By Paul Skehan (IRL), PARTICIPANT, Director General of spiritsEUROPE. Based in Brussels, he represents the interests of the European spirits sector and 32 national trade associations of spirits producers, as well as a group of the EU’s largest spirits producing companies, all household names. He is a passionate advocate for greater transparency about how science feeds into EU policy-making.
The validity of the European Union in the eyes of its citizens is that it can provide effective and useful public policies. Good policies are always based on good evidence, on good science. However, much weak or biased research is now presented as fact to policy-makers, especially in the area of lifestyle sciences. Europe desperately needs an arbiter of good science and a re-think of how its in-house science service, the Joint Research Centre, might best provide this. Unlike the US Federal Drug Administration (FDA) or the National Institute for Care Excellence (NICE) in the UK, Europe currently has too patchy an approach to tackling issues around substance use. Amongst the EU research centres, institutes and agencies that have developed since the food crises of the 1980’s and 1990’s, there is too little expertise at-hand on substance addictions. With the abolition of the Office of Chief Scientific Advisor who will fill that role? Industry, academia and wider society should be concerned.
Harm caused by alcohol abuse is found in every European country. The latest WHO report sets a figure of 3.3. million alcohol-related deaths per annum. Problems and diseases related to the harmful use of alcohol are high on the agenda of global public health policy, as they equally drive the corporate social responsibilities of beverage producers. Underage drinking, binge drinking, drink-driving, illness and disorder: all are reported regularly in the media, in health reports, in statistics and in reality. These are serious issues that deserve serious responses.
Without detailing the too obvious to mention, it is, nevertheless, worth noting that consumption of moderate amounts of alcohol can bring health benefits, some advantages in employment, enjoyment of life, cuisine, culture, etc. And taxes raised from the consumption of alcoholic beverages contribute towards the funding of many public services – including health.
As such, the issue of how to address alcohol-related harm is not straightforward, and ‘science’ is used on all sides of the argument to support particular points of view. Some of the research is contradictory, some of it is unconvincing, and some appears to be shaped from the outset with a particular policy objective in mind.
In SciCom’s last compendium titled “addictions & their brain reward systems” referenced in the preface, there was a strong focus on “drinking patterns, culture and policy responses” from a global perspective taken by Dr. Marjana Martinic of the International Alliance for Responsible Drinking (IARD)31. Similarly, alcohol treatment expert Andy Stonard of Esprit du Bois and Professor Philippe de Witte, Head of Behavioural Biology at the Université Catholique de Louvain (UCL) give a lot of food for thought about the science of alcohol and young people. Both are worth reading in conjunction with my piece which takes a closer look at the best practices and pitfalls we encounter as industry when trying to feed in scientific evidence to EU policy-makers, amongst others.
Policy-making should be based on robust science and research. Everybody will claim theirs is the best. Where stakeholders differ is how that ‘robustness’ might be measured.
Take these statements:
“Europeans drink more alcohol than anyone else in the world.”
“European consumers drink less than consumers in both Africa & South East Asia.”
If you are an advocate for temperance and you would like European policy-makers to impose greater restrictions on the alcohol beverage sector, then you are likely to claim the first statement above and cite countless statistics about the harms caused. Claiming that Europeans drink more than anyone else will strengthen your case as in itself, it appears ‘wrong’ to be top of any substance use league table.
If you represent the alcohol sector, on the other hand, and believe there are more than enough restrictions on how those products are marketed and sold, then you will prefer the second of these statements, when meeting members of the European Parliament, governments, and so on. You might also further clarify that European consumption stems from legal sources i.e. quality controlled whereas up to 85% in certain countries is uncontrolled ‘home brew’. But that’s splitting hairs.
So, which of these statements is true? Well… both in fact, depending on what you understand by ‘average consumption’. It should be a simple calculation: take the total amount of alcohol consumed in a region, and divide it by the number of people in that region. But which ‘people’? Should you include everyone in that denominator – including new born babies, 2 year olds, 3 year olds, etc., or should you include only those who fall within the usual drinking ages?
If you include all people aged 15+ in the calculation, you will find Europeans drink more than anyone else. However, if you only take into account those who actually drink (the drinking population), then you find that European consumers drink less than those other regions. This is not only the result of demographic differences (including other features than age, namely income, religion, etc.), but also the number of people who actually consume alcoholic drinks or abstain from drinking. My message here is that facts are easily misunderstood.
Does it matter? Of course it does. Figures like these are used every day by non-governmental organisations, health advocates, industry experts and policy-makers in countless meetings and fora. They feature in press releases and speeches. They are quoted as if they are incontestable. The objective is to have a sufficient number of media and other influencers take for granted the ‘spin’ desired: “Europeans Drink Most!” becomes the headline, then repeated indefinitely in future journals, speeches and blogs. The original calculation or research behind the headline has served its purpose. Alternative interpretations of the research are derided as being defensive or out of touch.
The fact that according to the OECD’s research below, consumption of alcohol in Europe has decreased significantly over the past 30 years, and seems to be relatively constant during the last 10 years or so, is not a fact that the temperance movement will highlight. On the other hand, industry does think it highly relevant.
