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5th Report, 2010 (Session 3)

Stage 1 Report on the Alcohol etc. (Scotland) Bill

CONTENTS

Remit and membership

Report

INTRODUCTION

Procedure
Purpose of the Bill
Scottish Government consultation
Concurrent legislative proposals
Committee consideration

PART 1 – PRICING OF ALCOHOL

Background
Extent of the evidence base
Cross-border and internet sales
Impact on low-income groups
Developing a new Scottish public policy response
Setting the price
The pivotal role of culture
Potential economic impact
Conclusion
Compatibility with EU law and legislative competence more generally
Anti-competition issues
Overall conclusion on per-unit minimum pricing

PART 1 – DRINKS PROMOTIONS

Background
Impact of discounting and promotions on alcohol consumption
Scottish Government
Conclusion

PART 1 – REQUIREMENT FOR AGE VERIFICATION POLICY

Conclusion

PART 1 – MODIFICATION OF MANDATORY CONDITIONS

Power to vary premises and occasional licence conditions

PART 1 – OFF-SALES: SALE OF ALCOHOL TO UNDER-21S ETC.

Power to vary the minimum purchase age
Variation of licence conditions

PART 2 – SOCIAL RESPONSIBILITY LEVY

Background
Evidence received by the Committee
Scottish Government
Conclusion

FINANCIAL IMPLICATIONS OF THE BILL

Background
Summary of costs outlined in the Financial Memorandum
Minimum pricing
Social responsibility levy
Costs on local authorities
Savings
Overall level of costs and savings and margins of uncertainty

SUBORDINATE LEGISLATION

Background
Minimum price of alcohol
Section 7 – Occasional licences: modification of mandatory conditions
Section 9 – Premises licences: variation of conditions
Section 10 – Licence holders: social responsibility levy
Section 11 – Regulations under section 10(1): further provision

EQUALITIES

Equality Impact Assessment
Impact on low income groups
Conclusion

OVERALL CONCLUSION

ANNEXE A: EXTRACTS FROM THE MINUTES

VOLUME 2: EVIDENCE

Remit and membership

Remit:

To consider and report on (a) health policy and the NHS in Scotland and other matters falling within the responsibility of the Cabinet Secretary for Health and Wellbeing and (b) matters relating to sport falling within the responsibility of the Minister for Public Health and Sport.

Membership:

Helen Eadie
Ross Finnie (Deputy Convener)
Christine Grahame (Convener)
Rhoda Grant
Michael Matheson
Ian McKee
Mary Scanlon
Dr Richard Simpson

Committee Clerking Team:

Clerk to the Committee
Douglas Wands

Senior Assistant Clerk
Douglas Thornton

Assistant Clerk
Seán Wixted

Committee Assistant
Andrew Howlett

Stage 1 Report on the Alcohol etc. (Scotland) Bill

The Committee reports to the Parliament as follows—

Introduction

Procedure

1. The Alcohol etc. (Scotland) Bill (“the Bill”) was introduced by Nicola Sturgeon MSP, Deputy First Minister and Cabinet Secretary for Health and Wellbeing (“the Cabinet Secretary”), on 25 November 2009. The Bill is accompanied by Explanatory Notes (SP Bill 34–EN), which include a Financial Memorandum, and a Policy Memorandum (SP Bill 34-PM), as required by the Parliament’s Standing Orders. The Health and Sport Committee was subsequently designated lead committee on the Bill. Under Rule 9.6 of the Parliament’s Standing Orders, it is for the lead committee to report to the Parliament on the general principles of the Bill.

Purpose of the Bill

2. The Bill, if passed, would reform the law in furtherance of the Scottish Government’s strategy on tackling alcohol misuse, Changing Scotland’s Relationship with Alcohol: A Framework for Action.The measures in the Bill1 are as follows—

  • minimum pricing, in the pursuance of reducing alcohol consumption;

  • further restrictions on off-sales promotions and promotional activity;

  • a requirement for an age verification policy;

  • provisions concerning the modification of licence conditions;

  • provisions in respect of assessing the impact of off-sales to people under 21;

  • provisions in respect of a social responsibility levy.

Scottish Government consultation

3. All of the areas covered by the Bill were included in the Scottish Government’s consultation, Changing Scotland’s relationship with alcohol: a discussion paper on our strategic approach, published for consultation in June 2008. The consultation set out a range of proposals and ideas to address the growing trend of alcohol misuse and received 259 responses from individuals and 207 responses from organisations. In addition, two MSPs submitted the results of consultations that they had carried out with constituents; the Scottish Prison Service provided the views of prisoner and prison service staff; East Renfrewshire Council and Dundee Drug and Alcohol Action Team submitted the views of young people in their area; Young Scot provided the results of a survey and of focus groups that they held on behalf of the Scottish Government, and Scottish Government ministers also received 53 letters or e-mails on the subject.

4. As part of the consultation process, the Scottish Government also held a Youth Summit to gather views on alcohol and its impacts on young people. The Government commissioned an analysis of the written responses from Hexagon Research and Consulting.

Concurrent legislative proposals

5. The Criminal Justice and Licensing (Scotland) Bill, introduced by Kenny MacAskill MSP, Cabinet Secretary for Justice, on 5 March 2009 and referred to the Justice Committee as lead committee, also contained provisions relating to assessing the impact of off-sales to people under 21 and to a social responsibility levy. On 24 March 2009, the Scottish Government announced its plans to introduce the Alcohol etc. (Scotland) Bill and, consequently, lodge amendments to remove sections 129 – sale of alcohol to persons under 21 etc. – and 140 – licensed premises: social responsibility levy – of the Criminal Justice and Licensing (Scotland) Bill at Stage 2.

Committee consideration

6. The Committee would like to record its thanks to those who gave evidence to, or otherwise participated in, its inquiry into the general principles of the Bill.

Formal evidence

7. The Committee issued a call for written evidence on 26 November 2009, with a closing date of 20 January 2010. 173 written submissions were received in response to the call for evidence. The Committee subsequently agreed the following programme of oral evidence sessions—

10 February 2010
Dr Petra Meier, Senior Lecturer in Public Health, School of Health and Related Research, University of Sheffield

24 February 2010
Gary Cox, Head of Alcohol Licensing Team, Alison Douglas, Head of Alcohol Policy Team, Mike Palmer, Deputy Director for Public Health, Marjorie Marshall, Economic Adviser, Rachel Rayner, Senior Principal Legal Officer, and Dr Lesley Graham, Associate Specialist, Public Health Division, Scottish Government;

Ben Read, Managing Economist, Centre for Economics and Business Research;

Prof Anna Dominiczak OBE, British Heart Foundation Professor of Cardiovascular Medicine, University of Glasgow, and Prof John Beath, Professor of Economics, University of St Andrews, Royal Society of Edinburgh.

3 March 2010
Major Dean Logan, Addictions Services Officer, The Salvation Army;

Tom Roberts, Head of Public Affairs, Children 1st;

Bruce Thomson, Assistant Regional Director for Dependency Services, Aberlour Child Care Trust;

Margaret McLeod, Policy and Information Manager, Youthlink Scotland;

Liam Burns, President, National Union of Students in Scotland;

Dr Peter Rice, Consultant Psychiatrist, British Medical Association Scotland;

Dr Bruce Ritson, Chair, Scottish Health Action on Alcohol Problems;

Dr Emilia Crighton, Chair of the Scottish Committee, UK Faculty of Public Health Medicine;

Jack Law, Chief Executive, Alcohol Focus Scotland;

Carolyn Roberts, Head of Policy and Campaigns, Scottish Association for Mental Health

10 March 2010
John Beard, Chief Executive, Whyte & Mackay Ltd;

Mike Lees, Managing Director, Tennent Caledonian Breweries;

Gavin Hewitt, Chief Executive, Scotch Whisky Association;

Bob Price, Policy Adviser, National Association of Cider Makers;

David Poley, Chief Executive, The Portman Group;

Fergus Clark, Scottish Member, The Society of Independent Brewers;

Liz Macdonald, Senior Policy Officer, Consumer Focus Scotland;

John Drummond, Chief Executive, Scottish Grocers' Federation;

Patrick Browne, Chief Executive, Scottish Beer and Pub Association;

Paul Waterson, Chief Executive, Scottish Licensed Trade Association;

Paul Smith, Executive Director, NOCTIS - The Voice of the Nighttime Economy;

David Paterson, Scottish Affairs Manager, Asda Group Ltd;

Tony McElroy, Corporate Affairs Manager, Tesco plc;

Richard Taylor, Director of Corporate Affairs, Wm. Morrison Supermarkets plc;

Nick Grant, Head of Legal Services, Sainsbury's plc;

John McNeill, Regional Chief Officer, Scotland, Northern Ireland and Isle of Man, The Co-operative Group Ltd

17 March 2010
John Beard, Chief Executive, Whyte & Mackay Ltd;

Patrick Shearer, President, and Andrew Barker, Assistant Chief Constable, Association of Chief Police Officers in Scotland;

Derek McGowan, Licensing Standards Officer, City of Edinburgh Council;

Mairi Millar, Clerk to the Licensing Board, Glasgow City Council;

Michael McHugh, Chair, West Dunbartonshire Licencing Forum;

John Loudon, Convener of the Licensing Law Subcommittee, and Jim McLean, Convener of the Competition Law Subcommittee, Law Society of Scotland;

Chris Jenkins, Head of Competition Advocacy, Office of Fair Trading

23 March 2010
Michel Perron, Chief Executive, Canadian Centre on Substance Abuse;

Ian Faris, President and Chief Executive, and Ed Gregory, Research and Analysis Manager, Brewers Association of Canada;

Jeff Newton, President, Canada’s National Brewers;

Kathy Klas, Director of Sector Liaison Branch, Alcohol and Gaming Commission of Ontario;

Patrick Ford, Senior Director for Policy and Government Relations, and Elizabeth Kruzel, Liquor Control Board of Ontario.

