RE: RNAO Urges Province to Use Public Health Evidence to Inform a Comprehensive Provincial Alcohol Strategy

Transcription

1 Hon. Kathleen O. Wynne Premier Room 281, Queen's Park Main Legislative Building Toronto, ON M7A 1A1 March 3, 2016 RE: RNAO Urges Province to Use Public Health Evidence to Inform a Comprehensive Provincial Alcohol Strategy Dear Premier Wynne, The Registered Nurses' Association of Ontario (RNAO) remains profoundly concerned about the direction the province has taken in regards to alcohol sales. Government actions and rhetoric surrounding "the biggest change since the repeal of prohibition" 1 seem to be more informed by market forces than by public health evidence. As RNAO has argued in the media, Ontario is absolutely moving in the wrong direction by enabling the sale of beer 2 and wine 3 in grocery stores. Liberalizing alcohol sales based on recommendations by Ed Clark 4 5 contradicts the province's stated aspiration "to make Ontario the healthiest place in North America to grow up and grow old." 6 Increasing the physical availability of alcohol by expanding retail sites is a threat to public health, public safety, and community well-being. 7 If alcohol was an ordinary commodity, like broccoli, then improving convenience and choice might be desirable. Alcohol, however, is "no ordinary commodity" as it "plays a major role in the causation of disability, disease, and death on a global scale." 8 The World Health Organization (WHO) attributes 3.3 million deaths globally each year due to alcohol. 9 There is a causal relationship between alcohol consumption and more than 200 health conditions. 10 In addition to acute and chronic diseases and injuries, alcohol use can lead to alcohol poisoning, homicide, impaired driving, suicide, exacerbation of mental illness, alcohol use disorder, and intergenerational effects complicated by genetics, alcohol consumption, and social/family environment. 11 The province has announced its commitment to support "the safe and responsible consumption of alcohol," 12 yet there are some situations where alcohol consumption is never safe. During pregnancy, there is no safe amount or time to drink alcohol 13 as fetal alcohol spectrum disorder (FASD) is the leading known cause of preventable developmental disability in Canada. As alcohol is a class 1 carcinogen, the Chief Public Health Officer of Canada, 16 Canadian Cancer Society 17 and Cancer Care Ontario" all warn there is no safe limit of alcohol consumption. Drinking while driving is also never safe from 2000 to 2010, Registered Nurses Association of Ontario L Association des infirmières et infirmiers autorisés de l Ontario 158 Pearl Street, Toronto, ON M5H 1L3 ~ Ph ~ Toll-free ~ Fax ~

2 between 36 and 41 per cent of fatally injured drivers in Canada tested positive for alcohol. 20 Alcohol must not be treated like broccoli. Instead, it must be recognized as a drug that can cause harm, just like tobacco and other narcotics. RNAO is not arguing for prohibition. As with other drugs, RNAO is advocating for an evidence-informed harm reduction approach to alcohol. Ontario's alcohol retailing system, before Ed Clark's recommendations were implemented, gave people access to alcohol within a social responsibility framework. Before changes that allowed beer and wine sales in grocery stores, more than 75 per cent of Ontarians already lived within a ten minute commute of an alcohol retail outlet. 21 There is a wealth of global, national, and provincial 29 evidence on effective population-level policies that decrease harms from alcohol. A 2013 comparison of provincial alcohol policies found multiple unrealized health and safety benefits. The average national score in this assessment was below 50 per cent of a perfect score. 30 At that time, Ontario, British Columbia, and Nova Scotia had the highest-rated alcohol harm reduction policies, while Quebec's scored the lowest. 31 Instead of building on Ontario's top ranking, the province is moving in the opposite direction by further privatizing alcohol retail outlets. 32 As one of many health and civil society organizations that have advocated for a comprehensive alcohol strategy to address health and social harms, we appreciated the Premier's announcement of the development of a "comprehensive, province wide Alcohol Policy" on Dec. 18, While welcome, it is disconcerting that this announcement came with the government opening up bids from grocery stores to sell beer on Sept. 23, 2015, 36 enabling beer sales in grocery stores as of Dec.15, 2015, 37 and announcing that 70 grocery stores will be able to sell wine, beer, and cider this fall on Feb. 18, Ontario's 2016 provincial budget, delivered on Feb. 25, 2016, reinforces this increased privatization of alcohol sales under the heading of "making everyday life easier" and increases access to alcohol by enabling an LCBO E-Commerce Platform that will facilitate home delivery. 39 Pressing ahead with such substantive changes to increase availability of alcohol while ignoring proven population-level alcohol policies calls into question the province's commitment to reduce harm from alcohol. Although the government is seeking to consult with stakeholders on developing the strategy, our experience is that the process seems rushed, lacking in rigour and deficient in transparency. It is unclear how the interests of industry stakeholders seeking to increase market share for their products can be reconciled with the strong public health evidence that the consumption of alcohol and related problems increase as alcohol becomes more available. 40 These contradictions may undermine trust in the sincerity of the consultation process and discourage engagement in the democratic process. RNAO recommends the following for better health outcomes and a healthier province, consistent with the three "best buy" recommendations of the WHO and recommendations from the national and provincial public health community: Roll back recent privatization initiatives and establish a moratorium on further privatization of alcohol sales. In light of the critical evidence of increased harm with increased physical availability of alcohol, strengthen government-run retailing systems and monopolies. Strengthen Ontario's minimum pricing structure by raising minimum prices; linking prices to alcohol content so that as alcohol content rises, so does price; and close loopholes to the minimum price. 2

