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Page 1: Alcohol licensing and public health: Achieving our

Alcohol licensing and public health:

Achieving our objectives together

Friday 6 February 2015

London

Page 2: Alcohol licensing and public health: Achieving our

Introduction Madeleine Rudolph

Alcohol and Drugs Programme Manager

Public Health England, London

Page 3: Alcohol licensing and public health: Achieving our

Welcome Hugh Morris

Chair, London Drug and Alcohol Policy Forum; City

of London councillor

Page 4: Alcohol licensing and public health: Achieving our

Alcohol licensing

and public health 6th February 2015

Guildhall, London

Yvonne Doyle MD MPH Regional Director for London Health Adviser to the Mayor of London

Page 5: Alcohol licensing and public health: Achieving our

Aims of the event

To ensure a common understanding of the full nature of the challenges from

harmful drinking in the various parts of London

To work with partners towards a shared view of how public health skills best

play into the alcohol licensing agenda

To use this understanding and enhanced alliances to further reduce harm from

alcohol in London

5 Note: Alcohol harm is one of the seven PHE national priorities in 'From evidence into action' Oct 14

Page 6: Alcohol licensing and public health: Achieving our

6

Public health and the Licensing Act 2003 –

guidance note on effective participation

by public health teams

“PHE is keen to maximise the impact of public health within the local licensing

regimes and ensure that public health:

performs its role as a responsible authority effectively

is a consideration in local licensing policies

is represented in licensing forums and partnership groups

shares data and evidence with other responsible authorities”

LGA and PHE, October 2014

Page 7: Alcohol licensing and public health: Achieving our

% of obese

adults1

% of obese/

overweight

adults1

% of obese

Children2

% of obese/

overweight

children2

% reaching

recommended

physical

activity level3

% of

population

who smoke4

% of population

consuming 5+

drinks in one

occasion5

Suicides per

100,000 pop.6

Hong Kong - 19 7b 27b 40 13 6 11.8

Johannesburg - 59 - - 21 - - -

London 20 57 22 37 57 18 14 7.5

Madrid 8 42 2c 15c 23 28 14 2.7

New York 24 56 21d 39d 56 16 20 6.0

Paris 7 40 5e 16e 38i 40 15j 8.1

São Paolo 16a 47a 7f 25f 62j 15 - 5.4

Sydney 12 38 10g 29g 56 16 24 8.6

Tokyo 4 25 - 10 32k 20 - 21.3

Toronto 12 41 12h 32h 47 17 13k 6.9

7

Relatively ‘healthiest’ city

Relatively ‘unhealthiest’ city

Page 8: Alcohol licensing and public health: Achieving our

Making the Link between Licensing and Public Health

Dr Kay W Eilbert DPH Merton

Page 9: Alcohol licensing and public health: Achieving our

What is the Public Health Interest in Licensing

To enable people to be healthy and make healthy choices, we need to reduce the risks in the environment to health and increase healthy options

Page 10: Alcohol licensing and public health: Achieving our

Evidence Bigger Impact from Working on Wider Environment

Frieden, TR. 2010. A framework for public health action: the health impact pyramid American journal of public health, Vol. 100, No. 4. (April 2010), pp. 590-595

Page 11: Alcohol licensing and public health: Achieving our

London Healthy High Street Group Our Vision

• Our vision is to make London’s high streets vibrant and diverse places to visit, shop and enjoy, where the healthier option is the easier choice.

Who we are

• We are a public health network supported by and advised by local authority colleagues (licensing, environmental health (food safety, trading standards) and town planning), Public Health England and GLA.

What do we do

• share learning and expertise on often complex problems affecting more than one borough

• push the boundaries of what is possible and share the risks

• develop joint products that enable us to move forward together to make London’s high streets healthier

• identify where action is required at a higher level and advocate as a group for change.

Page 12: Alcohol licensing and public health: Achieving our

HHS Examples of Work

As part of the LHIN,

• Worked on the use of town planning restrictions to prevent further saturation of ‘hot food takeaways’, promoting healthier catering and establishing ‘cumulative impact zones’ for betting shops. Local resources produced by the group include:

• Fast food saturation

• http://www.lho.org.uk/viewResource.aspx?id=18208

• Betting shops

• http://www.lho.org.uk/viewResource.aspx?id=18207

Page 13: Alcohol licensing and public health: Achieving our

HHS - Alcohol and Licensing Work • Focus on tackling the impact of alcohol licensing on the high streets by

– developing a shared understanding of how Council regulatory approaches can be used to create healthier physical environments and

– incorporating planning & licensing into the JSNA to inform the development of local Health & Wellbeing Strategies.

