A new Citizen’s Assembly on illicit drugs use will be established by Cabinet and is expected to begin its work in April and conclude by the end of the year.
While an evidence- based drug policy is laudable and overdue, what of Ireland’s largest drug problem – alcohol? Successive Governments have repeatedly examined international best practice alcohol policy, succeeded in passing the Public Health (Alcohol) Act (PHAA) in 2018 and yet five years later, we continue to wait as the Government prevaricates over the implementation of the Act in its entirety and what is there is being undermined by zero-alcohol product marketing.
The PHAA is a suite of quite modest measures designed to provide some degree of protection from an industry acting against the population’s health through aggressive marketing. Alcohol Action Ireland state that ‘what is clear is that there is continuing ferocious lobbying against the implementation of the PHAA and corporate social responsibility strategies that deflect attention from the harmful nature of the product.’
Poll findings indicate overwhelming public support for action to curb alcohol advertising. Data shows that 70% of people back a 9pm watershed for alcohol advertising on TV and 66% back stopping alcohol adverts being streamed on social media channels.
CEO of Alcohol Action Ireland (AAI), Dr Sheila Gilheany states that even after the order is signed, the industry has a year to get their houses in order. ‘They know this is coming and are very likely already prepared. Enforcement of this measure shouldn’t be a barrier to implementation – breaches will be very clear to spot. We must stop this deference to industry and implement the law without further delay.’
Information provided to AAI under the Freedom of Information shows that consultations between the Department of Health and the Broadcasting Authority of Ireland in relation to curbing alcohol ads to children, as required under the provisions of the PHAA, last took place in February 2022. When asked about this issue, Minster for Health Stephen Donnelly states that ‘consultations are ongoing.’
Concurrently, the vociferous marketing of zero alcohol drinks continues unabated – products that make up just 1.5% of the Irish drinks market. The real impact of zero alcohol drinks is the interest in marketing them – in venues that are no longer permitted for alcohol advertising, such as on buses and during sporting events. This goes against the spirit of our world-leading laws to protect us from alcohol marketing, which comprehensive research shows is harmful in terms of early initiation to drinking and how much and how often people drink. This constant brand exposure for big alcohol companies is a master stroke in that it makes them appear to be conscientious actors who care about our health and allows them to advertise in restricted areas – as we see plastered across the pitch at Six Nations Rugby matches in Dublin. When the broadcast watershed is finally introduced will it just mean a proliferation of zero-alcohol ads day and night?
AAI argues that the definition of advertising used in the Act should be sufficiently broad to prevent such ‘alibi marketing’. The legislation’s definition of ‘advertisement’ states that for the purposes of that Act, advertising means- any form of commercial communication intended to promote an alcohol product, whether directly or indirectly, including trademarks, emblems, marketing images and logos making reference to the product.
If this is not clear enough, then an amendment is needed to close the loophole. In Norway, the legislation is clear. Marketing of no alcohol and low alcohol products of the same brand as alcoholic products is banned. Non-alcoholic beverages must have their own distinct branding, quite different from the parent brand.
This is the type of crystal-clear clarity needed in the Irish market.
Headlines have been made recently about Ireland’s upcoming alcohol labelling regulations – another element of the PHAA. What is missing from the intensive discussions around labelling and the putative harm it may do to the wine growers in Italy, the prevarication in introducing a 9pm watershed for alcohol advertisements on TV or curbing the widespread flouting of the tenet of the law as occurs with alibi marketing – is the level of harm caused by the obfuscation and delays induced in the implementation of legislation.
A recent study in Nature (2023) states that alcohol readily crosses the placenta and that harm from prenatal alcohol exposure is determined by factors that include the dose, pattern, timing, and duration of exposure. A safe dose of alcohol during pregnancy has not been established. Prenatal alcohol exposure can cause fetal alcohol spectrum disorder (FASD) which is characterized by neurodevelopmental impairment, congenital anomalies, and poor growth. It is the leading cause of birth defects and developmental delay. The social and economic effects are profound but the diagnosis is often missed and receives scarce public recognition.
No safe level of alcohol during pregnancy has been established. The highest prevalence of alcohol use during pregnancy is in the WHO European Region (25%) while the prevalence of any alcohol use during pregnancy in Ireland is a staggering 60% or more – the highest in the world for which data is available.
In terms of prevalence of FASD the global prevalence among the general population is 7.7 cases per 1,000 individuals. The rate in the WHO European Region is highest at 19.8 /1000.
Ireland has the third highest rate of FASD in the world at 47.5/1,000.
The evidence shows that this amounts to around one in ten babies (around 6,000) born in Ireland every year with some form of foetal alcohol disorder with an estimated 600 having the most severe effects on their brains.
Is this what we want for our children – a tenth of babies born in Ireland having a lifelong impact from alcohol exposure before they were born? Recent evidence reports that over a third (37%) of Irish 15-24 year olds who drink alcohol have an alcohol use disorder and one in six live with parental alcohol use.
All of this remains largely invisible to citizens – unnamed and unexamined as the alcohol industry ploughs inexorably on leaving a trail of damage and destroyed lives.
We appear to possess an almost limitless capacity to sit back and watch as political life is seized by lobbyists and industry intent on maximising profits and market share. Next time you see and ad for alcohol or zero alcohol – think about the havoc wreaked on unborn babies, children of alcoholics and all those 15 – 24 year olds with an alcohol disorder.
Evidence- based best practice drug policy needs attention. So too does the reality of alcohol’s place at the core of Irish society and the need for urgent implementation of evidence-based best practice legislation that has the potential to take us off the global leader board for alcohol harm.
Dr Catherine Conlon is a Cork public health doctor and Safefood’s former director of human health and nutrition.