3 The WHO recommends a ban of alcohol advertising, promotion, and marketing. Ontario can start to confront a culture that normalizes drinking by updating current advertising regulations so they apply to all forms of media including social, internet, radio, television, and print. Immediately prohibit alcohol promotion targeted to youth, including scholarships, bursaries, and sponsorship. For greater transparency and accountability, make public all submissions and letters related to alcohol policy. Alcohol availability, pricing, and marketing are three population-based elements that will determine how socially responsible this government is in its approach to reducing harm from alcohol. Lessons can be learned from Ontario's success in reducing tobacco use and exposure through a cultural change prompted by policies, laws, public education, and programs. If Ontario does not make its alcohol policy congruent with the public health evidence, then the province will be undermining its other key initiatives, including those to reduce poverty, address homelessness, strengthen mental health and recovery from addictions, prevent injuries, avoid premature death and promote health by preventing acute and chronic diseases, and prevent violence. Current policies that increase the availability of alcohol work dramatically against the province's stated goal of developing a provincial FASD Strategy 41 and repeated advocacy on this issue from many organizations, including RNAO. Thank you for considering this constructive feedback and recommendations. We know that our province can and must do better. Kind regards, Doris Grinspun, RN, MSN, PhD, LLD(hon), O.ONT Chief Executive Officer, RNAO copy: Patrick Brown, Leader, Office Opposition Andrea Horwath, Leader, New Democratic Party of Ontario Hon. Dr. Eric Hoskins, Minister of Health and Long-Term Care Hon. Tracy MacCharles, Minister of Children and Youth Services Hon. Charles Sousa, Minister of Finance Hon. Dipika Damerla, Associate Minister of Health and Long-Term Care Granville Anderson, Parliamentary Assistant to the Minister of Children and Youth Services Jackie Wood, A/Director, MOHLTC, Strategic Initiatives Branch References 1 Office of the Premier, (2015). News Release: Ontario Expanding Beer Sales to Grocery Stores, April 16, Grinspun, D. (2015). Taking off the beer goggles to put public health ahead of politics. Hamilton Spectator, July 29,