• Work with Safe Sociable London Partnership

– Review of best practice across London for Statement of Licensing Policy

– List of potential conditions to use in responding to licensing applications

– Data tool to identify whether licensing applicants are located in high problem areas

• Work together across boroughs to

– Develop professional responses to consultations

– Lobby upwards where local action ineffective

Page 14: Alcohol licensing and public health: Achieving our

HHS - Next Steps

– Develop similar work for planning as SSLP licensing work

– Develop a toolkit that brings together the planning and licensing work for Public Health, licensing and planning colleagues

Page 15: Alcohol licensing and public health: Achieving our

Contact us:

Healthy High Street Lead: Jin Lim

e.mail: [email protected]

LDsPH Lead: Dr Kay Eilbert

Email: [email protected]

Page 16: Alcohol licensing and public health: Achieving our

Public Health and the Licensing

Act 2003

Madeleine Rudolph PHE London - Alcohol and Drugs Team February 2015

Page 17: Alcohol licensing and public health: Achieving our

“To be clear, this is not about stopping responsible drinking or

adding burdens on business. This is about promoting the

responsible sale and consumption of alcohol. This is about taking

alcohol related harms seriously.”

Section 182 Revised Guidance, Home Office, October 2014

17 Public Health and the Licensing Act (2003)

Page 18: Alcohol licensing and public health: Achieving our

Licensing and Health “Health bodies may hold information which other responsible authorities do

not, but which would assist a licensing authority in exercising its functions.

This information may be used by the health body to make representations in

its own right or to support representations by other responsible authorities,

such as the police.

Such representations can potentially be made on the grounds of all four

licensing objectives.

Perhaps the most obvious example is where drunkenness leads to

accidents and injuries from violence, resulting in attendances at emergency

departments and the use of ambulance services. Some of these incidents

will be reported to the police, but many will not. Such information will often

be relevant to the public safety and crime and disorder objectives.”

Section 182 Revised Guidance

18 Public Health and the Licensing Act (2003)

Page 19: Alcohol licensing and public health: Achieving our

Context • Legislative changes – health as a Responsible Authority

• Revised Home Office Section 182 Guidance

• Public Health move to Local Authorities (and PH grant)

These changes have created better opportunities to work together

Currently,

• progress has been made in working towards shared objectives

• there is variation in knowledge and experience in relation to both licensing

and public health

There is no London answer – variation in issues, aims and ambitions – but

sharing learning and experience remains valuable

19 Public Health and the Licensing Act (2003)

Page 20: Alcohol licensing and public health: Achieving our

Published October 2014:

20 Public Health and the Licensing Act (2003)

Page 21: Alcohol licensing and public health: Achieving our

Purpose of the Guidance • Practical ways to maximise the effectiveness of public health engagement

in licensing

• Introduce public health to licensing and licensing to public health

Responds to reported lack of understanding

Supports partnership working

• How public health could contribute to the current licensing process

Provide tailored information, reduce concerns and confusion

Reducing feeling of need to wait for a health licensing objective

Current case studies

• Provides a prompt for conversations with other responsible authorities

• Can support a stock take to review current health engagement in licensing

.

21 Public Health and the Licensing Act (2003)

Page 22: Alcohol licensing and public health: Achieving our

Your local system

• Is public health a consideration in local licensing policies?

• Is public health represented in local licensing forums and partnership

groups?

• Does public health share data and evidence with other responsible

authorities?

• How can we work together to maximise the effectiveness of health

contributions?

22 Public Health and the Licensing Act (2003)

Page 23: Alcohol licensing and public health: Achieving our

Statement of Licensing Policy

What public health can do:

• engage with the licensing authority to find out when the SLP is to be reviewed and

what the review process will be

• conduct a health-impact assessment of alcohol in the local area; or, where one has

been completed, assess its relevance to licensing

• engage with and collect the local views of the community and wider public health

community

• investigate the health data for the area, including the wider public health and local

alcohol profiles for England (LAPE) data

• engage the health and wellbeing board (HWB) in the consultation process to identify

issues that would benefit from the support of licensing

We will hear more about this from Matthew Andrews and Colin Sumpter

23 Public Health and the Licensing Act (2003)

Page 24: Alcohol licensing and public health: Achieving our

Cumulative Impact Policies

Public health might add:

• treatment data, including the number of people in the area in structured alcohol

treatment

• deprivation in the area

• data on alcohol consumption in the local area

• statistics from the local alcohol profiles for England (LAPE)

• Information from a study commissioned specifically for this purpose

Example later from Colin Sumpter and Matt Egan (Islington)

24 Public Health and the Licensing Act (2003)

Page 25: Alcohol licensing and public health: Achieving our

Responding to applications As a responsible authority, the DPH may, where they have appropriate evidence:

• make relevant representations on the likely effects of the grant or variation of a

premises licence on one or more of the licensing objectives

• make relevant representations on the review of a premises licence where problems

occur after the granting or variation of the licence

• issue an application for the review of a premises licence

• take a key role in identifying and interpreting health data and evidence

SSLP guidance and experience from Lambeth and Islington

25 Public Health and the Licensing Act (2003)

Page 26: Alcohol licensing and public health: Achieving our

Guidance and Licence Conditions

The DPH may:

• bring together operators, responsible authorities and the community to address the

impact of licensed premises on local populations

• engage with elected members - local knowledge to pinpoint hotspots of local alcohol

harm or high levels of consumption

• engage with the applicant to clarify public health concerns, potentially leading to the

incorporation of conditions which address these concerns

• use information, expert opinion and local intelligence from stakeholders and

agencies, such as alcohol treatment providers, homeless hostels and safeguarding

children services, which often have little engagement with local licensing processes

• ensure licence applicants are asked to demonstrate local knowledge (Police Reform

and Social Responsibility Act, 2011)

Next we will be hearing from Sue Holden – South Leeds alcohol licensing guidance

26 Public Health and the Licensing Act (2003)

Page 27: Alcohol licensing and public health: Achieving our

Local Licensing Guidance

Page 28: Alcohol licensing and public health: Achieving our

How did this all start?

• Joint Strategic Needs Assessment 2012, NHS Leeds highlighted issues in South Leeds

Page 29: Alcohol licensing and public health: Achieving our

JSNA 2012, NHS Leeds

• If you live in LS10 or LS11 you can expect your life expectancy to be lower than that of residents in other areas in Leeds

• 10 years lower than in Wetherby

• Alcohol misuse, obesity, smoking contributory factors

Page 30: Alcohol licensing and public health: Achieving our

Alcohol misuse and violence

• 14,000 domestic related incidents reported to the police in 2011

• 4,000 in City and Holbeck Division (28.6%)

• Domestic violence accounted for 33.6% of violent crimes in same Division

Page 31: Alcohol licensing and public health: Achieving our

Alcohol related admissions to hospital

Holbeck South Leeds

Leeds Average

Alcohol specific admission (/1000)

17.6 10.9 6

Alcohol attributable admission (/1000)

30.8 24.6 18.7

Page 32: Alcohol licensing and public health: Achieving our

Obesity

• National Obesity Observatory’s Report on Obesity

• Alcohol consumption can lead to increase in food intake

• Excess body weight and alcohol consumption appear to act together to increase the risk of liver cirrhosis

Page 33: Alcohol licensing and public health: Achieving our

Summary

• Area of deprivation

• Diverse area

• Low numbers of pubs

• High numbers of off licences and takeaways

• Nearly every corner shop sells alcohol

Page 34: Alcohol licensing and public health: Achieving our

• Obesity higher than the Leeds average

• Smoking rates are almost double the Leeds average

• Diabetes, COPD, CHD higher than the Leeds average

• Admission for alcohol related conditions are high

• Mortality rates for under 75 are much higher than the Leeds average

Page 35: Alcohol licensing and public health: Achieving our

Local concerns

• The wide and obvious availability of alcohol

• The contributory factor in possible link between violent crime and domestic violence and exacerbated by the availability of alcohol

• The higher proportion of premises licensed for alcohol for consumption off the premises

• The ease at which persons with mental health or alcohol dependancy problems to obtain alcohol

Page 36: Alcohol licensing and public health: Achieving our

Local concerns

• The ease at which people who are already drunk can obtain alcohol

• The normalisation of alcohol abuse and effect on children

• The supply of alcohol to children

• The accumulation of premises providing takeaway food and off sales of alcohol

• Littering of food wrappers and waste food originating from takeaways

Page 37: Alcohol licensing and public health: Achieving our

How do we make a change?