24 March 2010
Nicola Sturgeon MSP, Cabinet Secretary for Health and Wellbeing, Gary Cox, Head of Alcohol Licensing Team, and Rachel Rayner, Senior Principal Legal Officer, Scottish Government.

5 May 2010
Nicola Sturgeon MSP, Cabinet Secretary for Health and Wellbeing, Gary Cox, Head of Alcohol Licensing Team, Alison Douglas, Head of Alcohol Policy Team, Rachel Rayner, Senior Principal Legal Officer, and Marjorie Marshall, Economic Adviser, Scottish Government.

8. Extracts from the minutes of all meetings at which the Bill was considered are attached at Annexe A. Where written submissions were made in support of oral evidence, they are reproduced, together with the extracts from the Official Report of each of the relevant meetings, at Annexe B. All other written submissions are included at Annexe C.

The international dimension

9. In anticipation of the Bill’s introduction, the Committee requested that comparative international evidence on minimum pricing for alcohol sales be gathered. Several international examples of pricing policy as a tool for delivering on public health objectives in relation to alcohol-related disease, anti-social behaviour and longer term health strategy were examined. A desk-based research exercise was undertaken based on these examples to evaluate their potential relevance for the Committee’s scrutiny of the Bill. This included discussions with relevant experts in the target countries.

10. The research revealed that the only country that operated any form of minimum pricing on alcohol was Canada, where a model called “social reference pricing” operates in eight out of the ten provinces. In light of this, the Committee agreed to include an oral evidence session via video-conferencing with relevant witnesses in Canada as part of its programme of formal evidence-taking. This session was held on 23 March 2010, as noted above.

11. The Committee also noted from the research that Finland and France appeared to offer interesting examples of significant changes in alcohol consumption following changes in policy. Finland appeared to offer an insight into the effect of large changes in alcohol taxation on consumption and health; France appeared to offer an insight into non-price based policy approaches.

12. In light of this research, the Committee agreed that a delegation of the Committee should undertake a fact-finding visit to Finland and France to inform formal oral evidence-taking. A note of the visit is included at Annexe D.

Reports from other committees

13. The Financial Memorandum was scrutinised by the Finance Committee, which sought written evidence from affected organisations, took oral evidence from affected organisations followed by oral evidence from the Scottish Government Bill team and then reported to the Health and Sport Committee. The report is attached at Annexe E. The provisions within the Bill for making subordinate legislation were considered by the Subordinate Legislation Committee. Its report to the Health and Sport Committee is attached at Annexe F. These reports are discussed in detail later in this report.

Part 1 – pricing of alcohol

Background

Minimum price of alcohol

14. Section 1(2) of the Bill would amend the Licensing (Scotland) Act 2005 (“the 2005 Act”) to introduce a further mandatory condition of premises and occasional licences granted under that Act. The condition would be that alcohol must not be sold on the premises at a price below the minimum price. This section would also require that, where alcohol were supplied along with other products or services – for example, where a bottle of beer were packaged with and sold with a branded glass or where a bottle of wine were sold with food as part of a “meal deal” – the minimum price would be the minimum price that would apply to the alcohol if sold on its own, with no account taken of the non-alcohol elements of the package.2

15. Section 1(2) also sets out the formula by which the minimum price would be calculated as minimum price per unit (MPU) x strength of the alcohol (S) x volume of the alcohol in litres (V) x 100. The Explanatory Notes on the Bill set out a number of examples of minimum prices for different beverages calculated using the formula—

“For example, if the minimum price per unit was set at 40p per unit of alcohol:

(a) the minimum price for a standard sized bottle of spirits at 37.5% ABV would be £10.50 (0.40 x 37.5/100 x 0.7 x 100 = £10.50),

(b) the minimum price for a 500ml super-strength can of beer at 9% ABV would be £1.80 (0.40 x 9/100 x 0.5 x 100 = £1.80),

(c) the minimum price for a standard size bottle of wine at 12.5% ABV would be £3.75 (0.40 x 12.5/100 x 0.75 x 100 = £3.75),

(d) the minimum price for a case of 24 440ml cans of beer at 4% ABV would be £16.90 (0.40 x 4/100 x 0.440 x 24 x 100 = £16.90),

(e) the minimum price for a 2 litre bottle of strong cider at 6% ABV would be £4.80 (0.40 x 6/100 x 2 x 100 = £4.80),

(f) the minimum price for a 25ml measure of spirits at 37.5% ABV would be 38 pence (0.40 x 37.5/100 x 0.025 x 100 = £0.375),

(g) the minimum price for a 275 ml pre-mixed spirit and mixer at 5% ABV would be 55 pence (0.40 x 5/100 x 0.275 x 100 = £0.55). Note that the addition of a mixer does not affect the minimum price,

(h) the minimum price for a strong pint of lager at 5% ABV would be £1.136 (0.40 x 5/100 x 0.568 x 100 = £1.136)”3

16. The Scottish Ministers would have the power to specify the minimum price per unit by order subject to the affirmative resolution procedure.

Minimum price of packages containing more than one alcoholic product

17. Under section 2 of the Bill, the price of packages containing two or more alcoholic products would have to be equal to or greater than the sum of the prices at which each product was for sale. This provision would only apply where each alcoholic product in the package was available for sale on the premises. The effect of this provision would be that a retailer could not both sell an alcoholic product individually and offer a discount to the buyer for buying a package containing a multiple of alcoholic products that included that product. The Explanatory Notes give the following examples—

“For example, if a bottle of wine is sold at £4, then a retailer would not be able to sell a package of 2 of those bottles for less than £8. If one bottle of wine is sold for £4 and another bottle of wine is sold for £4.50, a retailer would not be able to sell a package of one of each of those bottles for less than £8.50.

“Similarly, a case of 24 440ml cans of beer may not be sold at a price less than the cost of buying 24 of those cans (provided that individual 440ml cans of that beer were available for sale on the premises).”4

18. The Bill provides that, where bottles or cans were packaged in a case, the product would be deemed to be the bottle or can and its contents, not the case. This would mean that a pre-packed package containing multiples of an alcoholic product would not be a separate product but a package potentially subject to this provision. As with the general provision on the minimum price of alcohol, the packaging of the alcohol with non-alcoholic products would not affect the rule.

Extent of the evidence base

Policy Memorandum – Sheffield study

19. In its Policy Memorandum on the Bill, the Scottish Government refers to research carried out by the School of Health and Related Research (“ScHARR”) at the University of Sheffield, namely the Independent Review of the Effects of Alcohol Pricing and Promotion5 for the UK Government and the Model-Based Appraisal of Alcohol Minimum Pricing and Off-Licensed Trade Discount Bans in Scotland6 for the Scottish Government. The Policy Memorandum draws attention to the following conclusions of the ScHARR work (“the Sheffield study”)—

“the model showed a strong and consistent link between the price of alcohol and the demand for alcohol. Increasing the price of alcohol is estimated to reduce consumption and alcohol-related harm.

“the model demonstrated a link between price increases, reduced consumption and subsequent reductions in chronic and acute health harms, including cancers, stroke, accidents, injuries and violence.

“minimum pricing targets price increases at alcohol that is sold cheaply. Cheaper alcohol tends to be bought more by harmful drinkers than moderate drinkers. So a minimum pricing policy might be seen as beneficial in that it targets the drinkers causing most harm to themselves and society. Studies also show that cheaper alcohol is also attractive to young people.

“‘moderate drinkers’ (i.e. those who drink within sensible drinking guidelines) are estimated to be only marginally affected, simply because they consume only a moderate amount of alcohol and also because they do not tend to buy as much of the cheap alcohol that would be most affected by minimum pricing.

“although the driver for minimum pricing is the protection and improvement of public health, the Scottish Government notes that while there is an estimated decrease in sales volume, that may be more than offset by the unit price increase, leading to overall increases in revenue from alcohol sales.

“the economy is likely to benefit through a reduction in sick days per year for all categories of drinker (moderate, hazardous and harmful) and less unemployment among harmful drinkers.”7

The Sheffield study - methodology

20. A written submission from ScHARR explained the methodology of the Sheffield study—

“As part of the study, we researchers examined the potential effects of different minimum pricing levels on patterns of alcohol consumption and the resulting impact on alcohol-related health, crime, and workplace problems in Scotland.

