WMA comments

THE WORLD MEDICAL ASSOCIATION, INC.
L’ASSOCIATION MEDICALE MONDIALE, INC
ASOCIACION MEDICA MUNDIAL, INC
Centre International de Bureaux
Immeuble A “Keynes” Website : www.wma.net Postal Address :
13, chemin du Levant Telephone : (33) 4 50 40 75 75 Boîte Postale 63
01210 FERNEY-VOLTAIRE Fax : (33) 4 50 40 59 37 01210 FERNEY-VOLTAIRE Cedex
France E-mail address : wma@wma.net France
WHO Working document for the development of
an action plan to strengthen the implementation of the
Global Strategy to Reduce the Harmful Use of Alcohol
WMA COMMENTS
The World Medical Association (WMA), the global federation of Medical Associations
representing the millions of physicians worldwide, has a long-standing commitment towards the
reduction of the harmful impact of alcohol on health and society and actively supported the
adoption of WHO Global strategy to reduce the harmful use of alcohol in 2010. Alcohol
consumption constitutes a major trigger for Non-Communicable Diseases (NCD), communicable
diseases, violence, and injuries and we note with great concerns the limited progress made to
reverse the current trend since 2010.
General comments
We welcome WHO consultation on its working document for developing the global alcohol action
plan and acknowledge the efforts made to develop a comprehensive framework encompassing all
stakeholders concerned to tackle the alcohol burden weighing on public health and ultimately on
health systems. We believe however that a more concise action plan would bring more clarity to the
document.
We support the observation in the introduction section to the action plan recognizing that “limited
technical capacity, human resources and funding hinder efforts in developing, implementing,
enforcing and monitoring effective alcohol control interventions at all levels”1
and call for Member
States to adequately fund WHO’s work on alcohol.
In our opinion, the absence of specific review and reporting mechanism for the action plan’s
implementation weakens its prospective impact. We recommend that a report to the World Health
Assembly be made biennially to assess the progress made, as is the case with the tobacco status
report.
We share the overall analysis of the challenges identified in implementing the Global Strategy. We
note however a lack of consistency between those challenges and the actions proposed under the six
areas of the action plan. We believe that a successful strategy to address the harmful use of alcohol
requires stronger and more tangible commitments and actions in the following areas:
1 Working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce
the Harmful Use of Alcohol, 14th November 2020, p.5
WMA page 2
1. Placing health equity at the core of the action plan
We welcome the point raised in the introduction section of the working document on the
“disproportionate prevalence of effective alcohol control measures in higher-income countries”,
raising questions about global health equity and agree on “the need for more resources and greater
priority to be allocated to support the development and implementation of effective policies and
actions in low- and middle-income countries”2
. We regret that the action plan does not include more
tangible actions to meet this requirement.
More generally, we recommend a stronger emphasis on health equity by placing it at the core of the
action plan. Social, cultural, environmental and economic factors are major determinants on the
quality of life, good health and life expectancy and have decisive impacts on alcohol consumption
patterns.
Addressing the problematic of alcohol through a Social Determinants of Health (SDH) perspective
requires looking at the root causes of alcohol behaviours. This is essential for the understanding of
the problem and makes it possible to unveil health inequities which are often the primary source of
addictive patterns and other alcohol abuses.
We believe therefore that it is critical that health inequities are clearly identified in the action plan
as major sources of alcohol abuses. This would underscore the ethical and human rights principles
as the founding values of the plan, beyond the health costs of the scourge.
2. Health professionals as partners in combatting the harmful use of alcohol
We welcome the actions proposed in the plan for the attention of health professionals, mainly
related to capacity-building and education, but regret that their role in documenting and preventing
alcohol abuses is not further developed. We note a clear disparity between the overwhelming
consideration given to economic operators in the action plan compared to health professionals3
.
This variance seems to us particularly inadequate from a public health perspective.
Physicians and other health professionals play a key role in education, advocacy and research.
Physicians in particular work to reduce the harmful use of alcohol by identifying early-stages of
addictive behaviour in consultations with their patients and supporting them in changing behaviour
in the framework of a trustworthy patients-physicians relationship. They can promote evidence-
based prevention strategies in schools and communities and assist in informing the public of alcohol
related harm. Physicians also have an important function in facilitating epidemiologic and health
service data collection on the impact of alcohol with the aim of prevention and promotion of public
health.
