Hong Kong Med J 2021 Feb;27(1):4–6 | Epub 1 Feb 2021
© Hong Kong Academy of Medicine. CC BY-NC-ND 4.0
EDITORIAL
Response to the World Health Organization’s
working document for the development of a
global action plan to reduce alcohol-related
harm: Position Statement of the Hong Kong
Alliance for Advocacy Against Alcohol
Regina CT Ching, FHKAM (Community Medicine), MScPHM LSHTM (Lond); SP Mak, FHKAM (Community Medicine), FFPH;
Martin CS Wong, MD, MPH1; Ming Lam, FHKAM (Psychiatry), MRCPsych; WM Chan, FHKAM (Community Medicine); Margaret FY Wong, DSW, MSocSci; Raymond Liang, MD, FRCP; TH Lam, MD, Hon FHKCCM2; for the Hong Kong Alliance for Advocacy Against Alcohol†
1 JC School of Public Health and Primary Care, Faculty of Medicine, The Chinese University of Hong Kong, Hong Kong
2 Emeritus Professor, Hon Clinical Professor, School of Public Health, The University of Hong Kong, Hong Kong
†The Hong Kong Alliance for Advocacy Against Alcohol was established under the Hong Kong College of Community Medicine
Corresponding author: Dr Regina CT Ching (reginachingching@hotmail.com)
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Background
Globally, alcohol use accounts for approximately
3 million deaths every year and the overall burden
of disease and injuries remains high. Health
consequences aside, alcohol use incurs significant
social and economic losses relating to the justice
sector, workforce productivity and unemployment,
and pain and suffering of the drinker and other
people.
In May 2010, the 63rd World Health Assembly
endorsed the Global Strategy to Reduce the Harmful
Use of Alcohol (Resolution WHA63.13). The Global
Strategy gives a strong mandate to the World
Health Organization (WHO) to strengthen action
at national, regional and global levels and envisions
improved health and social outcomes for individuals,
families and communities, with considerably
reduced morbidity and mortality due to alcohol use
and its ensuing social consequences.
Despite adoption of the political declarations
emanating from high-level meetings of the United
Nations General Assembly on noncommunicable
diseases in 2011; inclusion of alcohol for prevention
and treatment of substance abuse in target 3.5 of the
Sustainable Development Goals 2030; introduction
of the WHO Global Action Plan for the Prevention
and Control of NCDs 2013-2020 (subsequently
extended to 2030 to align with the Sustainable
Development Goals 2030) and updated evidence
on a prioritised set of cost-effective or ‘best-buy’
policy measures known as the SAFER initiative,
implementation of the Global Strategy worldwide
has been uneven, and resources and capacities falling
behind the magnitude of the problems. The Global
Strategy has not resulted in considerable reductions
in alcohol-related morbidity and mortality and
the ensuing social consequences. The levels of
alcohol consumption and alcohol-attributable harm continue to be unacceptably high.
On this basis, the WHO Executive Board in 2020
requested the WHO Director-General, inter alia, “to
develop an action plan (2022-2030) to effectively
implement the Global Strategy to reduce the
harmful use of alcohol(https://cms.who.int/teams/mental-health-and-substance-use/alcohol-drugs-and-addictive-behaviours/alcohol/global-alcohol-strategy)
as a public health priority, in consultation
with relevant stakeholders, for consideration by the
75th World Health Assembly in 2022” The WHO
Secretariat conducted a web-based consultation
(https://www.who.int/news-room/articles-detail/global-action-plan-to-reduce-the-harmful-use-of-alcohol)
from 16 November to 13 December 2020
on a working document for development of the
action plan open to Member States, United Nations
organisations and other international organisations,
and non-State actors. All relevant feedback received
will be published on the WHO website.
The Hong Kong Alliance for Advocacy Against
Alcohol (HKAAAA) was established under the Hong
Kong College of Community Medicine in 2015 and
comprises individuals from the academic, medical
and health, social, and education sectors, to advocate
for effective evidence-based policies and actions
to reduce alcohol-related harms in Hong Kong.
The HKAAAA submitted the following Position
Statement in response to the WHO consultation.
Position statement
The HKAAAA has read the working document
for development of an action plan to strengthen
implementation of the Global Strategy to reduce
the harmful use of alcohol and has the following
comments and suggestions:
1. The HKAAAA welcomes WHO’ move to
develop an action plan to strengthen the Global Strategy to reduce harms related to alcohol use.
2. The HKAAAA understands the Global Strategy
was set out to support and complement public
health policies in Member States at national
and local levels to achieve considerable reduced
morbidity and mortality as well as improved
health and social outcomes for individuals,
families and communities, but notes that
globally, the levels of alcohol consumption
and alcohol-attributable harm continue to be
unacceptably high.
3. The HKAAAA agrees that considerable challenges
for the development and implementation of
effective alcohol policies relate to the complexity
of the problem, differences in cultural norms
and contexts, intersectoral nature of cost-effective
solutions and limited political will
and government leadership, but considers the
influence of powerful commercial interests
especially from transnational alcohol companies
to be exerting the greatest negative influence of
all.