“To compile the report, we analysed over 20 separate policy scenarios, including setting a range of minimum prices per unit of alcohol, a total discount ban in off-licences and supermarkets and combinations of the two strategies. The research examined how policies affect alcohol purchasing and consumption by different population groups, including moderate, hazardous and harmful drinkers both in the on-licence (such as pubs, clubs and restaurants) and the off-licence (such as supermarkets) sectors.”8

21. The submission went on to explain that most of the modelling was based on an analysis of existing available Scottish data sources on consumption and harms—

“For example – via the Scottish Health Survey – the model includes the patterns of consumption for over 11,500 people in Scotland; and – via the Expenditure and Food Survey – individual alcohol purchases in Scotland between 2001/02 and 2005/06. Scottish data on crime, alcohol attributable disease and hospitalisations, and workplace harms were used. Whilst we have checked that our findings are consistent with what is known about alcohol policy internationally, a lot of effort has gone into ensuring that wherever possible the data underpinning the model are both recent and Scotland-based.”9

Data underpinning the Sheffield study

22. Dr Petra Meier, senior lecturer in public health at ScHARR and principal investigator for the Sheffield study, was asked about the data used in the modelling and, in particular, about the assumptions based on data from countries other than Scotland. Dr Meier responded that it would have been preferable to have Scottish data on everything and that “substantial efforts” had been made to take into account all the available Scottish health data, crime data, expenditure on food data, survey data on purchasing and Scottish consumption data. She added that ScHARR had been commissioned by the Scottish Government to—

“… take into account even more Scottish data, as they have become available, such as the 2008 Scottish consumption data. The expenditure and food survey is going to be validated according to Scottish Nielsen data—purchasing data from Nielsen that are just on Scotland—to see whether that information holds up. We have new data on crime and health conditions—a newer period of data. We are just modelling that at the moment.”10

23. She added that ScHARR had thought “long and hard” about how best to approach the data and had been “open” about where assumptions had been made—

“The work went through various rounds of peer review and people generally agreed that our assumptions were the best that could have been made. On occasions, people suggested alternatives, which we used as sensitivity analyses. For example, when people were not happy with the econometrics that we used, we used alternative evidence from Chisholm and from Huang, who did a previous UK study—I think that it was for HM Revenue and Customs. We checked how sensitive our model was to alternative assumptions, and although there were some variations we generally found that it was not far out in terms of the scale of effect.”11

24. The report of the re-run of the Sheffield study, Model-based Appraisal of Alcohol Minimum Pricing and Off-licensed Trade Discount Bans in Scotland Using the Sheffield Alcohol Policy Model (V 2):– An Update Based on Newly Available Data, (“the revised study”) was made available to the Committee on 21 April 2010. According to the report, it used those datasets that had become available since the original Sheffield study—

  • New consumption data from the Scottish Health Survey (SHeS) and Scottish Schools Adolescent Lifestyle and Substance Use Survey (SALSUS) had become available for 2008. The data in the previous model related to 2003 for SHeS and 2006 for SALSUS.

  • The Scottish Government had also procured market research data on the 2008/09 price distribution of off-trade alcohol (in terms of ethanol content) in Scotland from The Nielsen Company.

  • New mortality data was available for 2008.

  • Police-recorded crime statistics and Scottish Crime and Justice Survey (SCJS) data had become available for 2008-09.

  • The requirement of this research project was to update the previous Scotland model with the new data to provide revised estimates of the effects of current proposals for minimum pricing and prohibition of off-trade discounting. The technical details of the methodology have not been changed. Therefore the methods section (Chapter 2) of the previously published report was not reproduced.

25. The revised study stated that it updated the previous model with new data insofar as it was available, using the same methodology to analyse the same set of policies.

26. The Scottish Parliament Information Centre produced a Comparison Paper on the Sheffield Alcohol Modelling Reports12. This paper set out side-by-side, where results had changed and as they had been stated in the Sheffield study and in the revised study, those results of the modelling for ‘scenario 4’ – the application of a minimum price per unit of 40p; and ‘scenario 15’ – the application of a minimum price per unit plus a discount ban, thereby re-stating the information supplied to the Committee by the Scottish Government, for the purposes of comparison. It should be noted that, according to the revised study, these results indicate estimated consumption and harm impacts across all policies for the total population of Scotland.

‘Scenario 4’ – 40p Minimum Price per Unit

 

Previous Model

New Model

Overall Weekly Consumption

-2.7%

-2.3%

Change in Units per Year (all drinkers)

-22

-18

Change in Units per Year (harmful drinkers)

-192.4

-180.3

Change in Units per Year (moderate drinkers)

-5.2

-2.9

Alcohol Attributable Deaths (first year)

-40

-26

Alcohol Attributable Deaths (ten years)

-210

(10 in moderate drinkers

60 in hazardous drinkers

140 in harmful drinkers)

-119

(6 in moderate drinkers

51 in hazardous drinkers

62 in harmful drinkers)

Alcohol Attributable Morbidity (year 1)

-631

(-478 acute illnesses

-153 chronic illnesses)

-500

(-410 acute illnesses

-90 chronic illnesses)

Hospital Admissions (year 1)

-800

-640

Hospital Admissions (year 10)

-3,600

-2230

Healthcare Service Costs (year 1)

-£3.5m

-£2.8m

Value of QALYs gained

+£8.6m

+£7.3m

Overall Offences

-1,100

-1,400

Value of Harm Avoided (Victim Quality of Life)

£0.7m

£0.7m

Direct Costs of Crime

-£1m

-£1.2m

Unemployment

-800

-730

Sick Days

-11,600

-11,800

Societal Value of Harm Reductions

£540m

£398m

Cost Impact to Drinkers (per annum)

Harmful Drinkers - £102

Hazardous - £42

Moderate - £7

Harmful Drinkers - £85

Hazardous - £37

Moderate - £5

Over all increased spend by consumers
(per annum)

£80m

(split ‘broadly equally’ between on/off trade)

£68m

(split 63% off trade: 37% on-trade)

Overall Revenue to the Treasury

-£4m

-£2.4m

‘Scenario 15’ – 40p Minimum Price per Unit + Discount Ban

 

Previous Model

New Model

Overall Weekly Consumption

-5.4%

-5.1%

Change in Units per Year (all drinkers)

-44

-39.6

Change in Units per Year (harmful drinkers)

-293.3

-296.4

Change in Units per Year (moderate drinkers)

-9.88

-9.1

Alcohol Attributable Deaths (first year)

-70

-59

Alcohol Attributable Deaths (ten years)

-370

-261

Alcohol Attributable Morbidity (year 1)

-1230

(970 acute illnesses

260 chronic illnesses)

-1180

(990 acute illnesses

190 chronic illnesses)

Hospital Admissions (year 1)

-1,600

-1,490

Hospital Admissions (year 10)

-6,300

-4,850

Healthcare Service Costs (year 1)

-£6.9m

-£6.6m

Value of QALYs gained

£17.5m

£17.4m

Overall Offences

-3,200

-3,100

Value of Harm Avoided (Victim Quality of Life)

£1.9m

£1.8m

Direct Costs of Crime

-£2.7m

-£2.7m

Unemployment

-1,200

-1,220

Sick Days

-29,000

-30,500

Societal Value of Harm Reductions

£950m

£824m

Cost Impact to Drinkers (per annum)

Harmful drinkers - £137

Hazardous - £58

Moderate - £11

Harmful drinkers - £126

Hazardous - £55

Moderate - £10

Over all increased spend by consumers
(per annum)

+£120m (split 55% off trade: 45% on trade)

+£113m (split 71% off trade: 29% on trade)

Overall Revenue to the Treasury

-£12m

-£9.9m

Econometric modelling as a decision-making tool

27. Dr Meier was also asked about the soundness of using modelling as an alternative to evidence when making public policy decisions. In response, she explained that a model had been used to “to project what would happen” because the policy had not been introduced. Explaining that it was a prediction rather than a post-hoc observation, she described the model as being “like the weather forecast”. She went on—

“We can study what happens when prices change and make an assumption about how prices would change under a minimum pricing policy. We can consider what changes in consumption we might expect to see, and relate those to various factors. The international and UK literature is important in that respect, as we need to consider how much of the harm from alcohol can be attributed to consumption.”13

28. Dr Meier also stated that the Sheffield study had undergone “various rounds of peer review”14. Scottish Government officials commented further—

“The Sheffield study has been talked about as if it is almost entirely unconnected to the evidence base, whereas it very much builds on the evidence base. The study has been peer reviewed and is published this month in Addiction, which is an international journal on substance misuse. Wagenaar, who is one of the critical people in the field and who has done much of the modelling around elasticities, said that the Sheffield study is "exactly the type of translational science needed by policy makers, bridging basic research results to policy practice", and that its theory is "consistent with a very large body of empirical research, providing a strong indicator of validity of the models used."”15

29. Scottish Government officials also stated that the Sheffield study built on the international evidence base on price, consumption and harm but went “a stage further”16. They described it as a “much more sophisticated model”17 than had hitherto been developed—

“… it is recognised internationally as being a very strong addition to our understanding and knowledge in the area.”18

30. Prof Anna Dominiczak OBE, British Heart Foundation Professor of Cardiovascular Medicine, University of Glasgow, commented on the value of peer review—

“The Royal Society of Edinburgh—and I as an academic—think that researchers have invented nothing better than peer review, which involves other researchers who might disagree with you looking at your data and deciding whether they are robust enough to be published. You simply send your research to the editor of an appropriate journal and he sends it out for peer review. I do not want the committee to leave the meeting thinking that peer review is not the gold standard in any academic endeavour. It is research with a capital R.”19

31. Professor John Beath, Professor of Economics, University of St Andrews, and a representative of the Royal Society of Edinburgh, was also asked about the robustness of the science of econometrics. In response, he described it as an “old science” with some “eminent practitioners”. He explained that it had grown out of statistics and involved the application of statistical methods to economic data—

“In that sense, it has a robust, strong and long lineage; the Sheffield modellers are part of a long tradition of applied econometricians.”20