• Council and NHS Leeds formed multi-agency group

• Planning

• West Yorkshire Police

• Licensing

• Health

• Domestic Violence team

• Treatment services

• Youth services

Page 38: Alcohol licensing and public health: Achieving our

Licensing

• All actions must be appropriate to promote licensing objectives

• Crime and disorder

• Public safety

• Public nuisance

• Protection of children from harm

• No public health objective

Page 39: Alcohol licensing and public health: Achieving our

How do you consider health harm?

• Liaison

• Responsible retailing

• Affect change through providing information

• Cajoling, convincing, educating

• With support from the Police, Health and Environmental Health

• Consider crime & disorder and protection of children from harm

Page 40: Alcohol licensing and public health: Achieving our

Extract from S182 Guidance

The applicant must have regard to: □ The layout of the local area and physical environment

including crime and disorder hotspots, proximity to residential premises and proximity to areas where children may congregate

□ Any risk posed to the local area by the applicants’ proposed licensable activities and any local initiatives (for example, local crime reduction partnerships or voluntary schemes including local taxi-marshalling schemes, street pastors and other schemes) which might mitigate potential risks

Page 41: Alcohol licensing and public health: Achieving our

It goes on to say…

It is expected that enquiries about the locality will assist applicants when determining the steps that are appropriate for the promotion of the licensing objectives…

… The majority of information which applicants require should be available in the licensing policy statement in the area. Other publicly available sources which may be of use to applicants include:

Page 42: Alcohol licensing and public health: Achieving our

• the Crime Mapping website;

• Neighbourhood Statistics websites;

• websites or publications by local responsible authorities;

• website or publications by local voluntary schemes and initiatives; and

• online mapping tools.

Page 43: Alcohol licensing and public health: Achieving our

Will this work?

• Many applicants do not have English as their first language

• Many applicants do not have easy access to this information

• Interpretation of crime mapping websites, neighbourhood statistics may be difficult

The council can help with this.

Page 44: Alcohol licensing and public health: Achieving our

Local Licensing Guidance - Aim

• To provide guidance for applicants

• To provide the information required by the S182 Guidance

• To encourage business to take responsibility for the reduction of health harms

• To provide guidance for Licensing Committee

• To highlight the application is in a sensitive area and provide potential conditions

Page 45: Alcohol licensing and public health: Achieving our

Local Licensing Guidance - Aim

• To go further than we can through the legislation to encourage and foster responsible retailing

Page 46: Alcohol licensing and public health: Achieving our

How was it written?

• Collated health data

• JSNA2012

• Local information

• National information

• Collated information from partner agencies

• Environmental health

• Police

• Collated licensing profile data

Page 47: Alcohol licensing and public health: Achieving our

Consultation and approval

• Guidance does not need full consultation

• Was placed on website for comment during policy consultation

• Approved by Licensing Committee working group

• Endorsed by Licensing Committee

Page 48: Alcohol licensing and public health: Achieving our

How does it work in practice?

• Dialogue with applicants

• Meet face to face, phone, email

• Agree measures to go in operating schedule

• If measures agreed, no representation

• If not, representation submitted based on licensing objectives and goes to hearing

Page 49: Alcohol licensing and public health: Achieving our

Measures - Crime and disorder

• The display of alcohol will be in a designated area of the premises which is supervised directly by staff from the counter area

• The display of high strength beers, ciders and lagers of 7.5% alcohol by volume (abv) or higher shall be in an area accessible only by staff

Page 50: Alcohol licensing and public health: Achieving our

Measures - Prevention of public nuisance

• Staff will make hourly checks around the premises and remove any litter, including takeaway wrappers, can and bottles

Page 51: Alcohol licensing and public health: Achieving our

Measures - Protection of children

• There will be no window display posters or similar advertising containing any reference to alcohol on the premises shop frontage or the highway abutting the premises.

Page 52: Alcohol licensing and public health: Achieving our

What is the outcome likely to be?

• Refusal only in exceptional circumstances

• Must take the least onerous approach

• If subcommittee convinced by the representation:

• Conditions

• Reducing hours

• Removal of activities

Page 53: Alcohol licensing and public health: Achieving our

Example of successful liaison

• Asda

• Agreed that alcohol would be stored away form entrances

• Venus Foods

• Agreed to display health information

• Agreed not to promote alcohol in windows

• Agreed multiple sales of alcohol to individuals will be risk assessed in relation to alcohol harm

Page 54: Alcohol licensing and public health: Achieving our

What’s next?