4. Economic operators with core roles as developers,
producers, distributors, marketers and sellers of
alcoholic beverages, have primary commercial
responsibilities to their shareholders and must
therefore rely on substantial sales either by
encouraging heavy drinking or engaging more
people to drink, many of whom belong to
vulnerable and marginalised groups such as
young people, less educated, unemployed, people
who are stressed out or suffer from mental ill
health, and so on. As such, economic operators
have mission and vision that fundamentally
conflict with those of the Global Strategy. The
HKAAAA is of the view that these economic
operators should have no role in developing or
influencing the formulation of this action plan,
or for that matter, development, implementation
and evaluation of alcohol policy at global, national
and local levels. These economic operators are
not, and should not be construed as, equivalent
to other ‘non-state actors’ in the context of the
action plan. Neither is there a need to ‘invite’
them to self-regulate or act contrary to their
profit-driven goals and objectives.
5. As WHO rightly points out, alcohol remains the
only psychoactive and dependence-producing
substance that exerts a significant impact on
global population health that is not controlled
at the international level by legally binding
regulatory instruments. The HKAAAA urges
WHO to set out in the action plan immediate,
concrete steps and timeline to formulate
a global normative law on alcohol at the
intergovernmental level, modelled on the WHO
Framework Convention on Tobacco Control,
to regulate the distribution, sale and marketing of alcohol within the context of international,
regional and bilateral trade negotiations, as well
as to protect the development of alcohol policies
from interference by transnational corporations
and commercial interests.
6. The launching of WHO’ SAFER initiative
comprising the most cost-effective actions
or “best buys” namely, increasing taxes on
alcoholic beverages, enacting and enforcing
bans or comprehensive restrictions on exposure
to alcohol advertising across multiple types of
media, and enacting and enforcing restrictions
on the physical availability of retailed alcohol, is
applauded. However, the HKAAAA considers
that political will, government leadership
and intergovernmental commitment aside,
interference from transnational commercial
interests needs to be kept at bay, through global
regulatory efforts initiated, coordinated and
assured by WHO.
7. The HKAAAA recognises that in today’s
world that favours free trade, a legally binding
regulatory framework provides the bottom line
for economic operators in alcohol production
and trade as well as operators in other relevant
sectors to eliminate marketing and advertising
of alcoholic products to minors and other
vulnerable groups, prevent heavy drinking,
eliminate false health claims, and ensure
availability of easily understood consumer
information on the labels of alcoholic beverages
(including composition, age limits, health
warning and contra-indications for alcohol use).
8. The HKAAAA further points out the term
“harmful use of alcohol” used repeatedly
throughout the consultation document implies
there are beneficial uses of alcohol, which
practically do not exist. This misperception is,
to a large extent, influenced and reinforced by
commercial messaging and poorly regulated
alcohol marketing which deprioritise efforts
to counter the harms of alcohol use. This has
resulted in low awareness and poor acceptance
of the overall negative impact of alcohol
consumption on a population’ health, safety
and wellness among decision-makers, general
public and even healthcare providers. Moreover,
it confuses the public and hinders education
efforts. The HKAAAA calls on WHO to stop
using the term “harmful use of alcohol” and
adopt “alcohol-related harm” in its place.
9. To reduce interference from commercial
interests, the HKAAAA calls on all types of
dialogue between economic operators with a
stake in alcohol and public institutions (WHO
secretariat, Member States, public funded
bodies and research institutions, and civil
societies) be halted and reduced to a minimum, and if they must go ahead, be documented with
respect to the purpose, parties involved, mode,
content, expenses and outcome for the sake of
transparency and public accountability.
10. To help expose and recognise pervasive
commercial interference in public policy making
and anti-alcohol efforts including ‘corporate
social responsibility’ initiatives at transnational,
national and local levels in order that public
and non-profit organisations may steer clear of
commercial interests of economic operators, the
HKAAAA requests the WHO to take the lead in
a global stock taking exercise that will also serve
as baseline for future regulatory work.
11. The HKAAAA recommends the setting of
SMART (specific, measurable, achievable,
relevant and time-bound) objectives relating to
all recommended or proposed action within the
action plan.
12. The HKAAAA suggests biennial publishing of
national status reports on alcohol and health,
and biennial reporting by action parties to help
focus global, national and local anti-alcohol
efforts, and strengthen monitoring and public
accountability.
13. To counteract alcohol marketing in the form
of recurrent wine and dine promotions, sports
sponsorships and the like, which are often
held for days and weeks in a row, HKAAAA
supports the WHO to initiate global efforts to
organise annual national alcohol awareness
drives. HKAAAA, however, considers these
drives should last for at least 5 to 7 days, and
incorporate health behaviour changes on top
of raising awareness. Examples may include
public and non-public institutions refraining
from serving alcohol at business and private occasions, making pledges to reject alcohol
sponsorships, and strengthening support for
drinkers who anticipate quitting.
Concluding remarks
Alcohol is a toxic substance with dependence
producing properties, contributing to 3 million
deaths and 5.1% of disease burden every year globally.
It is time the health and social damage of drinking be
fully recognised and effectively dealt with at global,
national and health systems levels, modelled on the
WHO Framework Convention on Tobacco Control.
Author contributions
All authors contributed to the editorial, approved the final version for publication, and take responsibility for its accuracy and integrity.
Conflicts of interest
All authors have disclosed no conflict of interest.
Declaration
This Position Statement was submitted in response to the
World Health Organization (WHO) online consultation
on a working document on developing a global action plan
to reduce the harmful use of alcohol (https://www.who.int/news-room/articles-detail/global-action-plan-to-reduce-the-harmful-use-of-alcohol). Relevant submissions will be
published on the WHO website in mid-February 2021.
Funding/support
This editorial received no specific grant from any funding agency in the public, commercial, or not-for-profit sectors.