32. He acknowledged that econometrics relied on having a sufficient number of data points and sufficient richness in the data set and went on to state that econometric models had been “extraordinarily” useful—

“For example, the minimum wage legislation relied on and, in fact, required econometric work to assess its impact on labour supply and the overall level of employment, and discussions on the right level of income tax to set also require models of demand and supply.”21

33. Dr Emilia Crighton, Chair of the Scottish Committee, UK Faculty of Public Health Medicine, also defended the practice of modelling—

“If we are victims of modelling on the roads and in weather forecasts, we are victims of modelling on the minimum wage. Modelling is a way of exploring the what-ifs when complex reality exists. Modelling is widely used and it has been used in positive ways in health.”22

34. She added that “first and foremost, modelling can be seen as evidence” as an alternative in situations where it would be “unethical” to use randomised controlled trials. She explained that the “best” way to achieve that is to use mathematics, building a model of the reality of using different interventions.23

35. Dr. Peter Anderson, an international public health consultant, expert on alcohol and tobacco policy and co-author of Alcohol in Europe – A Public Health Perspective, a report commissioned by the European Commission, submitted written evidence supplementary to the oral evidence session with Dr Meier. He stated—

“The Sheffield modelling study for Scotland (similar to the modelling studies for the London Department of Health and NICE) is recognized as an exceptional piece of work from a scientific point of view that is well-based on evidence. Such modelling approaches are common practice in public health and are recognized as robust.”24

36. However, Professor Beath went on to recognise that modelling could produce results that are consistent with the data but nonetheless not necessarily realistic. In relation to the Sheffield study numbers for hazardous and harmful drinkers showing rather more responsiveness than those for moderate drinkers, Professor Beath posited that the finding was illogical, intuitively speaking, but, psychologically speaking, explicable—

“Let us consider whether the model was estimated in a period when alcohol prices were falling and let us compare moderate and harmful drinkers. The response of a moderate drinker to a fall in price will be to have an extra glass, but the response of a harmful drinker to the sudden bonanza of a lower price might be to splurge, so we would expect to see a larger response. If we then put the price change into reverse and push up prices, the harmful drinkers will have become more addicted to the drug and will find it—for medical reasons—particularly difficult to cut back on consumption.”

37. He argued that, as per-unit minimum pricing is “all about higher prices”, it was much more realistic to expect the second scenario – which, he believed, had not been estimated in the model – and an inelastic response to a rise in price.

38. Some witnesses also raised questions about the assumptions made by the Sheffield study in respect of the potential for increased sales across borders and over the internet; these are discussed under the heading Cross-border and internet sales below.

Responses to the Sheffield study

39. The Centre for Economics and Business Research (CEBR) produced a report entitled Minimum Alcohol Pricing: A targeted measure? Special Report for Scotland25. According to the report’s Executive Summary, it was an independent review of the case for the introduction of minimum alcohol pricing in Scotland, conducted in the light of the Sheffield study and the publication of the Alcohol etc. (Scotland) Bill. Ben Read, Managing Economist at the CEBR and co-author of its report, stated that the CEBR had applied some “pretty rigorous sense checks” to the results of the Sheffield study and that those checks had suggested that the results of the Sheffield study were not “robust”.26

40. Asked whether the CEBR’s reports were peer reviewed, Ben Read described the CEBR’s profitable trading record providing professional advice to businesses since 1993—

“If our advice was always rubbish, businesses would not come to us and we certainly would not have been trading profitably since 1993—we would have gone out of business some time ago. The type of review that we undergo is more to do with business decisions and whether the calls that we make and the advice that we give are robust.”27

41. Turning to a specific example where the CEBR’s sense checks found the Sheffield study’s finding to be questionable, Ben Read cited the Sheffield study’s prediction that there would be a much greater demand response to a given price change among hazardous and harmful drinkers than among moderate drinkers. He suggested that, because of “dependency issues and social factors”, heavier drinkers would be expected to be less responsive to price changes than moderate drinkers.28

42. On the other hand, Dr Peter Rice, a consultant psychiatrist representing the British Medical Association Scotland, questioned the assumption that heavier drinkers would be expected to be less responsive to price changes. He stated that members of his treatment group had been “price sensitive”.29 He also argued30 that per-unit minimum pricing would benefit heavy drinkers by “ensuring that fewer people get into the situation” and by “making the journey easier” for those trying to get out of the situation—

“Cheap alcohol is drunk predominantly by people with alcohol problems, so taking action on it would predominantly affect heavy drinkers.”31

43. Ben Read went on to argue that the results of the Sheffield study were not, in any case, particularly persuasive—

“Members may believe our results, those of the University of Sheffield, something in between or something completely different, but my reading is that the economic case for minimum pricing is not particularly strong in any case, even if one takes the University of Sheffield results into account. The financial costs to consumers that its modelling work suggests outweigh the economic benefits that it has calculated. The case for the Government is pretty much neutral. A bit of tax revenue would be lost, but a bit of money would be saved in the health service and on crime. Companies, which are the third party, would benefit. It appears that the only thing that would be done would be to increase the profitability of companies. That is the only reason why the economic case might stack up, but that does not seem to me to be the objective of the policy.”32

Scottish Government

44. Asked about the extent of the evidence base for the per-unit minimum pricing policy, the Cabinet Secretary affirmed that there was “clear international evidence of a relationship between affordability, consumption and harm”33 and stressed that there was “very strong” evidence from a “range of studies in European countries, the United States, Canada, New Zealand and other countries about the relationship between price and consumption”. She added that she believed that “people accept that link”.34

45. Turning to the Sheffield study, which she described as having “modelled what the effect of changes in consumption might be, based on various pricing options”, she defended the modelling approach as being “well respected” and giving an “important and significant indication of what the effect of per-unit minimum pricing would be on consumption, on health harms, on crime and on productivity”. She added that the Sheffield study and Dr Meier’s oral evidence to the Committee had been “clear” about the limitations of the study—

“… it is a modelling exercise, not an evaluation of a policy that is in place in any country. Nevertheless, it is an extremely valuable contribution to the evidence base, and it gives us a strong indication of the effect of the policy.”35

46. In relation to the Sheffield study’s credentials in the academic world and the critique produced by the CEBR, Scottish Government officials made the point that the model had been peer reviewed by well-respected experts in health economics, who had “supported the Sheffield findings rather than the CEBR perspective” and “agreed with the Sheffield response” that the CEBR had “picked particular values for considering the sensitivity to price of different drinker groups but used them wrongly”.36 It was further commented—

“In fact, the Sheffield study, the rebuttal and the papers that were published subsequently point out that alcohol and the alcohol market are complex. We have different types of alcohol, different types of drinker and different locations such as the on-trade and the off-trade. The Sheffield model, in comparison with the work that the CEBR did, is the only one that takes account of all those multiple layers of difference.”37

Conclusion

47. The Committee wishes to emphasise that the Sheffield study – which formed part of the Regulatory Impact and Competition Assessment prepared for this Bill and which served as a benchmark against which all of the evidence taken by the Committee was tested – was prepared using data that dated back as far as 2003. The Committee wishes further to highlight that the revised study – conducted using recent figures, from 2008-09 – was made available to the Committee after its evidence-taking was complete and the Committee has, consequently, been unable to test its findings with witnesses.

48. In respect of the value of econometric modelling as a decision-making tool, the Committee recognises the robustly argued defence by representatives of the academic and medical communities and the Scottish Government. The Committee notes the approach’s scientific credentials based on econometric modelling rather than on empirical data. Some members of the Committee are particularly concerned about the interpretation that an increase in price will result in a fall in consumption; in respect of this point, the Committee notes, on the one hand, Professor Beath’s comments that, following a period of cheap availability of alcohol, the heavy drinker may have become more dependent and therefore may have an inelastic response to a rise in price. On the other hand, the Committee also notes Dr Rice’s comments that members of his treatment group had been price sensitive.

49. The Committee notes the CEBR’s challenges to the findings of the Sheffield study but also notes that the CEBR itself recognises that its work is entirely intuitive rather than scientific; was produced to commission, and, in keeping with the field in which the CEBR works, was not subject to peer review. That said, the Committee finds the points raised by the CEBR have some merit. In particular, issues raised by the CEBR on unintended consequences of per-unit minimum pricing not covered by the University of Sheffield report are worthy of further investigation.

Cross-border and internet sales

50. Asked about the conclusions regarding economic behaviour to be drawn from the Sheffield study, Professor Beath suggested that other, “non-model” issues were not factored in to the Sheffield study—

“… substantially increasing the price of a particular good encourages people to consider other ways in which to get that good, such as through the internet or cross-border shopping. What happens in Northern Ireland and the Republic of Ireland is an excellent example—there are even rural routes across the border and a lot of cross-border trade.”

51. He suggested that such issues were “extraordinarily difficult to model” as, although they were believed to exist, it was difficult to judge their scale.

