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SARN response to WHO consultation

World Health Organization consultation on the working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce the Harmful Use of Alcohol

Submitted on 9 December 2020

We suggest four key points to strengthen the draft action plan:-

1) The role of economic operators 

We strongly agree that economic operators should “refrain from activities that may prevent, delay or stop the development, enactment and enforcement of high impact strategies and interventions to reduce the harmful use of alcohol.  (They) are encouraged to contribute to the elimination of marketing and sales of alcoholic beverages to minors and targeted commercial activities towards other high risk groups” (p.12).   

However, in some sections of the document, economic operators are given equal standing to other stakeholders, such as civil society and other UN organizations.  Alcohol adversely impacts 13 of the 17 UN Sustainable Development Goals ( yet the alcohol industry has attempted to undermine the focus on alcohol as an obstacle to sustainable development (  Therefore, the role of economic operators should be addressed in a separate section of the document, with attention given to their conflict of interest regarding public health.

2) Emphasis on evidence-based policies (WHO best buys / SAFER)

We strongly support an emphasis on each country implementing evidence-based policies to reduce alcohol-related harm (i.e. WHO best buys / SAFER).  This is especially important in LMICs which are particularly subject to interference from commercial interests.

3) Restricting digital alcohol marketing and protecting minors

One of the most cost-effective policies to reduce alcohol-related harm is to enforce bans on, or comprehensively restrict, alcohol advertising.  The digital marketing of alcohol represents new, high levels of risk, especially for minors. We strongly support statements in this document to regulate digital marketing and social media advertising. This is a global issue, which cannot be solved by any single country, and so it is appropriate that it should be led by WHO. 

4) The role of research / building research capacity

SARN builds capacity in alcohol research at a local, national and international level. SARN members contribute to the research evidence base which allows policymakers to effectively tackle alcohol-related harm, and provides NGOs with robust evidence for advocacy.  We therefore support the objective to “strengthen information systems and research for monitoring alcohol consumption, alcohol-related harm and policy responses at all levels with dissemination and application of information for advocacy, policy development and evaluation purposes” (p.9).  

However, we support a broad interpretation of the objective to focus on research which is “highly relevant to the development and implementation of alcohol policies” (p.18).  This should include qualitative research which is necessary to understand the social context of drinking in high risk groups (as attempting to implement interventions without understanding social and cultural drinking practices will be ineffective) (e.g. Emslie et al. 2017), rapid literature reviews and ‘reviews of reviews’ on emerging issues (e.g. Atkinson et al. 2019;  Fitzgerald et al. 2016), and using innovative methods to understand the lived experience of drinking across the harm continuum (Shortt et al. 2017), as well as more conventional epidemiological research.  


Atkinson A. et al. 2019. A rapid narrative review of literature on gendered alcohol marketing and its effects: exploring the targeting and representation of women.

Emslie, C., Lennox, J. and Ireland, L., 2017. The role of alcohol in identity construction among LGBT people: A qualitative study. Sociology of health & illness39(8), pp.1465-1479.

Fitzgerald, N., Angus, K., Emslie, C., Shipton, D. and Bauld, L., 2016. Gender differences in the impact of population‐level alcohol policy interventions: evidence synthesis of systematic reviews. Addiction111(10), pp.1735-1747.

Shortt, N.K., Rhynas, S.J. and Holloway, A., 2017. Place and recovery from alcohol dependence: A journey through photovoice. Health & Place47, pp.147-155.

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