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1. Introduction
1.1 The National Union of Students (NUS) is the collective voice of students and students' unions in the United Kingdom. Our members consist of almost seven hundred autonomous students' unions, and through them we represent the interests of over seven million students in further and higher education.
1.2 In this consultation response we will be discussing the impact of the consultation proposals on both individual students and on students' unions as retailers of alcohol.
2. Overview
2.1 With alcohol, as with most subjects, NUS does not wish to generalise with regard to students. As a group, students are not homogenous. Many are mature students, many are from overseas, and many are from a variety of different faith groups. Almost 60 per cent of students work during term-time, and most are acutely conscious of the need to get a good qualification. The traditional school-leaver student is in the minority, and the idea that all students are drinkers is inaccurate. Indeed, despite the popular perception of their behaviour, students report broadly similar spending on alcohol compared with the wider population.
2.2 However, NUS is well aware that there remain significant numbers of students who do drink to excess, and we take our role in educating students seriously. We have long sought to encourage responsible drinking amongst students, as well as responsible retailing by students' unions. We regularly send out materials on safe drinking to students' unions for use in local campaigns, and have worked with organisations such as the Portman Group to target individual students. Through initiatives like Best Bar None we seek to promote and recognise responsible retailing of alcohol by students' unions.
2.3 Students' unions are on the whole responsible licensees. They are also evolving as the market they serve changes, with many creating alcohol free spaces, coffee shops and juice bars within their buildings to cater for the increasing number of students who choose not to drink alcohol.
2.4 Even amongst those who do drink, habits are changing. Full-time students are spending less on alcohol now than they were a decade ago – 50 per cent less in students' unions 2007 compared to 1997. When they do drink they are more likely to do so at home, having bought alcohol in supermarkets and off licenses, such sales having now exceeded the spend in bars and clubs more generally. More problematically, when they do choose to go out, there is fiercer competition from local clubs and pubs, often part of large, national chains, many of whom aggressively target the student market with cut-price drinks promotions.
2.5 Any commercial profit made by students' unions is reinvested in services: welfare advice, sports clubs and societies, volunteering projects, student media and a host of other activities. Students' unions want to act responsibly and most do: but the need to maintain sales in order to fund these important services has resulted in students' unions using similar drinks promotions, which we know can contribute to binge drinking and consequently anti-social behaviour.
2.6 Another great concern for NUS and students' unions are a number of companies operating organised bar crawls, such as Carnage which actively encourage irresponsible drinking and a binge culture amongst its participants. Although students' unions are rarely involved with these events, and despite the fact that NUS condemns them, they add to the negative views of student drinking and of students in general.
2.6 NUS has a vision of a society in which responsible drinking is the norm, and where young people, students and students' unions are not viewed in a negative light because of excessive alcohol consumption, both perceived and real. We do not want a drinks trade that promotes binge drinking amongst young people and whose tactics put pressure on students' unions to follow suit. We do want a student population who not only know the risks of excessive alcohol consumption but can accurately judge their own intake and act responsibly – and without blanket bans on alcohol off-sales purchase for younger people such as that proposed in Scotland.
2.7 Our response to the consultation questions follows below. Note that we have not responded to questions 6 and 9.
3. Consultation Questions
3.1 Response to question 1
NUS would welcome the introduction of a mandatory code on alcohol retailing, as we believe that voluntary codes are proving ineffective. In any case it only takes one bar or supermarket to opt out of a voluntary code in a particular area for pressure to be put on other retailers to abandon the code in similar fashion. Such a code would also reinforce the good work many students' unions carry out.
3.2 We would also suggest the Government looks at ways of including in the code companies who organise bar crawls and other similar events, given the impact that they have on local communities, and the health and well-being of the participants.
3.3 Any code should of course be developed in full partnership with the licensed trade sector.
3.4 Response to question 2
Consumers must be educated as to the units in their drinks, and despite the launch of information campaigns such as Know Your Limits, NUS is concerned that most still lack sufficient awareness of the units system or its significance. The confusion that arises from unit limits being quoted variously in terms of number per week or number per day, as well as the different amounts between genders, compounds this problem.
