looms at the UK Supreme Court.

“At a UK level, we need to be making the case – and the Scottish Government needs to be making the case – for using taxation to reduce harm,” says Alison Douglas, chief executive of Alcohol Focus Scotland (AFS). “This would be complimentary to minimum unit pricing. Unfortunately, we’ve been going backwards at UK level on that.”

Pricing is not the only avenue campaigners are keen to pursue, though. AFS, for instance, would like to see “stronger restrictions” on sport sponsorship and advertising. Addressing the Global Alcohol Policy Conference in Edinburgh last October, the First Minister made a point of stressing the Scottish Government’s support for a 9pm watershed when it comes to broadcast advertising.

This, however, as Nicola Sturgeon reminded observers, was not within her gift, broadcasting being reserved to Westminster. “Even if broadcast media is reserved to Westminster there are other things that the Scottish Government can do to protect children from exposure to alcohol advertising that would enable us to begin moving in the right direction,” counters Douglas.

Indeed, as ministers prepare to embark on a ‘refresh’ of the 2009 strategy, the AFS chief executive – who was responsible for the development and implementation of the original blueprint in her former role as head of alcohol policy and delivery within government – intimates a desire to see potentially controversial proposals, such as a social responsibility levy and alcohol-only checkouts, which the Scottish Government has previously considered only to then shelve, explored again. Even putting minimum unit pricing to one side, though, ministers have not necessarily shied away from potential controversies.

The change in the legal drink-drive limit just over a year ago saw Scotland adopt the lowest threshold in the UK, albeit Northern Ireland will soon go further after legislation was passed last month. Police figures published in the last fortnight showed the number of people found to be above the drink-drive limit between December 3 and January 1 rose almost a third on the previous year. That as an SLTA survey of 600 businesses found 40 per cent of trade in rural areas were down or showed no growth over the festive period.

“We’re collateral damage in this idea that nobody should have one drink, which is utter nonsense,” says Waterson, citing that of the 459 drivers caught, only 19 were found to be between the old and new limit. “If we had a penalty system based around a points system then it would give a bit of flexibility. It’s rather like saying to somebody, ‘you can’t drive over 30mph in a 30 limit and if you drive at 35mph we’re going to give you a 20-year criminal record’. It’s nonsense.”

It is no secret that relations between police and parts of the licensed trade had soured in the early days of a single force amid disquiet over its enforcement strategy. Talks between Police Scotland and trade reps from across the country took place last June, just weeks after Glasgow Licensing Board controversially imposed a midnight closing time on The Arches venue following police complaints about drug and alcohol incidents.

Agreement on formal terms of reference for a national licensing trade forum is expected later this month, bringing police and different parts of the trade together on a regular basis. “Of course, the environment of licensing across Scotland differs for lots of reasons,” says Police Scotland Assistant Chief Constable Mark Williams, who oversees the force’s national licensing and violence reduction unit.

“But we want to make sure that the professional approach we take is a consistent one and the licensed trade associations know what to expect from us and can have a confidence in the service that we deliver so that there are no surprises.”

A national database for licensing – known as Innkeeper – is also scheduled to go live within the next few weeks. “It records all aspects of a visit to allow us to ensure that we have a catalogue of information,” says Williams. “When people apply for relicensing, licensing extensions or extraordinary licenses for particular events, we’re [then] able to go back and properly evidence our support – or otherwise – based on our experience of dealing with that premises, shop or whatever it may be, in the visits we’ve made.”

Williams, who was local police commander of the Edinburgh City Division until his promotion to ACC seven weeks ago, had – along with other public agencies – been vocal previously in his belief that the capital had an overprovision of licensed premises. “There are some examples of licensing boards that do work very effectively, are very proactive and absolutely work to the licensing objectives that they’ve set. And there are others that don’t do it so well,” he says.

“The overarching principles of licensing in Scotland are about public safety and wellbeing and managing that. And I sometimes am concerned that the economic vitality of an area, or a city even – and I reflect back to my experience in Edinburgh – is always prioritised over public safety. There has to be a balance struck between the two.”