52. David Paterson, Scottish Affairs Manager, Asda Group Ltd, also suggested that modelling on per-unit minimum pricing could fail to “deliver real-world results” as it had not taken into account cross-border trade, where there might be a price differential, and internet sales. He described Asda Group Ltd’s “specific experience” of cross-border trade—

“In Northern Ireland, our store in Enniskillen, which is on the border, is the number 1 performing store in our UK chain and the number 6 performing store in the global Walmart chain. That is primarily driven by differences in price. The bulk of the customers in that store drive from Dublin, which is an hour and 40 minutes away, and a third of the transactions are in euros. The difference between the price of beers, wines and spirits in the centre of Dublin and the price over the border in Northern Ireland is around 25 per cent.”38

53. In relation to internet sales, he stated that Asda Group Ltd did not accept the Scottish Government’s position that internet sales present a “relatively small” issue—

“Internet sales are a growing part of our business. We believe that our home shopping business will more than double in the next five years and we are seeing very high, double-digit, year-on-year growth in internet sales. We are really concerned that if you set up that price differential, you will not get the reductions in consumption that you foresee, because other methods of sales will come.”39

54. John Drummond, Chief Executive of the Scottish Grocers' Federation suggested that “unintended consequences” of per-unit minimum pricing could include—

“… an extension of cross-border trading, the advancement of illicit trade through the trading operations of white van man and increased internet trading of products dispatched from south of the border. All those would impact on small stores, particularly in the south of Scotland and conceivably in central Scotland. Communities could be affected if local stores were put into jeopardy as a result of the loss of business.”40

55. ACPOS representatives were asked whether they anticipated a rapid increase in the import of cheap alcohol from England if a minimum price per unit were introduced in Scotland. Chief Constable Pat Shearer stated—

“A lot depends on the differentials, but if you set that issue against the whole volume that can be pushed out of the market through supermarkets and off-sales, or in the on-trade, it is relatively insignificant. It could become attractive for some people to get involved in peddling alcohol, but we and HM Revenue and Customs would start to focus on that. It has never been a major issue, but we would have to assess whether it was becoming one.”41

56. Assistant Chief Constable Andrew Barker commented that similar questions had been asked in relation to the current position with, for example, imported alcohol. He stated that ACPOS had recently scoped the issue with all eight Scottish forces and that there was no indication that such supplies were an issue

I do not know whether opportunities for that would develop. In considering the nature of alcohol consumption as a whole and what we support as an overall package to try to reduce alcohol consumption and its effects on our service provision and on our communities, my view is that it would be a small price to pay if we had to monitor and deal with issues as they arose.”42

57. Witnesses from Ontario, Canada, were asked about the Ontarian experience of cross-border sales. In response, it was explained that it had become less of a problem more recently but had previously been a problem, primarily in the 1980s, when some people felt that it was economically feasible to bring alcohol products across the border from areas, where it could be accessed at a lower price, and sell it illegally. It was explained that the amount of illegal beverage alcohol in Ontario had been “greatly reduced” as a result of a “concerted effort” on the part of the police and the Liquor Control Board of Ontario to enforce the law.43

58. They went on to explain that smuggling activity had been influenced as much as anything by changing exchange rates between Canada and the United States—

“Ontario has border crossings not only with the adjoining provinces of Manitoba and Quebec but with the states of Michigan, at Detroit, and New York, at Niagara Falls. Given the large volume of traffic on those border crossings and the fair degree of cross-border commerce, there will always be some volume of smuggling activity but … it has come down in recent years.”44

59. In relation to cross-border sales via the internet, it was explained that, under Canadian federal statute, each provincial liquor authority had delegated authority and served as the sole legal importer of beverage alcohol into the marketplace in its jurisdiction––

“… outside that jurisdiction, it is not legal to make a sale into Ontario—for example, from the United States or another province—unless the goods are first consigned to the Liquor Control Board of Ontario.”45

Scottish Government

60. In respect of cross-border sales, the Cabinet Secretary gave figures from the Irish Central Statistics Office which, she argued, showed “clearly” that alcohol was not the main driver of cross-border shopping between the Republic and Northern Ireland—

“In the past year, 16 per cent of households made at least one trip from the Republic to Northern Ireland to do the shopping; 80 per cent of them bought groceries, and 44 per cent of them bought alcohol while they were there. Perhaps more pertinently, the average spend on those shopping trips was €286; alcohol accounted for €32 of that, while €114 was spent on groceries.”46

61. She maintained that these figures showed that people bought alcohol while they were there but that the driver for that cross-border flow was the difference in value between the euro and sterling in the Republic and Northern Ireland, which made it cheaper for people to do their grocery shopping in Northern Ireland.47 She went on to add—

“Obviously, the police and customs officials will monitor such cross-border issues, as they do already. I refer members back to the chief constable's comments.”48

62. The Cabinet Secretary did not accept that internet sales presented a significant problem in relation to the outcomes envisaged by the Sheffield study. She acknowledged that the Bill would not apply to the price paid for alcohol ordered over the internet in Scotland in relation to deliveries dispatched from England; she added, however—

“… the judgment and the assessment is that the majority of people would not switch to internet sales from the current way that they buy alcohol because of the effect of minimum pricing.

I point members to the bigger picture. Minimum pricing is about trying to make a dent in the enormous toll that alcohol misuse is taking on our health, economy and levels of crime in Scotland. We should focus on the bigger picture, rather than try to magnify the potential downsides in order to distract attention from the very real upsides of the policy.”49

Conclusion

63. The Committee notes the points made by the Cabinet Secretary in relation to cross-border sales, consumer behaviour and trafficking. Although some members remain sceptical that these would not become problematic under per-unit minimum pricing, the Committee notes that the matter of illegal sales will continue to be dealt with by the police and HM Revenue and Customs. However, legal cross-border and internet sales will remain an issue.

64. The Committee is concerned by the Cabinet Secretary’s arguments in relation to internet sales. The Cabinet Secretary appears to be basing her judgment on how consumers would behave following implementation of per-unit minimum pricing on how they currently behave. Not only has consumer behaviour in relation to internet sales changed generally but the very existence of a minimum price per unit could act as a catalyst for accelerating internet sales.

Impact on low-income groups

65. Asked whether the University of Sheffield had undertaken any modelling to find out what people in lower income groups consumed, Dr Meier stated—

“…no separate modelling has been done by income group. Income is accounted for in the econometric model in terms of how people respond to price, but we were not asked to produce separate tables on low-income groups. That is something that could be done with the data.”50

66. Asked about the effect of the proposed policy on various income groups, Ben Read suggested that, within each income group, some would pay less and others would pay more but that the lowest-income groups would be the “most fundamentally affected”51. He elaborated on this point—

“We know that lower-income households, naturally, spend a hell of a lot less money on alcohol, in absolute terms, than middle and upper-income households, because they cannot afford to buy champagne, for instance, and they buy what is available within their budget. If lower-income households are consuming about the same in terms of units but are spending a lot less, they must be spending less per unit … This area warrants further research, but we have been trying to illustrate the point. There is an intuitive appeal to it: as I have said, people in lower-income households will buy not champagne but what they can afford—relatively cheap alcohol—if they want to drink at all.”52

67. He surmised that it was a “reasonable conclusion” to infer that those who spent less per unit for the alcohol that they drank would suffer the worst from a cost increase.53

68. The Canadian Centre for Substance Abuse also raised this point, stating—

“The main disadvantage of minimum pricing policies is that they are likely to be regressive in the sense of placing greater burden on those with limited incomes who are frequent heavy drinkers. We feel this is a valid concern and one that should be addressed by governments to ensure adequate funding for treatment and other social services—especially for economically and socially marginalized populations.”54

69. On the other hand, the Liquor Control Board of Ontario’s representative gave a different view, stating—

“… when a floor price is increased, the typical commercial activity that we see in the marketplace is not only an increase in the lowest-priced products but a corresponding lift in more expensive, premium products. That seems counter to the notion that the effects are regressive in some way.

70. The representative from Canada’s National Brewers – a representative organisation for Canada’s three largest domestic brewing companies, owners of the Beer Store, the largest private beer retail chain in Ontario – added that minimum prices were typically adjusted according to the inflation rate, such that they are kept constant in terms of absolute, or inflation-adjusted, dollars—

“It is not as if the increases in the minimum price exceed the inflation rate and therefore effectively reduce people's purchasing power.”55

71. Bruce Thomson, Assistant Regional Director for Dependency Services at the Aberlour Child Care Trust, also expressed concern about detrimental impact arising from the effects of the policy on low-income groups. He appreciated that, if consumption and therefore harm were to go down when price increased, that would be “very good for children growing up in problem-drinking families”. He went on, however—

“… if the problem is more intractable than that, so that a price rise does not reduce consumption but results in people paying more for alcohol—we are talking about families who already have very limited means—we are concerned about the impact of that on meeting children's basic needs for food, clothing and so on. We therefore said in our submission that we support the principle of minimum pricing but that its impact on families should be monitored to ensure that it works.”56

72. Speaking about an Edinburgh-based study conducted during a period of major change in tax-related price which outstripped cost-of-living changes, Dr Bruce Ritson, Chair, Scottish Health Action on Alcohol Problems (“SHAAP”), tempered the concerns on this issue, stating that the study had shown that the heaviest drinkers had responded by reducing their consumption significantly, with the level of associated harm also reducing significantly—

“They did not just carry on drinking at the previous level and pass on the cost to other family members. There was no evidence for that.”57

73. Liz Macdonald, Senior Policy Officer at Consumer Focus Scotland, also commented on the potential impact of the proposed policy on low income groups as an “obvious concern” of a consumer organisation.58 She acknowledged, however, evidence from the health lobby—

“… low-income communities suffer the greatest ill effects—there are much higher rates of liver disease in deprived communities, for example—so you also have to bear in mind the fact that people on a low income stand to benefit from reduced levels of social harm caused by alcohol.”59

74. She went on to caution against making assumptions about what people drink and assuming that low-income consumers always bought the value brand—

“If a moderate drinker who lives on a low income buys a bottle of whisky at Christmas, they might decide to buy a bottle of Grouse rather than Tesco's cheapest. That demonstrates that it is difficult to determine the impact of minimum pricing on low-income consumers. It is possible that minimum pricing will have the impact that we have discussed, so I agree that it would have been useful if the Sheffield study had provided more data about the impact on low-income consumers.”60

75. In a supplementary submission, which was not tested by the Committee in oral evidence, SHAAP provided the Committee with a paper prepared by Professor Anne Ludbrook looking at the distribution by price and income of alcohol purchased from off-sales.61 The key findings reported in the submission are set out below—

  • all income groups purchase low price off-sales alcohol;

  • the relationship between income group and the amount of alcohol purchased at the cheapest price (below 30p a unit) is not straightforward. Although the lowest income group buys more than the highest at this price, there is little difference between the middle income groups and the lowest;

  • at prices of 30p to 40p and 40p to 50p the amount purchased tends to increase with income;

  • middle-to-higher income groups are the main purchasers of alcohol priced between 30p and 50p;

  • for individual alcohol types (beer, lager, table wine and spirits), the lowest income groups purchase less than the average number of units below 30p and below 40p;

  • low income households are less likely to purchase off-sales alcohol at all.