We believe that those considerations are not sufficiently reflected in the proposed action plan and
recommend its revision so that health professionals are considered as recognized partners in
tackling the alcohol affliction.
2 Working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce
the Harmful Use of Alcohol, 14th November 2020, p.2
3 See below, item 3
WMA page 3
3. Protecting public health interests from commercial interference
The working document identifies as one of the challenges in implementing the strategy “the
influence of powerful commercial interests in policy-making and implementation (..) Competing
interests across the whole of government at the country level, including interests related to the
production and trade of alcohol and government revenues from alcohol taxation and sales, often
result in policy incoherence and the weakening of alcohol control efforts”. “General trends
towards deregulation in recent decades have often resulted in a weakening of alcohol controls, to
the benefit of economic interests and to the expense of public health and welfare”4
.
We welcome this accurate analysis of the situation. Unfortunately, the conclusions are not followed
by tangible actions later in the plan. The structure of the action plan includes an explicit role for
economic operators suggesting that their contributions are authentic. Under each area of the plan,
actions to the attention of economic actors are proposed with a view to contribute to the reduction
of alcohol burden or to refrain from acting against public health interests. We cannot validate those
proposals that we consider inappropriate, unrealistic and even dangerous, leaving the door open to
commercial intrusion to the very detriment of public health.
Equally, we have strong reservations on the validity to pursue a regular “global dialogue” with the
alcohol industry5
, which counteracts the Guiding principle 1 (Global Strategy to Reduce the
Harmful Use of Alcohol. WHO, 2010): “Public policies and interventions to prevent and reduce
alcohol-related harm should be guided and formulated by public health interests and based on
clear public health goals and the best available evidence”.
The role of the alcohol industry in the reduction of alcohol-related harm should be strictly confined
to their roles as producers, distributors and marketers of alcohol, and never include alcohol policy
development or health promotion. It is crucial that the action plan sets very clear boundaries on the
scope of action of the alcohol industry to protect public health interests.
Furthermore, we are concerned to note that the responsibility for monitoring and reporting
interference from commercial interests lies only with civil society actors. We strongly recommend
providing the plan with a comprehensive monitoring mechanism led by the WHO secretariat
involving all actors, including Member States, to counter commercial intrusions.
Commercial interests contradict the very essence of the strategy to serve public health. We identify
no evidence of efficacy for continuing dialogue with the alcohol industry and deeply regret the
disproportionate attention given to economic operators in the plan, compared to the limited
consideration provided to the health professionals’ role in documenting and preventing harmful use
of alcohol6
.
4. The need for legally binding regulatory instruments at national and international levels
In the challenges identified, the working document refers to the absence of legally-binding
regulatory instruments which “limits the ability of (…) governments 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. This prompted calls for a global normative
4 Working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce
the Harmful Use of Alcohol, 14th November 2020, p.4
5 Action area 3: partnership, dialogue and coordination, p.16
6 See above, item 2
WMA page 4
law on alcohol at the intergovernmental level, modelled on the WHO Framework Convention on
Tobacco Control”.
Regretfully, the actions recommended later in the plan to the attention of Member States do not
effectively address those challenges. Yet, the “best buys”, promoted by WHO-led SAFER initiative,
are recognised as the most cost-effective policy measures for alcohol control7
. Alcohol is
responsible for significant mortality and morbidity around the world and it is time for governments
to take their responsibilities. We recommend a more ambitious action plan including pertinent
regulatory and fiscal measures to reduce harmful alcohol consumption, such as:
– Effective restrictions on advertising;
– Setting a minimum unit price at a level that will reduce alcohol consumption;
– Regulation of access to, and availability of, alcohol by limiting the hours and days of sale,
the number and location of alcohol outlets and licensed premises, and with a minimum legal
drinking age.
To protect alcohol control measures, we further recommend that alcohol be classified as an
extraordinary commodity and that measures affecting the supply, distribution, sale, advertising,
sponsorship, promotion of or investment in alcoholic beverages be excluded from international
trade agreements. Health impact assessments of trade agreements constitute a necessity to protect,
promote and prioritize public health over commercial interests.
Finally, we support the proposal made in the introduction of the action plan to open discussion on a
global normative regulation of alcohol at intergovernmental level, modelled on WHO Framework
Convention on Tobacco Control.
***
07.12.2020
7 Working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce
the Harmful Use of Alcohol, 14th November 2020, p.2