Registed Nurses' Association of Ontario

RNAO Urges Province to Use Public Health Evidence to Inform a Comprehensive Provincial Alcohol Strategy


RE: RNAO Urges Province to Use Public Health Evidence to Inform a Comprehensive Provincial Alcohol Strategy

Dear Premier Wynne,

The Registered Nurses' Association of Ontario (RNAO) remains profoundly concerned about the direction the province has taken in regards to alcohol sales. Government actions and rhetoric surrounding "the biggest change since the repeal of prohibition" seem to be more informed by market forces than by public health evidence. As RNAO has argued in the media, Ontario is absolutely moving in the wrong direction by enabling the sale of beer and wine in grocery stores.

Liberalizing alcohol sales based on recommendations by Ed Clark contradicts the province's stated aspiration "to make Ontario the healthiest place in North America to grow up and grow old." Increasing the physical availability of alcohol by expanding retail sites is a threat to public health, public safety, and community well-being.

If alcohol was an ordinary commodity, like broccoli, then improving convenience and choice might be desirable. Alcohol, however, is "no ordinary commodity" as it "plays a major role in the causation of disability, disease, and death on a global scale." The World Health Organization (WHO) attributes 3.3 million deaths globally each year due to alcohol. There is a causal relationship between alcohol consumption and more than 200 health conditions. In addition to acute and chronic diseases and injuries, alcohol use can lead to alcohol poisoning, homicide, impaired driving, suicide, exacerbation of mental illness, alcohol use disorder, and intergenerational effects complicated by genetics, alcohol consumption, and social/family environment.

The province has announced its commitment to support "the safe and responsible consumption of alcohol," yet there are some situations where alcohol consumption is never safe. During pregnancy, there is no safe amount or time to drink alcohol as fetal alcohol spectrum disorder (FASD) is the leading known cause of preventable developmental disability in Canada. As alcohol is a class 1 carcinogen, the Chief Public Health Officer of Canada, Canadian Cancer Society and Cancer Care Ontario" all warn there is no safe limit of alcohol consumption. Drinking while driving is also never safe – from 2000 to 2010, between 36 and 41 per cent of fatally injured drivers in Canada tested positive for alcohol. Alcohol must not be treated like broccoli. Instead, it must be recognized as a drug that can cause harm, just like tobacco and other narcotics.

RNAO is not arguing for prohibition. As with other drugs, RNAO is advocating for an evidence-informed harm reduction approach to alcohol. Ontario's alcohol retailing system, before Ed Clark's recommendations were implemented, gave people access to alcohol within a social responsibility framework. Before changes that allowed beer and wine sales in grocery stores, more than 75 per cent of Ontarians already lived within a ten minute commute of an alcohol retail outlet. There is a wealth of global, national, and provincial evidence on effective population-level policies that decrease harms from alcohol. A 2013 comparison of provincial alcohol policies found multiple unrealized health and safety benefits. The average national score in this assessment was below 50 per cent of a perfect score. At that time, Ontario, British Columbia, and Nova Scotia had the highest-rated alcohol harm reduction policies, while Quebec's scored the lowest. Instead of building on Ontario's top ranking, the province is moving in the opposite direction by further privatizing alcohol retail outlets.

As one of many health and civil society organizations that have advocated for a comprehensive alcohol strategy to address health and social harms, we appreciated the Premier's announcement of the development of a "comprehensive, province wide Alcohol Policy" on Dec. 18, 2015. While welcome, it is disconcerting that this announcement came with the government opening up bids from grocery stores to sell beer on Sept. 23, 2015, enabling beer sales in grocery stores as of Dec.15, 2015, and announcing that 70 grocery stores will be able to sell wine, beer, and cider this fall on Feb. 18, 2016. Ontario's 2016 provincial budget, delivered on Feb. 25, 2016, reinforces this increased privatization of alcohol sales under the heading of "making everyday life easier" and increases access to alcohol by enabling an LCBO E-Commerce Platform that will facilitate home delivery. Pressing ahead with such substantive changes to increase availability of alcohol while ignoring proven population-level alcohol policies calls into question the province's commitment to reduce harm from alcohol. Although the government is seeking to consult with stakeholders on developing the strategy, our experience is that the process seems rushed, lacking in rigour and deficient in transparency. It is unclear how the interests of industry stakeholders seeking to increase market share for their products can be reconciled with the strong public health evidence that the consumption of alcohol and related problems increase as alcohol becomes more available. These contradictions may undermine trust in the sincerity of the consultation process and discourage engagement in the democratic process.

RNAO recommends the following for better health outcomes and a healthier province, consistent with the three "best buy" recommendations of the WHO and recommendations from the national and provincial public health community:

  • Roll back recent privatization initiatives and establish a moratorium on further privatization of alcohol sales. In light of the critical evidence of increased harm with increased physical availability of alcohol, strengthen government-run retailing systems and monopolies.
  • Strengthen Ontario's minimum pricing structure by raising minimum prices; linking prices to alcohol content so that as alcohol content rises, so does price; and close loopholes to the minimum price.
  • The WHO recommends a ban of alcohol advertising, promotion, and marketing. Ontario can start to confront a culture that normalizes drinking by updating current advertising regulations so they apply to all forms of media including social, internet, radio, television, and print. Immediately prohibit alcohol promotion targeted to youth, including scholarships, bursaries, and sponsorship.
  • For greater transparency and accountability, make public all submissions and letters related to alcohol policy.

Alcohol availability, pricing, and marketing are three population-based elements that will determine how socially responsible this government is in its approach to reducing harm from alcohol. Lessons can be learned from Ontario's success in reducing tobacco use and exposure through a cultural change prompted by policies, laws, public education, and programs. If Ontario does not make its alcohol policy congruent with the public health evidence, then the province will be undermining its other key initiatives, including those to reduce poverty, address homelessness, strengthen mental health and recovery from addictions, prevent injuries, avoid premature death and promote health by preventing acute and chronic diseases, and prevent violence. Current policies that increase the availability of alcohol work dramatically against the province's stated goal of developing a provincial FASD Strategy and repeated advocacy on this issue from many organizations, including RNAO.

Thank you for considering this constructive feedback and recommendations. We know that our province can and must do better.

Kind regards,

Chief Executive Officer, RNAO

See the full letter with references below.

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