3.5 As a result the number of units listed on a container of alcohol can have little meaning, especially on large bottles of spirits where the entire unit content of the bottle is listed rather than the number of units per measure. And even when consumers do have some understanding of the unit system, the alcohol content of drinks can change (e.g. Jack Daniel's), and render the previous understanding obsolete.
3.6 Therefore whilst NUS supports the principle of alcohol unit labelling, we are concerned that at present it will have little of the desired impact whilst the units system is so little understood. Any system therefore has to be supported by higher profile, innovative campaigns to educate the public on the units system and what it means for them as an individual.
3.7 Response to question 3
The content of any code should be carefully considered, and as suggested in the consultation document, the Government should ensure any provisions are discussed in detail through a future consultation. As part of this code we believe the Government should consider the inclusion of minimum pricing of alcohol, particularly for supermarket off-sales, but also where bars are concerned, at least in respect of the promotions they are allowed to use.
3.8 Such a minimum price should not be a blunt instrument; it should take into account the strength and the amount of units in one serving. For example, the price could increase with the strength of the drink, so as to encourage consumers to choose weaker alternatives, and different approaches could be designed for different types of drink like beer, wine or spirits.
3.9 Any code should also ensure premises have effective training for staff, and strategies to deal with vulnerable people who consume too much alcohol on the premises, so that they are not merely ejected from the building and left to their own devices. However it is imperative that any proposals on staffing are carefully considered and implemented so as not to impact on the employment prospects of part-time workers, many of whom will be students and who will rely on earnings from bar work to see them through their courses.
3.10 We also believe the Government should examine some other approaches, such as giving premises greater flexibility at the end of the evening to extend the "drinking up" period from 15 minutes to one or even two hours, with music still being played and water, soft drinks and food still being served. This would allow for a longer, safer period of dispersal, and for consumers to be less intoxicated when they leave the bar.
3.11 In any event there must be support for licensed premises to develop the necessary standards where these are not already being met, particularly for smaller organisations with fewer financial resources.
3.12 Response to question 4
We agree that differential approaches must be taken to different types of premises. A large supermarket has far greater resources – and arguably far greater responsibility – than a village hall putting on occasional events. Similarly, students' unions could be treated separately to purely commercial organisations, depending on the provisions of the code, as their aims and objectives will be significantly different.
3.9 Exactly what allowances you could make for the size or type of organisation would depend on the final code, but broadly we believe that charitable and non-profit organisations should be protected from excessive expenditure on measures designed to tackle problems relating to the high-risk premises identified in the consultation document.
3.10 Response to question 5
As stated in our response to question 1 above, we would support any measure that would ensure compliance with any mandatory code. However, as with the code itself, enforcement provisions must take into account different types of organisations and be proportional to the significance any breach. Serious breaches should however result in serious penalties.
3.11 Response to question 7
More needs to be done to educate consumers on safe drinking and on the units system. However the Government must be more innovative in its campaigns and have separate initiatives to target different groups of drinkers. For example, Heriot-Watt students' union carried out a specific campaign to target women drinkers, Boozy Betty.
3.12 Any official campaign for young people must also take great care to avoid the perception of young people that such messages are hypocritical, coming as they do from ministers and health professionals who, it is thought, drink to excess themselves, or did so in their youth.
3.13 We believe therefore that peer education campaigns are vitally important for young people to not only take notice of the campaign messages but to take them on board and change their behaviour. The Government should support and develop peer education campaigns wherever possible.
3.13 Response to question 8
We support the principle of including units information on advertising, but, as previously discussed, we remain concerned the units system is too little understood for this to have the greatest impact.
4. Conclusion
4.1 NUS supports greater action being taken on alcohol misuse in England, subject to the comments laid out above. We would like to thank the Department of Health for the opportunity to contribute to the consultation and would be pleased to discuss our response further at any time.
National Union of Students
October 2008
Appendix 1: Contact Details
National Union of Students
Second Floor, Centro 3
19 Mandela Street
London
NW1 0DU
020 7380 6600
www.nus.org.uk
NUS Services Limited
Snape Road
Macclesfield
SK10 2NZ
01625 413200
www.nussl.co.uk
Appendix 2: References
Unite Student Living Report 2007
'Beer Gut Bill Tops Four Figures' – BBC News
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