4 3 Grinspun, D. (2016). No rush for wine in grocery stores. Toronto Star, February 18, Premier's Advisory Council on Government Assets (2015). Striking the Right Balance: Modernizing Beer Retailing and Distribution in Ontario. Toronto: Author. 5 Premier's Advisory Council on Government Assets (2016). Striking the Right Balance: Modernizing Wine and Spirits Retailing and Distribution in Ontario. Toronto: Author. 6 Ministry of Health and Long-Term Care (2012). Ontario's Action Plan for Health Care. Toronto: Author, See, for an example of the multi-faceted health, social, and community impacts of alcohol in one community in Ontario: Research and Evaluation Division of Kingston, Frontenac, Lennox & Addington Public Health (2012). It Starts Here: A Conversation about Alcohol in the City of Kingston. Kingston: Author. 8 Barbor, T. et al. (2010). Alcohol: No ordinary commodity-a summary of the second edition. Addiction, 105, World Health Organization (2015). Fact Sheet: Alcohol World Health Organization (2014). Global Status Report on Alcohol and Health Geneva: Author, vii Taylor, G.(2016). The Chief Public Health Officer's Report on the State of Public Health in Canada 2015: Alcohol Consumption in Canada. Ottawa: Public Health Agency of Canada,13-17, Office of the Premier, (2015). News Release: Ontario Developing Policy to Support Responsible Alcohol Use. December 18, Public Health Agency of Canada (2014). Fetal Alcohol Spectrum Disorder (FASD). Revised April 29, Taylor, Registered Nurses' Association of Ontario (2014). Submission to the Select Committee on Development Services. London: Author Taylor,3. 17 Canadian Cancer Society (2016). Alcohol Cancer Care Ontario (2014). Alcohol and Cancer. Revised August 28, Cancer Care Ontario (2014). Cancer Risk Factors in Ontario: Alcohol. Toronto: Author Canadian Centre on Substance Abuse (2015). Impaired Driving in Canada. Ottawa: Author, Giesbrecht, N. & Wettlaufer, A. (2013a). Reducing Alcohol-Related Harms and Costs in Ontario: A Provincial Summary Report. Toronto: Centre for Addiction and Mental Health, World Health Organization (2011). Discussion Paper: Prevention and Control of NCDS: Priorities for Investment. Moscow: Author, World Health Organization and World Economic Forum (2011). From Burden to "Best Buys": Reducing the Economic Impact of Non-Communicable Diseases in Low and Middle-Income Countries. Geneva: Authors World Health Organization. Chapter 4 Reducing risks and preventing disease: population-wide interventions National Alcohol Strategy Working Group (2007). Reducing Alcohol-Related Harm in Canada: Toward a Culture of Moderation--Recommendations for a National Alcohol Strategy Canadian Public Health Association (2011). Too High a Cost: A Public Health Approach to Alcohol Policy in Canada. Ottawa: Author Giesbrecht, Wettlaufer, et al. (2013b). 4

5 28 Cancer Care Ontario and Public Health Ontario (2012). Taking Action to Prevent Chronic Disease: Recommendations for a Healthier Ontario. Toronto: Author, Centre for Addiction and Mental Health (2013). Alcohol Policy Framework. Toronto: Author. AlcoholPolicyFramework.pdf 30 Giesbrecht, N., Wettlaufer, A., et al. (2013b). Strategies to Reduce Alcohol-Related Harms and Costs in Canada: A Comparison of Provincial Policies. Toronto: Centre for Addiction and Mental Health, 2. %20Alcohol%20Related%20Harms%20and%20Costs% pdf 31 Giesbrecht, Wettlaufer, et al. (2013b), Giesbrecht & Wettlaufer. (2013a), 3, Centre for Addiction and Mental Health, Canadian Centre on Substance Abuse, Canadian Mental Health Association, MADD Canada, Ontario Public Health Association, RNAO (2015). Why Ontario Needs a Provincial Alcohol Strategy. y.pdf 34 Centre for Addiction and Mental Health, Canadian Centre on Substance Abuse, Canadian Mental Health Association, MADD Canada, Ontario Public Health Association, RNAO (2015). Media release: Ontario needs a provincial alcohol strategy, say leading health organizations. September 21, current_year/pages/ontario-needs-a-provincial-alcohol-strategy,-say-leading-health-organizations.aspx 35 Office of the Premier, (2015). News Release: Ontario Developing Policy to Support Responsible Alcohol Use. December 18, Office of the Premier, (2015). News Release: Province Takes Next Steps to Modernize Beer Retailing. September 23, Benzie, R. (2015). Beer finally arrives in Ontario grocery stores. Toronto Star, December 15, Office of the Premier, (2016). News Release: Wine Coming to Grocery Stores Across Ontario, February 18, Ministry of Finance (2016). Jobs for Today and Tomorrow: 2016 Ontario Budget. Toronto: Author, Barbor, T. et al, MacCharles, T. (2014). Mandate Letter to Parliamentary Assistant to the Minister. Toronto: Ministry of Children and Youth Services Anderson, G. (2015). Fetal Alcohol Spectrum Disorder Provincial Roundtable Report: A Report from Parliamentary Assistant Granville Anderson to the Minister of Children and Youth Services. Toronto: Author Select Committee on Developmental Services (2014). Final Report: Inclusion and Opportunity: A New Path for Developmental Services in Ontario. Toronto: Author Fetal Alcohol Spectrum Disorder Ontario Network of Expertise (FASD ONE) (2014). Fetal Alcohol Spectrum Disorder (FASD): A Call To Action for Ontario. Toronto: Author Registered Nurses' Association of Ontario (2014). Submission to the Select Committee on Development Services. London: Author. January 13, Registered Nurses' Association of Ontario (2014). Media Release: Registered nurses call for provincial strategy to address Fetal Alcohol Spectrum Disorder. Toronto: Author DiConstanzo, M. (2013). A Troubled Life. Registered Nurse Journal. November/December 2013,