brad s. krevor, ph.d, heller graduate school brandeis university march 30, 2005 the integrated...
TRANSCRIPT
Brad S. Krevor, Ph.D, Heller Graduate SchoolBrandeis UniversityMarch 30, 2005
The Integrated Responsible Retailing Systems Project
A new model to reduce the sale of age-restricted products to underage customers
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Background
Attorney General Consumer Protection Initiative:
4 Regional meetings (1999)
National CDC-sponsored meeting (March 2000)
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Background
Report on Best Practices for RR
Commissioned by Center for Substance Abuse Prevention (CSAP)
Diverse Report Committee
Review of evidence
Alcohol enforcement
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Background
Innovations of CSAP Report: • Completed a systematic review of components of RR
• Identified the critical nature of management systems
• Role of public agencies: enforce and assist licensees identify and implement Best Practices for RR
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Background
Paradox of enforcement:Enforcement is sine qua non of compliance…
… but public agencies have inadequate resources to inspection frequently
“Educate into compliance”: … but not when turnover rates > enforcement frequency
Wagenaar study (2005)
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Background
Paradox of enforcement:
Deterrent effect is undermined by uncertainty of how to avoid risk:
Policies do not translate into consistent clerk (or manager) performance
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Background
EAV Study for Miller Brewing Company:
Clerk is important determinant of whether the store is found to be compliant (EAV study)
TobaccoInspections
Baseline 1Compliance
Baseline 2Compliance
CompliantB1 & B2
Florida 81% 86% 66%
Iowa 43% 51% 33%
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Clerk characteristics: • Little or no loyalty to job or employer
• Aversion to confrontation
• Personal use of alcohol and tobacco, now or as
minor, may affect age-verification behavior
• Willful collusion
Impact of tight labor market and limited hiring pool
Background
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Integrated Responsible Retailing Model
a continuous system supported by the efforts of retailers, agencies, and other public and private stakeholders
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Protocols for age verification/ sales declination
Point-of-sales aids:
Signage
Specialty calendars
ID scanning
Hiring, Supervision,
Training
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A “Community Policing” model employs a “problem-solving” approach to underage access and use.
Identify and address actual sources of age-restricted products in the community
An involved, concerned community is decisive in motivating public agencies, which in turn can engage—and assist—retailers.
“Retailers as Active Partners”
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Responsible Retailing
Policies
• Laws and Regulations
• Enforcement protocols
• Penalties
• Funding
What Policies will encourage adoption of effective RR practices?
Public PolicyPublic Policy
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Background
2003 RR Forum 1st priority recommendation:Demonstrate and evaluate the integrated RR systems model.
Project partners:Alabama Alcohol Beverage Control Board
Iowa Division on Alcoholic Beverages
Missouri Dept. of Alcohol and Tobacco Enforcement
New Mexico Alcohol and Gaming Division
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Developing an operational model
1. Health care analogue: implementing clinical guide-lines in medical practice sites.
Example: In a1991 study, 60% of tobacco users reported that their primary care physician had not advised them to quit. What factors impede the adoption of clinical guidelines (1996) for treating tobacco dependence.
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Developing an operational model
Why primary care physicians don’t adopt guidelines: Unfamiliarity Time constraints: too busy Inability to overcome inertia of prior practice Doubts regarding effectiveness Doubts regarding self-efficacy (for tobacco) Aversion to confrontation
[note similarity to explanations for not checking IDs]
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Developing an operational model
Why primary care physicians do adopt guidelines:
Training (mixed results) Feedback on peer performance
Brandeis—Harvard study (1999): absence of resources and mechanisms is impediment.
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Developing an operational model
Assisting medical practice sites to implement clinical guidelines:
Planning Guide for Primary Care Practice Sites [and for Pre-Natal Care Practice Sites]
Promulgated by State of Vermont health department
Local hospital / health dept. provides medical sites with training and counseling
[Similar delivery system designs in Massachusetts, New Mexico, Oregon et al.]