Scottish Government

76. In supplementary written evidence62 to the Committee, the Cabinet Secretary acknowledged the Committee's interest in the impact on low-income groups and advised that officials were scoping what would be possible, given limitations on the data available. She undertook to keep the Committee informed of progress and likely timescales, in recognition of the Committee's desire for information to be available at the earliest opportunity.

77. In relation to the Ludbrook paper, the Cabinet Secretary first reminded members that it was a report independent of the Scottish Government; she went on to summarise the report’s findings as follows—

“… generally speaking, the report does state that the lowest two income deciles purchase more alcohol at less than 30p a unit than the highest two, but overall the relationship between the number of units purchased at less than 30p and income is not strong. At 30p to 40p, the number of units purchased increases with income up to decile 7, and the highest decile purchases more than the lowest. From 40p to 50p, there is a clear upward trend in purchasing as income increases.

In terms of averages, the report shows that the lower-income deciles exceed the average purchase of low-price alcohol only at prices of less than 30p.”63

78. In response to a suggestion that the paper showed the alcohol basket of the lowest three deciles to be predominantly made up of cheap drink and that per‑unit minimum pricing would therefore have a disproportionate effect on the lowest deciles because their purchasing would be limited by their income, the Cabinet Secretary committed to consider the point in detail but stated that that was not her understanding of the thrust of the report.64

79. Moving on to other aspects of the line of inquiry on the impact on low-income groups, the Cabinet Secretary explained that there was a “constraint” in terms of what the University of Sheffield was able to do as it was difficult to develop elasticities for different income groups in Scotland owing to the small sample sizes available in the data. She advised, however, that the Scottish Government’s health analytical services division had analysed the figures on consumption across income groups in the Scottish health survey in order to elaborate on the point about the socioeconomic impact—

“The analysis from the health survey concludes that, in the lowest income decile, 23 per cent do not drink at all and 57 per cent drink moderately, which means that 83 per cent of the lowest income decile either do not drink or drink below the recommended limits. That compares with only 7 per cent of the top decile that do not drink at all and only 60 per cent who drink moderately. Effectively, people on the lowest incomes are drinking less than people on higher incomes, which means that minimum pricing impacts on them less than it does on those with higher incomes.”65

80. She went on to explain that, in the harmful category, those in the lowest decile drank 85 units on average while those in the highest decile drank 60 units on average—

“That means that the harms are greatest among the lowest income groups, which is why they are five and a half times more likely to be admitted to hospital and 13 and a half times more likely to die from alcohol-related illnesses.”66

81. The Cabinet Secretary offered the following conclusion on the subject of any differential impact on different income groups—

“… effectively, it shows that minimum pricing will not impact adversely on the bulk of low-income people who do not drink or who drink moderately but that those who drink dangerously stand to benefit the most, because they are suffering the biggest harms at the moment.”67

Conclusion

82. The Committee has not yet tested either Professor Ludbrook’s paper nor the Cabinet Secretary’s response and has not been able to seek the views of other experts. The Committee intends to do so at Stage 2.

83. The Committee remains concerned about the level of evidence on the impact on low-income groups. The Committee notes that interpretations include suggestions that they will suffer the most, economically, and that they will benefit the most, in terms of health. The Committee believes that, thus far, there is insufficient information on this important issue. The Committee calls on the Scottish Government to prioritise work in this area in order to provide the Parliament with as much robust information as possible as the Bill progresses through the legislative stages. Further, should the policy become law, the Committee believes that this particular issue would have to be monitored extremely closely in order to determine exactly what the impact or impacts on low-income groups were and whether any remedial action should be taken. The Committee notes that there has been no modelling of the effect on this income group or indeed on any income group.

Developing a new Scottish public policy response

84. The Committee explored with witnesses issues surrounding the implementation of a policy for which there was limited empirical evidence.

85. According to Dr Ritson, the rarity of minimum pricing policies in operation in other countries, their differences to the policy proposed and the absence of evaluation, should not in itself be seen as an obstacle to implementing the policy—

“… I do not see why Scotland should be reluctant to be the first to try something new in public health. We have a long tradition of innovation in our public health measures. The smoking ban is one that comes to mind, but there have been others over the centuries. We should not be shy of going into minimum pricing in a major way just because we would be the first to do so.”68

86. Dr Crighton also commented on this point, arguing that the severity of the alcohol problem in Scotland called for new action—

“… [Scotland] has the fastest growing rate of deaths from chronic liver disease based on alcohol. We have the biggest problem. We have the local authorities with the five highest mortality rates among males because of liver disease in the UK … I work in Glasgow. I have five local areas there that have the highest mortality rates among males because of alcohol.

We cannot afford to sit back and see what others will do for us. We have a problem and we must find a solution. We have to be brave and find what will work best.”69

87. Tom Roberts, Head of Public Affairs at Children 1st, argued that there was nonetheless evidence to support the policy, stating that the charity saw minimum pricing as “only one way of tackling the issue”. He acknowledged that Finnish research showed that there was not an “exact link between price and consumption” but argued that there was enough evidence to suggest that, “as price changes, consumption habits change”. He stated that price was one important way of tackling the “real crisis in drinking”, which is why Children 1st had supported minimum pricing—

“To my mind, it is common sense that we should tackle price as one way of tackling people's consumption, just as, for a number of years, we have increased the price of cigarettes. That is not the sole reason that more people have stopped smoking, but it is one reason for that. People say that they are quitting smoking to save money; the NHS uses the money that people save from not smoking as one motivation to quit. That takes us back to the issue of the public health messages that are sent to parents about the impact of drinking on families. We should encourage people to look at its impact not only on behaviours and their children but on their pocket. That adds up to something that might start to make a dent on the problematic drinking that exists in this country.”70

88. Major Dean Logan, Addictions Services Officer at the Salvation Army, cited various studies dating from recently and as long ago as the 1980s that linked alcohol availability and price with public health. He concluded—

“As no country has ever trialled what the Scottish Government is proposing, it is always difficult to say what the effect will be. However, I think that enough of a body of evidence exists from over the years to say that price and availability are the two levers that can be used to affect alcohol consumption at a societal level.”71

89. Dr Peter Rice acknowledged that the Canadian model had not been evaluated as well as it should have been but also commented that, in general, there had not been the rises in alcohol-related harm in Canada that there had been in Scotland and suggested that, consequently, there were “lessons to be learned” from the Canadian model. He also supported Major Logan’s observations on the relationship between harm and price—

“There is a considerable evidence base on that, which has been well reviewed, meta-analysed and so on.”72

90. Specifically in relation to the minimum-pricing approach, Dr Rice stated—

“A peer-reviewed article published by Paul Gruenwald shows that changes to the cheapest floor prices of alcohol have a considerably bigger impact than across-the-board changes. Gruenwald's estimate is that a 10 per cent increase in the cost of the cheapest alcohol led to a more than 4 per cent reduction in overall alcohol consumption, whereas an across-the-board 10 per cent change led to a decrease of less than 2 per cent. The more it is looked at, the more it is recognised that floor price is what matters. There is an absolutely solid logic model that links price and harm. It shows that floor price is the most important price and its relationship to harm. That is the evidence base.”73

91. Witnesses from Canada recognised that there was “no direct evidence” to support the use of social reference pricing. Michel Perron, Chief Executive of the Canadian Centre on Substance Abuse, stated however that a number of studies had suggested that minimum pricing might be an effective way of mitigating the effects of the abuse of alcohol—

“We know that there is an elastic relationship between price and consumption—that the lower the price, the greater the consumption and, by extension, the harm. We are aware of egregious examples of alcohol prices being so low that they run contrary to the notion of a culture of moderation, which we have tried to cultivate in Canada.”74

92. He went on to describe minimum pricing as a “fairly inexpensive” method by which an immediate “threshold of engagement” can be created “between the Government and the people on beverage alcohol”. He questioned75, however, whether it was “reasonable to assume” a causal relationship between minimum pricing and reducing harmful drinking at the population level “could ever be shown”, given so many “confounding” influences—

