cohealth made a number of recommendations to a discussion paper released by the commonwealth government in relation to the National Alcohol Strategy. These recommendations included reinstating the Alcohol and Other Drugs Council of Australia, and calling on the Commonwealth to confirm the funding of nearly $800 million in key health initiatives under the Health Flexible Funds.
cohealth is broadly supportive of the proposed goals, guiding principles, priority populations, and priority areas for the National Alcohol Strategy. cohealth suggests some specific initiatives as effective strategies to achieve the aims under a number of the priority areas, as summarised below (note that numbers refer to recommendation numbers in the main body of this submission). These recommendations are consistent with the World Health Organisation Global Strategy to reduce harmful use of alcohol, which can be found at: http://www.who.int/substance_abuse/activities/gsrhua/en/
At the outset, cohealth has two key recommendations:
Taxation is a critical supply side policy option for reducing both the supply of, and demand for alcohol.
cohealth agrees that the proposed priority areas are appropriate. Furthermore, below we suggest some specific initiatives as effective strategies to achieve the aims under a number of the priority areas.
Priority 1: Change the current drinking culture in Australia to reduce harmful drinking
It has been calculated that there are more than 42 million occasions of binge drinking per year in Australia with alcohol consumption contributing to 3% of the burden of chronic and complex health conditions and injuries per year in Australia.
The full extent of the effect of alcohol in Australia is not limited to the increased risk of poor health outcomes. The additional effects include:
Priority 2: Prevent and reduce alcohol related injury and violence
Alcohol consumption is attributable to other forms of injury in the community, beyond the health of the individual consumer of alcohol. Within the context of family relationships involving a man and woman, and children, alcohol can fuel male attitudes of control and coercive behavioural responses to threats to male dominance.
Our organisation’s work in family violence and alcohol and other drugs shows that consumers of alcohol are more likely to disclose associated problems with excessive alcohol consumption in primary healthcare settings than in a specialist family violence service or AOD setting.
The health system is a critical space to support the identification of and response to alcohol consumption; both from the perspective of the individual consuming alcohol and in the context of women and children who experience alcohol related violence.
Health care services need to be skilled in identifying and responding to excessive alcohol consumption in the community. In this space, community health services which offer health services based on the social model of health are well placed to respond to alcohol related violence in the community. Community health organisations are accessible for local communities, and key populations providing a range of services in the one setting. This model enables the individual to access multiple services at once, and in a way that is not feasible in a fee paying service.
Priority 3: Prevent alcohol use during pregnancy
It is accepted that excessive consumption of alcohol during pregnancy can lead to damaged fetal development in an unborn child. Further the minimum or threshold level at which alcohol poses a threat to pregnancy remains unknown.
20% of birth parents drank alcohol in contravention of guidelines which recommend abstention during pregnancy.
Fetal Alcohol Spectrum Disorder (FASD) covers the range of abnormalities that can occur to a person if their fetus is exposed to alcohol consumption during pregnancy. The prevalence of FASD in Australia is considerable amongst Aboriginal communities, where one study reported that 23 per cent of birth parents of Aboriginal children reported drinking alcohol in pregnancy.
Priority 4: Protect young people from alcohol related harm
In Australia, specific populations are more likely to drink at levels that are harmful.
Young adults (aged between 18-24) are more likely to drink at harmful levels on a single occasion than the rest of the adult population. Males were more likely to drink at harmful levels than females.
Aboriginals and Torres Strait Islanders – who consume alcohol – are more likely to drink at levels that are considered high risk with those aged 15 or above being 17% more likely to consume at levels that are risky/high risk levels.
Mainstream service delivery responses to address alcohol consumption often involve language that is not inclusive of minority communities, or is conducted in settings that are not culturally or community oriented towards engaging these communities.
Sexually and gender diverse communities consume alcohol at levels that are higher than individuals who do not identify as sexually and gender diverse.
Community health organisations have developed a critical role in supporting key populations at risk of chronic and complex health conditions. This includes providing treatment and prevention interventions from primary care to secondary and tertiary care in the one setting. These settings are well equipped to respond to the needs of key populations in relation to addressing harmful alcohol consumption.
Priority 6: Provide an effective framework for advertising, promotion and sponsorship
Alcohol packaging is an essential part of building specific brands. In the marketing of alcohol, product design and colour scheme are part of this branding. The packaging and colours of the product are developed to target specific consumer groups to attract consumers and specific groups. Branding and advertising can also be used to falsely reassure consumers about the potential dangers of products. For instance, the packaging and branding of products can focus the consumer’s attention away from the harms associated with alcohol products and the levels of alcohol or other toxins in these products.
To limit the opportunities to exploit marginalised individuals and communities and address patterns of alcohol consumption in Australia there is a need to impose increased restrictions on alcohol advertising, promotion and sponsorship.
Priority 7: Enhance effective enforcement and controls on availability.
The price of alcohol is critical to alcohol consumption and levels of excessive alcohol consumption. There is strong and consistent evidence that higher alcohol prices decrease both alcohol consumption and alcohol related harms while lower prices increase them. A price increase of 10 per cent is estimated to reduce overall alcohol consumption by an average of 5 per cent. Demand for wines and spirits more responsive to price than is the demand for beer.  Increased alcohol prices have also been shown to reduce the proportion of young people who consume excess levels of alcohol. This includes reducing underage and binge drinking, delaying intentions among younger teenagers to start drinking and to slow progression towards drinking larger amounts.
Beer and spirits are already taxed using a volumetric system of taxing. Imposing a volumetric tax on wine would ensure consistency in the taxation of alcohol products. Volumetric taxes also raise the price of the cheaper alcohol products on the market, which weakens demand for these products.
There is concern at the alcohol industry’s propensity to heavily discount alcohol products in marginalised and remote communities to attract custom from key populations with identified levels of harmful alcohol consumption, like aboriginal communities and young people. The concern relates to discounts for bulk alcohol purchases and discounts that are activated to fall on the same day as pension and welfare payments. To ensure that marginalised communities are not exploited by alcohol industry pricing, improvements in data collection and monitoring as set out under Priority 9 below should accompany taxation reform of alcohol products.
Priority 8: Improve treatment capacity, particularly within primary, acute and other health care settings.
Priority 9: Guide practice through appropriate data collection and evaluation, and be responsive to emerging issues
The data generated from this initiative would inform the need for targeted strategies to respond to specific issues, for example specific alcohol products (for example, alco pops and other alcohol products (that is, sweet, low cost, high percentage of alcohol) that are designed to introduce young drinkers to alcohol products , or promote heavier alcohol consumption.
Priority 10: Improve responses for emergency services
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