Last year the World Health Organization launched a public consultation on its draft “Global Alcohol Strategy to Reduce the Harmful Use of Alcohol”. It is not obvious that the world needs an alcohol strategy, nor does it seem an obvious priority for the WHO in the middle of a pandemic. National governments are quite capable of deciding how alcoholic drinks are taxed and regulated without pressure from a UN agency. Some countries allow you to buy a beer at any time day or night. Others have total prohibition. The huge differences in the way in which governments treat alcohol make it an unlikely candidate for global regulation, but the World Health Organization is keen to leave its mark on the issue nonetheless.
The WHO has had a Global Alcohol Strategy since 2010, but the draft of the new strategy represented a significant shift in emphasis. While the 2010 plan acknowledged the problems created by the illicit market, which makes up 25% of global alcohol supply and more than 50% in some countries, the working document barely mentioned it. And while the 2010 focused on alcohol-related harm, the working document treats mere consumption of alcohol as a problem in itself.This went largely unreported in the media because the WHO gave journalists a better story when they said that more efforts should be made to prevent “women of childbearing age” from drinking. This was yet another public relations disaster from an agency that has careered between tragedy and farce under the leadership of Dr Tedros Adhanom Ghebreyesus. From making Robert Mugabe a “goodwill ambassador” in 2017 to allowing Covid-19 to spread rather than offend the Chinese, the WHO has had a bad few years.
After launching a public consultation on its alcohol plan, the WHO came back with a new draft last month in which the reference to childbearing women was wisely deleted. Elsewhere, however, the problems remain. The new draft is actually even worse because the authors have inserted an unjustifiable and wholly unrealistic target of reducing per capita alcohol consumption worldwide by 20 per cent by 2030.
There was no target for per capita alcohol consumption in the 2010 plan. There was a target in the WHO’s Global Non-Communicable Disease Action Plan of 2013 but that was to reduce the “harmful use of alcohol, as appropriate, within the national context” by 10 per cent. The new proposal of a 20 per cent reduction in per capita alcohol consumption cannot be justified on health grounds since consumption is not a measure of health, and it is patently unachievable in such a short space of time. There is no reason to believe that this target could be met even if every member state introduced the WHO’s so-called “best buys” (tax rises, advertising bans, etc.) tomorrow.
Where did this target come from? A clue may lie in last year’s consultation which was inundated with submissions from temperance organisations. Many of these submissions were very similar. Some were identical. One of the biggest organisations in this network is Movendi International which was, until recently, known as the International Order of Good Templars. It was formed in the 1850s to campaign for the total prohibition of alcoholic beverages, but has since taken a more incremental approach to building an alcohol-free world. In its submission, Movendi called on the WHO to set a target of a 30 per cent reduction in per capita consumption by 2030, saying: “We propose a bold and ambitious overall target of a 30% reduction of per capita alcohol consumption until 2030”.
This exact phrase was repeated word for word in the consultation responses of numerous other organisations, ranging from IOGT Iceland and Slovenia’s Institute for Research and Development to Cambodia’s Khmer Youth Association, Kenya’s Alcohol Control Policy Network and Tanzania’s Network Against Alcohol Abuse. Duplicate responses were particularly common from temperance and public health organisations in Asia and Africa.
Organisations which endorse total abstinence from alcohol will naturally support any measures to suppress consumption. They can be expected to propose the most extreme targets for reductions in alcohol consumption, regardless of how unrealistic they may be. But pressure groups rooted in the temperance movement have very little public support and it is concerning to see the preferential treatment given to them by the WHO. Movendi, for example, is listed as a “non-state actor in official relations” with the WHO. Its spokespeople regularly appear at WHO conferences and it has an official arrangement with the WHO to “draft advocacy materials linked to WHO’s activities”, “increase support for alcohol control initiatives” and to produce “technical sessions and webinars to discuss and promote WHO’s global public goods in the field of alcohol prevention and control with content reviewed and approved by WHO in line with its policies and guidelines”. Movendi has also previously agreed to “help explore new or innovative ways and means to secure adequate funding for the implementation of the WHO Global strategy to reduce the harmful use of alcohol”.
In light of the close relationship between the WHO and the global temperance movement, it is reasonable to ask whether the WHO has simply split the difference between the 30 per cent target for consumption proposed by groups such as Movendi and the 10 per cent target for harmful use already in place in the NCD Action Plan to arrive at a target of 20 per cent for consumption. It is difficult to see any other logic to the decision since there is no evidence that a 20 per cent reduction is attainable or optimal. It is a false compromise; the “golden mean fallacy” writ large.
Since there is no prospect of this target being met, the WHO is setting up member states to fail. When 2030 comes around and this arbitrary and unrealistic milestone has not been reached, we can expect the WHO and its temperance partners to demand even tougher action, perhaps including a legally binding Framework Convention on Alcohol Control (modelled on the Framework Convention on Tobacco Control) that has so far been firmly rejected by member states.
Whatever the reasons for the sudden insertion of this target into the Global Action Plan, it is quite unacceptable. Insofar as the WHO has a mandate for getting involved in alcohol policy, it is in relation to health harms, not consumption. There is no reason to assume that a reduction in per capita consumption will necessarily lead to a reduction in alcohol-related harm. As the latest draft of the Plan acknowledges, wealthier countries tend to have higher rates of consumption but do not have higher rates of heavy episodic drinking.
The focus on consumption allows the WHO to push ahead with the kind of crude, supply-side policies that are popular with western public health academics but which can only discourage the sale of legal alcohol. Meanwhile, they virtually ignore illicit alcohol which is a bigger problem in most low and middle income countries. In contrast to the WHO’s 2010 plan, the new draft says almost nothing about the social, economic and health harms of black market booze and does not acknowledge the risks of increasing demand for homemade and illicit products by suppressing demand for legal products.
A new public consultation has now been launched and will run until 3 September. No doubt the temperance lobby will complain that the draft is still not extreme enough, but the WHO should listen to more moderate voices before it embarks on a plan that is designed to fail and which will be wholly unacceptable to many member states.
Cross-posted from the IEA blog. See also Henry Hill's article about the WHO at CapX.
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