• New local licensing guidance for other areas

• Local Licensing Guidance developed for inner west and inner east areas

• Streamlined approach with applicants

• Less time consuming

• Just as effective

Page 55: Alcohol licensing and public health: Achieving our

Lessons Learned

• Needs ongoing involvement from partners to review applications and make representations

• Can be a ‘way in’ to speak with business owners at a time when they are compliant

Page 56: Alcohol licensing and public health: Achieving our

Contact

Susan Holden

Principal Project Officer

Leeds City Council

0113 395 1863

[email protected]

Page 57: Alcohol licensing and public health: Achieving our

Public Health Licensing Approach in London

Safe Sociable London Partnership

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 58: Alcohol licensing and public health: Achieving our

Why Licensing?

• Managing availability is one of the most effective ways to reduce harm.

• New arrangements have brought Public Health into the sphere.

• There is a lot of scope to improve the effectiveness of licensing through data and partnerships.

• Its all about prevention.

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 59: Alcohol licensing and public health: Achieving our

So What have we done about it?

• Firstly, we established a London Licensing Network to bring together all the people involved in licensing in London to tell us what they wanted.

One of the key things we were told was that there was a significant need for data - so we developed a data pack in

conjunction with key partners.

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 60: Alcohol licensing and public health: Achieving our

Licensing Information Pack 2013 • Produced by the Safe Sociable London

Partnership

• Designed to help local teams gain a more

accurate picture of the impacts of alcohol in

their local area

• Includes a series of innovative case studies

that highlight how local teams are already

working together

• Includes links to data sources to ensure that

teams have all the necessary information

they require when making licensing

decisions

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 61: Alcohol licensing and public health: Achieving our

• Secondly we talked to Director’s of Public Health about what they wanted.

They wanted an easy process to be able to respond consistently

and effectively to licensing applications, without taking up too much time and resource

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 62: Alcohol licensing and public health: Achieving our
Page 63: Alcohol licensing and public health: Achieving our

Step 1: Identifying Criteria • A set of criteria was developed based upon local licensing and public

health priorities to identify where applications are clearly ‘green’ or ‘red’.

• This was based on both the application and local priorities • The role of RAs including public health is to comment on

applications and make representations to the licensing authority if they think the application threatens of the statutory licensing objectives

• The licensing objectives under the 2003 Licensing Act are:

• the prevention of crime and disorder • public safety • the prevention of public nuisance • the protection of children from harm.

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 64: Alcohol licensing and public health: Achieving our

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 65: Alcohol licensing and public health: Achieving our

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 66: Alcohol licensing and public health: Achieving our

Step 2: Scanning Tool Working with Greater London Authority we developed a

scanning tool that allows local partners in public health to identify what types of data they have and what the data says about the local environment in which the licensed premise sits

To provide a snap shot of the data/area – Bulls eye chart

– Dashboard

From this public health teams can drill down into the data and see what evidence is available to make a response

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 67: Alcohol licensing and public health: Achieving our

Step 3: Data

Providing access to data through:

– Data Pack

– GLA’s Safe Stats website

– Other local data and information

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 68: Alcohol licensing and public health: Achieving our

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 69: Alcohol licensing and public health: Achieving our
Page 70: Alcohol licensing and public health: Achieving our

Step 4: Decision Matrix We developed a decision matrix to help DsPH

to decide if they want to make a response and options for what the response could be.

Things to consider: – Enough data/Evidence

– Who else is making a rep

– Discussion with applicant

– Conditions/Objections

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 71: Alcohol licensing and public health: Achieving our

This tool is useful but…..

• Need to have an understanding of Licensing

• Linking to the objectives

• Need to be confident to present the information and your representation

• Need to know your local Statement of Licensing Policy

• Guidance from Licensing and Police colleagues

• Talk to your population

• weigh up the options

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

Page 72: Alcohol licensing and public health: Achieving our

Consultation

This tool was developed through consultation with partners including licensing officers, police and public health

This tool will bring consistency, certainty and a way to access and use evidence that will make public

health’s role easier to engage with

Safe Sociable London Partnership Care about others, care about yourself, care about your drinking

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Public Health and Licensing: Our Approach

February 2015

Colin Sumpter

Public Health Strategist

Camden and Islington Public Health

Page 75: Alcohol licensing and public health: Achieving our

Outline

• The Camden and Islington context

• Range of approaches employed locally to tackle alcohol harm

• Partnership working

• Supply-side interventions:

