Public health and licensing workshop

Outlet density and cumulative impactDr James NichollsAlcohol Research UK

Three issues

Public health licensing objective for cumulative impact areas

Research on outlet density, consumption and harm

Scotland and ‘overprovision’ policies

Cumulative impact policies

A ‘rebuttable presumption that applications [which add to cumulative impact] will normally be refused’ (Sections 13.19-38 of Section 182 Guidance)

Consensus that outlet density exacerbates particular harms

158 CIAs across 93 licensing authorities in 2012 [134 / 83 in 2010]

Health evidence valid in preparing a policy (s. 13.23), but no health objective for it to address.

‘We want to ensure that licensing authorities are able

to take alcohol-related health harms into consideration

when making decisions about cumulative impact

policies (CIPs) which can be used to manage problems

linked to the density of premises in specific areas. We

consider that a new health-related objective for

alcohol licensing related specifically to cumulative

impact is the best way to achieve this.’

Objections to health objective

A&E admissions already covered by crime and disorder objective

No link between density and health at local level

A ‘bridge to far’ for health involvement in licensing

Outlet density: evidence reviews

Popova, S. et al. (2009) ‘Hours and days of sale and density of alcohol outlets: Impacts on alcohol consumption and damage: a systematic review’, Alcohol and Alcoholism 44.5 (500-16)

Jackson et al. (2009) ‘Interventions on control of alcohol price, promotion and availability for prevention of alcohol use disorders in adults and young people’, NICE evidence review

Home Office (2012) ‘Impact assessment: consultation on including a health objective in the Licensing Act 2003 related specifically to cumulative impact’

Outlet density and consumption

Jackson et al. (2009): ‘A clear positive association between outlet density and increases in alcohol consumption was observed among both adults and young people. Further limited evidence was also identified that found a positive relationship between alcohol outlet density and alcohol-related harms.’

Consistent evidence of impact on crime and disorder (though variations by locality and type of outlet)

Outlet density and health

Theall, K. et al. (2009) ‘The neighborhood alcohol environment and alcohol-related morbidity’, Alcohol and Alcoholism 44.5 (491-9)

Livingston, M. (2011) ‘Alcohol outlet density and harm: comparing the impacts on violence and chronic harms’, Drug and Alcohol Review 30 (515-23)

Also evidence from Nordic studies following state-level changes in legislation.

Outlet density and health: the evidence

Theall et al., 2009: ‘Our findings support the notion that alcohol outlets are likely to play a significant role in health outcomes at neighborhood level, irrespective of individual consumption patterns’

Livingston (2011): 10% increase in the number of off-licenses would increase hospital admissions by 1.9% (on-licenses = 0.5%)

‘There was a strong positive association between [off-license] density and rates of alcohol-caused chronic disease.’

‘Outlet density’ today

1884 2012

Key problems

Rebalancing towards the off-trade

Capacity v number of outlets

Impact of supermarkets on small off-licenses (cf. Forsyth, A. (2012) ‘Shop servers experience of alcohol-related issues and interventions in socially contrasting neighbourhoods’ Alcohol Research UK)

Effective proximity measures (especially supermarkets and online)

Scale of CIA for health indicators

Scale of cumulative impact areas

Licensing authorities could introduce a new CIP or ‘extend the geographic area of an existing CIP (potentially to cover the whole licensing authority area) following consideration of health data’ (Health Objective Impact Assessment, p. 5)

Croydon’s proposed borough-wide policy is ‘disproportionate and unhelpful … [It] may well be open to challenge and it certainly falls foul of national policy’ (Association of Licensed Multiple Retailers Press Release 25th Feb)

Is Government guidance clear enough on this?

Licensing (Scotland) Act 2005

Fifth licensing objective:‘Protecting and improving public health’

OverprovisionRequirement for statement on ‘overprovision’ in Statement of Licensing Policy

Support for data-gathering

Focus on Statements of Licensing Policy

Problem of causal relationships – bar is lower for overprovision (risk, rather than undermining objectives)

Strong trade resistance – legal challenges

Alcohol and Drug Partnerships

Community engagement through Licensing Forums