“It is a challenge to establish a causal relationship between any social intervention or taxation policy and a particular behavioural effect. At best, we can look at an attribution of causality, as opposed to a direct conditioned response. The province in Canada that consumes the greatest amount of alcohol—Quebec, our French-speaking province—has the lowest reported harm. The issue is not so much consumption as the manner in which and the purpose for which alcohol is consumed. A level of sophistication is needed in alcohol policy; I know that members are seeking clarity in that area. Unfortunately, some of the evidence will remain equivocal. Despite the strong anecdotal evidence of a relationship, there will not be the level of causality that we would like to see.”76

Scottish Government

93. The Cabinet Secretary dismissed any argument that a per-unit minimum-pricing policy should not be introduced because of a lack of evidence of a per-unit minimum pricing system being in place anywhere in the world and, consequently, a lack of evidence that it would work—

“On that basis, we would never do anything. The fact that such a system is not in place anywhere in the world is the reason why we have undertaken modelling through the Sheffield study to give us the best estimate of what the impact would be, and why we will have to evaluate the effects when the system is in place. I believe that the harms that alcohol misuse does are such that we should be bold and prepared to innovate and to lead, which is what Scotland would do with minimum pricing. If we introduce minimum pricing, we should be proud of it.”77

Conclusion

94. The Committee has heard a variety of views on the principle of implementing an untried policy that is, therefore, not supported by empirical evidence: for some, it is innovative, bold and necessary; for others, it appears to be misdirected and unjustifiable. This diversity of feeling is shared by the Committee: some members are persuaded by the case for a minimum price per unit; others are not persuaded and are concerned at the scarcity of evidence that price increases, affecting particularly those in the lowest income deciles, will produce the desired result.

Setting the price

95. During the course of oral evidence taking, witnesses were invited to comment on the level at which a minimum price per unit should be set based upon the findings of the original Sheffield study. The revised study – conducted using updated data for some datasets – became available after the Committee’s evidence-taking was complete and its findings were not, therefore, tested with witnesses.

96. Commenting on the Royal Society of Edinburgh’s assertion in its written submission that it was “imperative” that the minimum price be set at such a level that would ensure that consumption would be reduced to a material extent78, Professor Beath explained that, for example, the lowest price for beer and cider in the off-trade was 16p per unit of alcohol and the highest price was 60p. He argued that the issue of where a minimum price would actually “have bite” depended on where in the price distribution most of the consumption occurred—

“If very few people buy alcohol at 16p per unit, setting a minimum price of 25p will impact on a small number of people, but not a large number. It would be nice if the University of Sheffield was asked to consider that interesting issue about where the mass of consumption is in the distribution of prices. If the mass of consumption is up at 60p per unit, to have any impact at all on the consumption of beer and cider from the off-trade, the price will have to be set at at least 60p a unit.”79

97. Asked about NUS Scotland’s position opposing a minimum price set at a level that would “prevent individuals on low incomes from purchasing alcohol to drink responsibly”, Liam Burns, President of NUS Scotland, responded—

“If the legislation on minimum pricing is to be successful, it must cause a reduction in unhealthy consumption. That is how we would sum up what the bill is meant to do. If unhealthy consumption ends up continuing because households simply make do with less money, the bill will clearly have failed. If it results in those on low incomes who consume a healthy amount of alcohol having to consume less, it will also have failed. We can give those broad principles, but we are in no position to say what the minimum price should be.”80

98. Dr Peter Rice was also asked at what level the minimum price should be set. He cautioned in response that the decision should be based on further data and modelling; he went on to suggest, however, that a price range of 40p to 60p seemed to be right—

“For instance, we know that only 9 per cent of alcohol at 40p per unit is consumed by moderate drinkers—people who drink less than 21 or 14 units a week—and that it is considerably preferred by heavy drinkers, which is those who drink more than 50 or 35 units a week … the appropriate level seems to me to be 50p.”

99. Dr Bruce Ritson felt that it would be “unwise” to be more specific than selecting the 40p to 60p range. He too argued for a price set at a level that would improve public health and added that it was hard to know what conditions would prevail when a minimum price was introduced, which, he suggested, presented problems for predicting an exact level now.81

100. Dr Emilia Crighton responded that most of the faculty’s members had expressed a preference for 60p. She attributed this to a simple desire to maximise the public health benefit. She added, however, that any price in the 40p to 60p range would be acceptable because it would have an impact.82

101. In respect of the same question, Jack Law from Alcohol Focus Scotland favoured a range of 45p to 60p as “anything less than that would not really have the required impact on overall population consumption”.83 For similar reasons, the Salvation Army also picked a price within this range—

“We looked at the evidence that accompanied the request to provide evidence to the committee on the bill, particularly the Sheffield study. After considering the impact of a minimum price on a range of alcohol use, we decided that a price of 50p per unit seemed to be the level at which we could get the most benefit without putting the price out of the range of normal social drinkers. We were comfortable with a minimum price of 50p.”84

The pivotal role of culture

Scottish drinking habits

102. 50.5m litres of pure alcohol were sold in Scotland in 2009, equating to 12.2 litres of pure alcohol for every person over the age of 18. This compares with an average of just over 10 litres per capita in England and Wales. Each person in Scotland bought an average 23.4 units of alcohol a week. 30% of men and 20% of women report their usual alcohol consumption as being more than the recommended limit per week. Guidelines are 21 units per week for men and 14 units a week for women.85

103. Research also suggests that there are around 1,047,000 hazardous drinkers and roughly 230,000 harmful drinkers in Scotland. Very high levels of alcohol consumption are relatively rare with 7% of men drinking in excess of 50 units and 4% of women drinking more than 35 units a week (these are the cut-offs used to classify harmful drinking in the International Classification of Mental Disorders). For both men and women, the proportion exceeding limits declines with age and increases with income.86

104. The majority of alcohol in Scotland is purchased in the off-trade sector, whose share of the market has grown gradually in recent years. Of the 50.5m litres of pure alcohol sold in Scotland in 2009, 33.8m (67.1%) litres of this were sold through the off-trade and 16.6m (32.9%) in the on-trade. The average price paid per unit in Scotland is 72p but this differs markedly between the on- and the off-trade.87 The table below shows the percentage of pure alcohol sold in the on-trade and the off-trade in Scotland in each of the last six years88

chart

A widespread problem

105. Asked which population groups gave the greatest cause for concern in respect of increases in consumption and increases in hazardous or harmful consumption, Dr Crighton stated that she was “anxious” about the whole population—

“Overall, we are drinking far too much. The effect on people living in the most deprived areas is more marked. I am most concerned about the west of Scotland, because we drink far too much.”89

106. Jack Law and Dr Ritson echoed Dr Crighton’s concern that the problem covers everyone in Scotland. Dr Ritson stated—

“One is reminded that no man is an island, because everyone's drinking influences all the rest of us. Further, the heavier a population drinks, the more people get caught up in the heavy drinking culture.”90

107. Professor Anna Dominiczak of the Royal Society of Edinburgh, speaking of her doubts about evidence to suggest that moderate drinking is protective of cardiovascular health, also alluded to the severity of the cultural problem. She stated that any such benefits were associated with a “very moderate way of drinking” and that that was “not the culture” that gave cause for worry in Scotland.91

Gender

108. The Scottish Health Survey 200892 recorded that the proportion of those drinking over the weekly recommended limit had declined over the period from 2003 to 2008 from 34% to 30% of men and from 23% to 20% of women. The survey commented that, although the overall decline in men’s average weekly unit consumption had been “statistically significant”, it had been “at the very margin of being so” and that the decline for women had not been significant. The survey went on to explain that, amongst women, levels of weekly consumption had been associated with a number of socio-demographic factors, such as socio-economic classification, household income and area deprivation—

“Levels of consumption were highest among women in managerial and professional households, in the highest income quintile and among those living in the least deprived areas.”93

109. In relation to men, the survey stated that weekly consumption above the recommended limits had shown a different pattern, “not associated with socio-economic classification or area deprivation”. Consumption levels had been similar for the first three income quintiles while the lowest two groups had been the least likely to have drunk over 21 units a week—

“The one exception to this pattern was that men in the most deprived areas were more likely than those in the least to drink very heavily (more than 50 units a week).”

110. The following bar chart from the survey shows the proportion of people exceeding government guidelines on weekly alcohol consumption (age-standardised), by equivalised household income quintile and gender—

chart

111. Asked about the finding of the Scottish Health Survey 2008 that levels of consumption were highest among women in managerial and professional households, in the highest income quintile and among those living in the least deprived areas, Dr Meier said—

“What is usually said is that people on lower incomes drink more and that deprivation is a big factor that drives drinking. Recently, we have seen that that is not necessarily the case among women: we now know that professional women drink more than women who have not got much money. The link between drinking and not having much money does not necessarily hold in the UK.”94

112. She added that the Sheffield study had not modelled whether per-unit minimum pricing would affect a managerial or professional woman in the highest income quintile who drank more than the weekly average in the same way that it would affect someone less well off in a deprived area.