– Influencing the Statement of Licensing Policy

– Making representations as a responsible authority

• Getting started with Public Health involvement

• Conclusions

Page 76: Alcohol licensing and public health: Achieving our

Alcohol consumption

Lower Risk: 56%

Abstainers: 21%

Source: Local Alcohol Profiles England (LAPE) 2014

6%

16%

Alc

ohol inte

rventions

• Cumulative Impact Policies

• Representations

• Late Night Levy

• Reducing the Strength

• A&E Data Sharing

• Treatment system

• Alcohol Awareness Training

• IBA

• Campaigns (AAW, DJ, Freshers)

• Don’t Bottle It Up

Supply

D

em

and

Harm

Increasing Risk:

Higher Risk:

Page 77: Alcohol licensing and public health: Achieving our

Alcohol and Public Health

• As a public health issue the long term health impact of alcohol

consumption is the ‘iceberg’ under the visible ‘tip’ of acute issues

which are primarily focused on by other responsible authorities

• Evidence base that reducing availability and affordability of alcohol

reduces consumption: 3,000 licensed premises in Camden and Islington

Emergency

admissions Assaults

Family breakdown

Chronic Liver

Disease

Alcohol-related

admissions Long-term

mental health

ASB/Noise

Cancers

Alcohol

Dependency

High blood

pressure Obesity

Lost productivity

and unemployment

Page 78: Alcohol licensing and public health: Achieving our

Achieving our shared goal

Shared goal across authorities: Reducing alcohol harm

• Supply-side interventions for public health are entirely reliant on

partnership working, nothing can be achieved alone.

• Vital partners for licensing process include:

– Licensing

– Community Safety / Police

– Acute Health / Ambulance

– Trading standards

• This work is most effective through a combination of policy making

and systematic application review

• Public Health can also provide skills and impetus to ad-hoc projects

that work toward this goals such as Reducing the Strength projects,

Responsible Retailer Schemes or other new initiatives

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What facilitates partnership working?

Committed and interested senior Councillors / Leader / Police

Engaged Directors of Public Health and Public Protection

Named, active and well connected PH and Licensing leads

A well-established local evidence base

Regular action and activity!

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“Islington has one of the highest concentrations of licensed

premises in the country. We have some of the worst health

problems associated with excessive alcohol consumption. And we

have more crime, nuisance and family difficulties caused by alcohol

than most other parts of London. We are taking a firm stand to fix

these problems with a mix of sensible licensing policies and

rigorous enforcement”

Councillor Paul Convery, Lead Member for Community Safety

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STATEMENT OF LICENSING

POLICY

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Influencing Islington’s SoLP

Alcohol Summit, September 2012

Licensing Policy developed, 2013

Consultation period

SoLP Launch, Feb 2013

Monitoring and Implementation

Alcohol Summit, September 2016

APHR on Alcohol, May 2012

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Kingdon Model of Policy Making

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Cumulative Impact Policies and Framework Hours

• Public (The borough residents want the issue to be tackled):

– Feedback from residents that Night Time Economy harm was growing

• Problem (Alcohol harm is recognised as an issue in the borough):

– Annual Public Health Report raised the profile of alcohol harm

– Alcohol Summit collated evidence in the round of rising alcohol harm

• Policy (There is an effective intervention available):

– Successful, popular but very small CIP in previous SoLP (Clerkenwell)

– Rebalancing’ of the Licensing Act in 2012

– End of the Olympics – more time available!

• Political (Those in power are willing to implement it):

– ‘New senior police officer with an aim to ‘Reclaim the Night’

– Change of Council political leadership

Page 85: Alcohol licensing and public health: Achieving our

Consultation approach

• By law before determining its policy a licensing authority must consult:

responsible authorities; licence holders; businesses; and residents

• Islington chose to expand this through active engagement

• Dedicated communications plan was developed to reach:

– Internal: Email to councillors; Safer Islington Partnership; staff newsletter

– Health bodies: Public Health; CCG; Mental Health Trust; Business

Improvement Districts; Chamber of Commerce

– Licensees and businesses: Pubwatch; Town Centre Management

– Residents: contacted all residents who had ever made representations;

website front-page; resident magazine; twitter

– Resident meetings: Ward Partnerships; Safer Neighbourhood Panel;

Housing ASB

– Neighbouring boroughs

• Result: 500 responses, the large majority strongly in favour of

introduction

• Challenge in getting positive responses to validate approach

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Public Health influence on the SoLP