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Developing an operational model
2. Business analogue for implementing Best Practices:
ExxonMobil Assurance of Voluntary Compliancea. Adoption of many Best Practices in CSAP Report
b. Continual monitoring
c. Remedial response to age-verification failures
d. Company-wide commitment
Transparency
How would one replicate the ExxonMobil model at the level of community?
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RR Systems Project
Phase 1 (Sept 2003 – May 2005):
Focus upon Tier 1: Retail-level
Objective: Develop tools to assist retailers and implementation strategies
Study Sites: Birmingham, AL Springfield, MO Santa Fe, NM Des Moines, IA
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RR Systems Project
Assistance to retailers:
1. Develop “A Planning Tool for [Iowa] Retailers” a quality improvement tool to assess current practices identifies absent Best Practices Promoted and supported by state Regulatory /
Enforcement agency: R / E Agency is engine that drives the model
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RR Systems Project
Assistance to retailers:2. Monitoring / Feedback
Multiple inspections by young adults Reports to retailers on individual inspections
Feedback—not penalties
Will include inspections by pseudo-intoxicated
customers
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RR Systems Project
Experimental Design: Arm #1: use of Planning Tool for Retailers Arm #2: use of Mystery Shopper reports Arm #3; use of both PT and MS reports Arm #4: control stores
60-80 stores per community (36 in Santa Fe)
Mostly gas station / C-stores (some package stores)
Mostly chains
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RR Systems Project
What we’ve learned in Phase 1:
Experimental design undermined by:
1. Change for chain stores occurs through district supervisor / trainer, not through individual store manager
2. Some chains introduced changes following state RR Forum
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RR Systems Project
Lessons from Phase 1:
Planning Tool for … Retailers
Useful self-assessment tool, especially for chains
Could be more explicit
Could be more prescriptive
Focus groups will be held in spring 2005
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RR Systems Project
Lessons from Phase 1:
Mystery Shopper Reporting
“50 year-old native American woman”
Use of feedback (Missouri experience)
Expand to capture opportunity of “teachable moment”
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RR Systems Project
Lessons from Phase 1: Variability of retailers
Chains Owner-operated
high Number of employees low
“ Turnover “
“ Need for Systems “
“ Level of technology “
“ Explicit policies “
no Manager is change agent? yes
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RR Systems Project
Phase 2 (beginning May 2005):
Focus: Community context (2nd tier of model)
Objective: Employ community policing principles to identify actual sources of alcohol (both commercial and social) in the community
“If you were 100% successful . . .”
Expand intervention
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RR Systems Project
Phase 3 (2006?):
Objective: conduct a multi-state community trial to evaluate the effectiveness of the “enforcement + assistance” model at the level of county, with study arms that employ various implementation strategies (e.g. voluntary, compulsory for violators, incentives) to engage retailers.
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Questions raised by RR Systems Project
Q. #1: How do we raise the level of performance in individual stores?
Andy’s Liquorette
ExxonMobil
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Questions raised by RR Systems Project
Q. #2: How do we engage retailers to adopt and sustain RR Best Practices?
Voluntary adoption: Corporate leadership Increase enforcement Build capacity: Field of Dreams fallacy Adopt BPs to discharge citation Mandatory adoption Retailer Incentives
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Questions raised by RR Systems Project
Q. #2: Potential retailer incentives
Reduced license fees
Mitigation for future infractions
Affirmative Defense for future infractions
Curtailment of routine compliance checks
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Questions raised by RR Systems Project
Q. #2: Incentives to engage retailers are problematic
Objections of Regulatory / Enforcement agencies
Compare: Susan Curry study Treatment for TB Brazil: payments to parents for 16 million school
children
Public health outcomes vs. personal responsibility Good Policy may be counterintuitive
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Questions raised by RR Systems Project
Q. #3: How do we create the capacity to sustain an RR system at the level of state and community?
Beyond current resources of R/E agencies
What would it cost to provide training, mystery
shopper feedback, enforcement?
Which entities can provide the “assistance” in the
“enforcement + assistance” model?
How can public resources be best applied?
How can public resources be leveraged?
Brad S. Krevor, Ph.D, Heller Graduate SchoolBrandeis UniversityMarch 30, 2005
The Integrated Responsible Retailing Systems Project