113. Jack Law said that “women of child-bearing age” were a group of particular concern—

“We are not particularly well informed about or aware of foetal alcohol disorders, even though it is understood that drinking during pregnancy could have a significant impact on the foetus. That cohort needs to be looked at.”95

114. Dr Rice, however, expressed greater concern about drinking amongst men, stating that men's alcohol problems were “worse than women's” and “always” had been—

“There is a lot of focus on the changes in women's drinking, but the lines on the graph follow each other in parallel and it is easy for men to get forgotten about.”96

Age

115. The Scottish Health Survey 2008 recorded that around a half of men aged between 16 and 54 had drunk more than 4 units on the heaviest drinking day compared with 14% of men aged 75 and over. The pattern was similar for binge drinking (i.e. more than 8 units), with at least 3 in 10 men aged under 55 drinking more than 8 units compared with just 2% of men aged 75 and over. The survey observed a similar pattern amongst women: the youngest age groups had been the most likely to have consumed over 3 units on their heaviest drinking day (ranging from 45% to 54% among those aged between 16 and 44). Women aged 16-24 had been the most likely to have consumed more than 6 units (41%) and their mean units had been highest (7.1). All of these rates had decreased with age so that, by the age of 75 and over, only 6% of women drank over 3 units, 1% drank over 6 units and mean daily consumption was just 0.7 units on the heaviest drinking day in the preceding week.97

116. Jack Law also said that older people were of particular concern—

“A recent survey that Alcohol Focus did through one of our projects found that more than 85 per cent of the respondents of pensionable age drank significantly on a daily basis and had very little knowledge of the impact that their alcohol consumption was having on their general health and wellbeing, or of the relationship between their alcohol consumption and any medication that they were taking.”98

117. Dr Rice pointed to trends towards higher consumption amongst the middle-aged and older people. He stated that the over-45s were among those with the fastest-rising rates of hospital admissions and that the over-65s also had hospital admission rates that were rising fast. He added—

“Last week, I spoke to Professor Colin Drummond of the national addiction centre, who told me that he had looked at survey data from England that showed that the rates of hazardous consumption are rising fastest in women over 65; it is from a low base, but the rates are increasing fastest in that group.”99

Next

Footnotes:

1 Alcohol etc. (Scotland) Bill. Policy Memorandum, paragraph 2. Available at: www.scottish.parliament.uk/s3/bills/34-AlcoholEtc/b34s3-introd-pm.pdf [Accessed 26 May 2010]

2 Alcohol etc. (Scotland) Bill. Explanatory Notes, paragraph 5. Available at: www.scottish.parliament.uk/s3/bills/34-AlcoholEtc/b34s3-introd-en.pdf [Accessed 26 May 2010]

3 Explanatory Notes, paragraph 8.

4 Explanatory Notes, paragraph 12.

5 University of Sheffield. (2008) Independent Review of the Effects of Alcohol Pricing and Promotion. Available at: www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/documents/digitalasset/dh_091364.pdf [Accessed 26 May 2010]

6 ScHARR, University of Sheffield. (2009) Model-Based Appraisal of Alcohol Minimum Pricing and Off-Licensed Trade Discount Bans in Scotland. Available at: www.scotland.gov.uk/Publications/2009/09/24131201 [Accessed 26 May 2010]

7 Policy Memorandum, paragraph 17.

8 ScHARR. Written submission to the Health and Sport Committee.

9 ScHARR. Written submission to the Health and Sport Committee.

10 Scottish Parliament Health and Sport Committee. Official Report, 10 February 2010, Col 2704-5.

11 Scottish Parliament Health and Sport Committee. Official Report, 10 February 2010, Col 2708-9.

12 Scottish Parliament Information Centre. (2010) Comparison Paper on the Sheffield Alcohol Modelling Reports. Available at: www.scottish.parliament.uk/s3/committees/hs/papers-10/hep10-15.pdf [Accessed 26 May 2010]

13 Scottish Parliament Health and Sport Committee. Official Report, 10 February 2010, Col 2708.

14 Scottish Parliament Health and Sport Committee. Official Report, 10 February 2010, Col 2709.

15 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2738-9.

16 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2738-9.

17 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2738-9.

18 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2739.

19 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col2778.

20 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2765.

21 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2765.

22 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2821.

23 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2822-3.

24 Dr Peter Anderson. Written submission to the Health and Sport Committee.

25 Centre for Economics and Business Research. (2010) Minimum Alcohol Pricing: A targeted measure? Special Report for Scotland. Available at: www.scottish.parliament.uk/s3/committees/hs/inquiries/AlcoholBill/documents/
026CentreforEconomicsandBusinessResearchLtd.pdf
[Accessed 26 May 2010]

26 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2769.

27 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2767.

28 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2768.

29 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2825.

30 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2825.

31 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2826.

32 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2770.

33 Scottish Parliament Health and Sport Committee. Official Report, 24 March 2010, Col 3030.

34 Scottish Parliament Health and Sport Committee. Official Report, 24 March 2010, Col 3032.

35 Scottish Parliament Health and Sport Committee. Official Report, 24 March 2010, Col 3032.

36 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2753.

37 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2753.

38 Scottish Parliament Health and Sport Committee. Official Report, 10 March 2010, Col 2909.

39 Scottish Parliament Health and Sport Committee. Official Report, 10 March 2010, Col 2909.

40 Scottish Parliament Health and Sport Committee. Official Report, 10 March 2010, Col 2885.

41 Scottish Parliament Health and Sport Committee. Official Report, 17 March 2010, Col2982.

42 Scottish Parliament Health and Sport Committee. Official Report 17 March 2010, Col 2982.

43 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 3018.

44 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 3019.

45 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 3019.

46 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3110.

47 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3110.

48 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3111.

49 Scottish Parliament Health and Sport Committee. Official Report, 24 March 2010, Col 3037.

50 Scottish Parliament Health and Sport Committee. Official Report, 10 February 2010, Col 2715.

51 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2772.

52 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2772.

53 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2772.

54 Canadian National Alcohol Strategy Advisory Committee, Canadian Centre for Substance Abuse. Written submission to the Health and Sport Committee.

55 Scottish Parliament Health and Sport Committee. Official Report, 23 March 2010, Col 3022.

56 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2800.

57 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2840.

58 Scottish Parliament Health and Sport Committee. Official Report, 10 March 2010, Col2899-900.

59 Scottish Parliament Health and Sport Committee. Official Report, 10 March 2010, Col 2900.

60 Scottish Parliament Health and Sport Committee. Official Report, 10 March 2010, Col 2900.

61 Professor Anne Ludbrook. Paper for SHAAP. Purchasing Patterns for Low Price Off Sales Alcohol: Evidence from the Expenditure and Food Survey. Available at: www.scottish.parliament.uk/s3/committees/hs/inquiries/AlcoholBill/documents/20100503-SHAAPreport-purchaseoflow-pricealcoholanalysis.pdf [Accessed 26 May 2010]

62 Scottish Government. Written submission to the Health and Sport Committee, 21 April 2010.

63 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3112.

64 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3113.

65 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3113

66 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3113

67 Scottish Parliament Health and Sport Committee. Official Report, 5 May 2010, Col 3113

68 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2822.

69 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Cols 2822-3.

70 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2807.

71 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2807.

72 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2816-7.

73 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2817.

74 Scottish Parliament Health and Sport Committee. Official Report, 23 March 2010, Col 2992.

75 Scottish Parliament Health and Sport Committee. Official Report, 23 March 2010, Col 2999.

76 Scottish Parliament Health and Sport Committee. Official Report, 23 March 2010, Col 2997.

77 Scottish Parliament Health and Sport Committee. Official Report, 24 March 2010, Col 3056.

78 Royal Society of Edinburgh. Written submission to the Health and Sport Committee.

79 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2782.

80 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2809.

81 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2812.

82 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2812.

83 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2812.

84 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2796.

85 Scottish Parliament Information Centre. (2010) Alcohol etc. (Scotland) Bill. SPICe Briefing 10/13. Available at: www.scottish.parliament.uk/business/research/briefings-10/SB10-13.pdf [Accessed 26 May 2010]

86 Scottish Parliament Information Centre. (2010) Alcohol etc. (Scotland) Bill. SPICe Briefing 10/13. Available at: www.scottish.parliament.uk/business/research/briefings-10/SB10-13.pdf [Accessed 26 May 2010]

87 Scottish Parliament Information Centre. (2010) Alcohol etc. (Scotland) Bill. SPICe Briefing 10/13. Available at: www.scottish.parliament.uk/business/research/briefings-10/SB10-13.pdf [Accessed 26 May 2010]

88 Source: Nielsen Industry Statistics obtained by NHS Health Scotland. Notes–2005, 2006, 2007 and 2008 = 12 months

2008X = 12m. Off - Trade to w/e 04.10.2008 / On-Trade to end September2008

2009X = 12m. Off - Trade to w/e 03.10.2009 / On-Trade to end September2009

89 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2829.

90 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2829.

91 Scottish Parliament Health and Sport Committee. Official Report, 24 February 2010, Col 2764.

92 Scottish Government. (2009) The Scottish Health Survey 2008. Available at: www.scotland.gov.uk/Publications/2009/09/28102003/0 [Accessed 26 May 2010]

93 Scottish Government. (2009) The Scottish Health Survey 2008. Available at: www.scotland.gov.uk/Publications/2009/09/28102003/0 [Accessed 26 May 2010]

94 Scottish Parliament Health and Sport Committee. Official Report, 10 February 2010, Col 2721.

95 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2830.

96 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2829.

97 Scottish Government. (2009) The Scottish Health Survey 2008. Available at: www.scotland.gov.uk/Publications/2009/09/28102003/0 [Accessed 26 May 2010]

98 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2830.

99 Scottish Parliament Health and Sport Committee. Official Report, 3 March 2010, Col 2830.