• Public Health consultation response set out the case for Health

– Matt will cover in some more detail the evidence used

• ‘Alcohol and Health’ included as an appendix to the overall policy,

written by Public Health

Wider health evidence influenced the development of the policy and made

it stronger from the public health point of view

BUT

Still have to rely on evidence from the tip of the iceberg when we look at

individual applications…

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REVIEWING APPLICATIONS

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Public Health approach to applications

• Notified of all licensing applications: Get on all mailing lists

• To be relevant, must have regard to the potential impact on the

licensing objectives:

– The prevention of crime and disorder;

– Public safety

– The prevention of public nuisance; and

– The protection of children from harm

• Also can speak to Cumulative Impact Policy but only in

conjunction with one or more licensing objective.

• Objectives don’t explicitly include public health, but public health

shares the aims of all the objectives.

• Can ask for rejection, amendments or conditions

Page 89: Alcohol licensing and public health: Achieving our

Representations: Spreadsheet tool

Page 90: Alcohol licensing and public health: Achieving our

Representations: Spreadsheet tool

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Making Representations

• The licensing tool is a data analysis tool, not a decision making tool

• Always discuss potential representation with licensing and Police

• If a representation is agreed to be appropriate, summarise facts on 2 sides of A4

• Set borough context briefly, focus primarily on small area statistics

• Employ the wording of the licensing objectives, e.g.:

– Public Safety: Alcohol-related crime and violent crime, and alcohol-related

ambulance callouts by Lower Super Output Area (LSOA)

– Protection of Children from Harm: Review due to sales to under-age focus

on health harms in children and the importance of an alcohol-free childhood

• Make clear statement of grounds at outset, include evidence but make clear

recommendation at end (two bullet points)

• If required, at Licensing Committee you will be required to summarise it in a short

presentation

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Results

• Looked at and logged a lot of applications, learnt a lot about the

borough’s licensed premises, made good connections

• Also, made 15 representations to date:

– 6 applications refused

– 4 applications had hours of sale reduced

– 3 revoked after review

– 2 voluntarily withdrawn

• 4 appeals to date:

– 1 decision upheld, 1 partially upheld, 1 revocation amended to suspension, 1

appeal voluntarily withdrawn (Sainsbury’s – first dry supermarket).

• Licensing colleagues tell us they’re receiving fewer, but better,

applications

• Sometimes, we have to say we have no evidence!

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Conclusions

• Responsible authorities have the same objective: Reduce alcohol harm

• Have a named contact in PH (operational level). Find out who your

partners are and make connections. Attend licensing meetings whether

submitting evidence or not.

• Focus on strengths of PH: Evidence and professional judgement

• Put in hard groundwork on getting policies in place: SoLP; CIPs;

conditions; etc. – be ambitious in what is put forward in policies

• Don’t be nervous about putting in representations and don’t be afraid of

going to appeal – there is nothing to lose and much to gain

• Future efforts could include joint-funded posts building on joint-resourced

projects and the lobbying for health as a licensing objective

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School for Public Health Research 06/02/2015

Cumulative Impact Policies In

Action: Evaluating a complex intervention to prevent

alcohol related harms

Health as a licensing objective for Cumulative Impact

Policies

This is an outline of independent research funded by the

National Institute for Health Research’s School for Public Health Research (NIHR SPHR).

The views expressed are those of the author(s) and not necessarily those of the NHS, the

NIHR or the Department of Health.

February 6th, 2015

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• Charlotte Ashton

• Matt Egan

• Daniel Grace

• Janice Gibbons

• Jan Hart

• David Humphreys

• Karen Lock

• Fred Martineau

• Elizabeth McGill

• Sarah Milton

• Triantafyllos Pliakas

• Colin Sumpter

Collaborators

This work was supported by the National Institute for Health Research

(NIHR)’s School for Public Health Research (SPHR). The views

expressed are those of the author(s) and not necessarily those of the

NHS, the NIHR or the Department of Health.

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• Efforts to reduce alcohol-related harms based

on the view that “less is best”

– Controls on affordability

– Controls on the physical availability

• Controls on availability

– Restrictions in hours and days of sale

– Limits on number of outlets (outlet density)

• International evidence supports use of

controls on alcohol availability (Martineau et

al., 2013)

Controlling alcohol availability

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• Restrictions on the physical availability of

alcohol:

– Stronger powers to control density

– Health as a licensing objective

– Early morning restriction orders (EMROs)

• Aiming to “empower local areas to make

decisions for themselves”

• Local licensing has a potentially

important role in public health problems

related to alcohol

The 2012 Alcohol Strategy

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Research Methods

• Mixed Methods research

• Qualitative analysis, informed by

Institutional ethnography, has

included:

– documentary analysis, non-

participant observation (e.g.,

licencing committee meetings),

individual and focus group

interviews

• Informing our Quantitative analysis

examining the effects of CIPs (on

applications, social and health harms

etc.)

