Presentation to a Department of Trade and Industry workshop, Pretoria

Introduction

The SA Council of Churches (SACC) welcomes the opportunity to make submission on the Liquor Bill, dated 27^th June 2003 and affirms the importance of the objectives in the Bill as laid out in paragraph 2 (1) (a) and (b).

These are:

While there is no common policy on alcohol consumption by our member churches (some are committed to total abstinence while others permit drinking of alcohol in moderation) these denominations have structures of support for those who suffer because of their own or others' abuse of alcohol. Based on our support for the work of our member churches' attempts to cope with the consequences of alcohol abuse, we therefore address issues that have been unresolved since our previous submission. Furthermore, we expand on the ethos of social responsibility in the liquor industry and conclude with new recommendations. All these are aimed at recognizing that government and the industry, together with civil society, have a joint obligation in counting the cost to society that comes through alcohol abuse.

Therefore:

1. Further to our previous submission on the 1999 Liquor Bill we note that concerns about the establishment and funding of programmes to address the socio-economic impact of alcohol abuse remain unaddressed.



2. The Bill seeks to reduce the socio-economic cost of alcohol abuse solely by setting standards and regulating the manufacture, sale and distribution of alcohol. Whereas the 1999 Bill made a cross-sectoral National Liquor Advisory Committee responsible for designing and implementing programmes to combat abuse, the new Bill makes provision for a narrowly defined "National Liquor Policy Council", represented only by government. We are concerned that this body has no responsibilities either for the prevention or the treatment of alcohol abuse.



3. Decentralisation of the industry (manufacturing, distribution and sales), while desirable from the standpoint of economic fairness, may increase the availability and consumption of alcohol, thereby enhancing the potential for irresponsible use. We believe that the State has a moral obligation to have mechanisms in place to minimise the adverse effects of alcohol consumption.



4. Although the regulation of alcohol sales is left up to the provinces, the revenue from such sales accrues to national government. To the extent that such revenue should be a primary source of funding for programmes to combat alcohol abuse, there is a gap between revenue and expenditure. Revenues from excise taxes on alcohol should be earmarked for alcohol abuse prevention and treatment programmes and should be allocated to the provinces if they are to be responsible for implementing such programmes.

Principles for an "ethos of social responsibility"

5. We fully support the aims of the new bill to promote "an ethos of social responsibility in the industry" but note with concern that there appear to be no mechanisms to address this objective. We therefore urge government to utilise the National Liquor Policy Council or a similar body to put structures in place that enable the industry to take responsibility for harms that alcohol abuse can cause to people. Some of the ways in which such social responsibility may be made tangible by the government and industry could be through contributions to the costs of, inter alia, research, understanding and lessening the impact of alcohol abuse on:
   • ill health and disease (e.g. are there health benefits to drinking?)
   • the criminal justice system
   • un/underemployment
   • homelessness and
   • the breakdown of family relations.
   • Drinking patterns of youth (e.g. how do "Happy Hours, "smart drinks" affect the age levels and drinking cultures of youth?)
   • Vulnerable groups such as Youth, young homeless, children of parents who misuse alcohol, the unemployed who live in poverty, women whose spouses abuse alcohol etc.


6. A further concern with the establishment of the Council as proposed in the new Bill is that, since it is comprised of government only, accessibility of the public to these meetings become irrelevant. Yet, in fact, we would argue that they become more necessary in the light of understanding a meaningful ethos of social responsibility within the industry. The SACC, therefore, urges that credible members from civil society be appointed to represent the public on the Council.



7. As in the past, we again support and acknowledge the importance of outlawing of the provision of liquor in lieu of wages (Section 8). We once again, however, raise our concern about the lack of identifiable enforcement of this important piece of legislation. The SACC strongly recommends that such enforcement be included amongst the tasks of the inspectorate.



8. Other matters for concern remain the absence of guidelines or a frame of reference on which provinces will need to decide, such as:
   • Trading hours
   • Sales in supermarkets
   • Sales at petrol stations


9. In the last mentioned case, it is important to point to the concern for public safety as it relates to driving. Social responsibility in the industry will need to work in conjunction with a package of other measures such as "Drive Alive" and "Don't Drink and Drive" campaigns. Purchasing liquor at a petrol station may become socially acceptable custom for drinking on a journey but the consequences could be hazardous for public road safety.

Conclusion

10. In conclusion, the SACC recommends that further consideration be given to defining the meaning that an "ethos of social responsibility" might have for government as well as the liquor industry. In our opinion such ethos can be given substance through a commitment by Council to provide for ongoing study on the awareness of the impact of alcohol on society. Public representation on the Council needs to be seriously reviewed. Finally, while alcohol level content needs to be printed on packaging, we recommend that other health information, such as may be contained on cigarette packets, be displayed on advertisements, products as well as in licensed premises.