Example of representations

drawn upon in licencing

meetings

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Islington: Second Wave of CIZs

“I think that we probably took perhaps a bit

more of a flexible approach, a longer term

approach…we did have in our minds that

there would be dispersion when we drew

the boundaries up. We thought about having

a ward-based approach but that just didn’t

give us the right fit…It was easier

administratively but didn’t sort of meet our

objectives…and obviously we had to keep

our eye on the evidence…” (Islington

Council, emphasis added)

– Islington Introduced in 2011 (purple) and

2013 (blue)

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Alcohol Related Harms by CIZ

Failed underage test purchases/sq km

5 - 1

0

10 -

15

15 -

20

20 -

25

25 -

30

30 -

35

Non-duty alcohol seizures/sq km

0 - 3

3 - 6

6 - 9

9 -

12

12 -

15

15 -

18

Alcohol-attributable ambulance callouts/sq km

100

- 150

150

- 200

200

- 250

250

- 300

300

- 350

350

- 400

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Alcohol Outlet Density by CIZ

Total number of licensed premises/sq km

0 - 5

0

50 -

100

100

- 150

150

- 200

200

- 250

250

- 300

300

- 350

Number of on-licensed premises/sq km

0 - 5

0

50 -

100

100

- 150

150

- 200

200

- 250

250

- 300

300

- 350

Number of off-licensed premises/sq km

15 -

20

20 -

25

25 -

30

30 -

35

35 -

40

40 -

45

45 -

50

50 -

55

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CIZs and licence applications

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• Outlet Density (primary)

• Opening Hours

Other Possibilities:

• Availability of some products?

– e.g., removal/not selling superstrength beer or cider

• Commitment to other alcohol related initiatives?

– e.g., enhanced training of staff regarding not selling to

minors

• Affordability?

What are the mechanisms by which

CIPs operate?

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• Local Economy

• Crime & Disorder

– Public Nuisance, Public Safety,

Violence & Drink Driving

• Child Protection

• Health

• New premise applications

– in other areas within and outside

borough (‘Spillover’)

What are the Intermediate and

Long Term or Ultimate Effects?

(Pub Signs,

London,

2014)

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Islington CIP logic model for analytical

framework

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Define the

intervention and the

research question(s):

Engagement /

qualitative research

with stakeholders

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IMMEDIATE

OUTPUTS

Is intervention

achieving its basic

functions?

Quants: pre and post

data on licenses and

license applications

Qual: more

detailed look at

license

application and

decision making

process

Page 109: Alcohol licensing and public health: Achieving our

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INTERMEDIATE

OUTCOMES

Short term consequences on

the alcohol retail

environment

Quants: number and type of

on and off licenses in area.

Quantified trading

standards.

Qual: richer data

on outlet,

marketing and

‘responsibility’

behavours

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POPULATION OUTCOMES

Short term consequences on

people’s behaviours.

Quants: alcohol attributed

ambulance call outs and

crime or anti-social

behaviour

Qual:

understanding

how target

populations

perceive and

respond to

changes

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LONG TERM OUTCOMES

(problems attributing these

to the intervention)

Quants: alcohol hospital

admissions and chronic

conditions

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Concluding Thoughts

• Enforcing a CIP is possible but requires work

– evidence production, commitment and

involvement of diverse actors etc.

• Some contested understandings of CIPs remain

– on grounds of evidence, purpose etc.

• Understanding intermediate and long term effects

complex question requiring additional quantitative

analysis

– Where and how health enters the equation

demands further reflection

– Need to consider link of CIPs with other alcohol

related policies & interventions

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Questions & Comments

If you have further questions

or comments please contact me:

[email protected]

Page 114: Alcohol licensing and public health: Achieving our

Panel Q&A

Page 115: Alcohol licensing and public health: Achieving our

Workshops

Page 116: Alcohol licensing and public health: Achieving our

Event summary Alison Keating

Head of Alcohol and Drugs Team

Public Health England, London

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Alcohol licensing and public health:

Achieving our objectives together

Friday 6 February 2015

London