Moreover, NGOs and related scientists draw a direct line between ‘Europe is by far the world’s heaviest-drinking region’ 32 and the level of alcohol related harm, e.g. the ‘European Region remains the area of the world with the highest levels of alcohol consumption and alcohol related harm’. 33 However, the map chart below (also published by WHO) shows a different picture as regards the regional distribution of alcohol attributable deaths in 2004.
The ethics of EU Institutions generating their own spin
As a centre for policy-making, Brussels attracts more than its fair share of spin. For every policy issue under discussion in the European Parliament, lobbyists – both corporate and not-for-profit – will seek to communicate their particular take on science to MEPs and their assistants. Activists will find the piece of research that supports their particular policy objectives and promote that research as the only truth. Facts become weaponised. The subtleties and weaknesses of much of the original research will be ignored or lost.
But the European institutions also contribute to the spin. Policy-makers’ speeches and questions will cherry-pick aspects of previously published research to poke holes in, or support, particular legislative initiatives. My point is that European Commission documents will quote some scientific findings and not others, depending on the proposal a particular Commissioner wants to make. Commissioners may even contradict each other with the same research. Robust scientific reports on the Joint Research Centre’s website will be put up or taken down as the cause necessitates. And some go further, by offering grants for research, the direction of which the European Commission dictates, but the robustness of which sometimes leaves much to be desired.
In alcohol research, we have witnessed the bulk of Commission funding go to the same researchers in broadly the same policy areas over the past 5 to 6 years. While some of that research appears to have been well executed and reasonably neutral in its outlook, many projects seem to be aimed at particular policy conclusions from the outset, and the research developed in a way to justify those policy recommendations.
When the European Commission funds research, does it have any responsibility over the quality of that research? I would argue that it does. Typically, results are published on the Commission’s own website34, even if the reports themselves will always contain some disclaimer as to the ownership of the work. In such instances, there is a need for a right of rebuttal, or for counter-arguments to be posted alongside the original research. Otherwise, it has all the appearances of being sanctioned by the European Commission.
My call for action here is that:
a) The allocation of public health programme funding should be based on a sound methodology in line with international or European professional diligence standards applicable, for example, to market research. The European Commission then has a responsibility to ensure that the research that is conducted and finally published (with acknowledgements to the EU funding) is of sufficiently high quality.
b) Research presented to inform the public EU debate should respect principles of good research. Research which deviates from those principles should be clearly identified (and when necessary, named and shamed) – not least by the organisation that commissioned the research in the first place. Conversely, if research follows the required standards, it should be welcomed by all stakeholders, regardless of its origin/funding.
THE COMPLEXITY OF SETTING THE RIGHT ALCOHOL POLICIES...
Alcohol consumption is proven to have health benefits too
For those who would favour severe restrictions in the availability of alcoholic drinks, who would favour increased taxes so as to force up prices, the simple message to policy makers is “consumption of alcohol is bad, so cut consumption and harms will disappear.”
Regardless of the many profound ethical arguments about ‘nanny state’ interventions raised by Professor Kinderlerer, Professor Kazatchkine and others in this publication, what upsets this simplistic narrative is the fact that numerous studies show that otherwise healthy adults who consume alcohol in moderation may face a lower risk for a number of conditions, in particular age related risks such as coronary heart disease, ischemic stroke, diabetes and dementia. My point is not to argue that “alcohol is good for you” in an irresponsible manner and as the representative of an alcoholic beverage sector association, but to point out that there are black and white scientific evidences that must be factored in.
Drinking patterns are of great relevance: moderate drinking, compared to heavy drinking, and, for that matter, to not drinking at all, has been shown to be associated with certain beneficial health effects.
According to a 2006 meta-analysis ‘consumption of alcohol, up to 4 drinks per day in men and 2 drinks per day in women, was inversely associated with total mortality, maximum protection being 18% in women […] and 17% in men. […] Our findings, while confirming the hazards of excess drinking, indicate potential windows of alcohol intake that may confer a net beneficial effect of moderate drinking, at least in terms of survival’. 35
A number of independent studies also show that moderate drinkers generally enjoy not only a reduced all-cause mortality risk but also may benefit psychologically, e.g. feelings of pleasure, happiness or stress relief.36 Chan concludes ‘regular alcohol consumption is associated with increased quality of life in older men and women’.37 Or Goldberg38 who found that ‘compared with abstainers, moderate drinkers exhibit improved mental status characterised by decreased stress and depression, lower absenteeism from work, and decreased incidence of dementia (including Alzheimer’s disease)’ Or more recently, Valencia concluded: ‘Alcohol drinkers, including those with heavy drinking, reported better physical HRQL [health related quality of life] than non-drinkers’.39
We must redefine good versus bad research
As all contributors are at pains to point out in this SciCom series, the dialogue between science and policy is never straight-forward. The fact is, bias is introduced in a number of different ways, not least by ideological positions and agendas aimed at particular policy outcomes. New Zealand Chief Science Adviser, Sir Peter Gluckman, demonstrates clearly in his recent health case-studies how policy-makers have countless sources of solicited and unsolicited advice. Thus, science can rarely speak with one voice. Yet, surely we must be able to agree some basic ground rules that ‘good’ research is ‘good’ no matter who funds it, provided it is grounded in certain principles, generating reputable, credible and reproducible findings that derive from sound scientific methods, and using reasonable and fair assumptions and verifiable, correct data inputs? But what constitutes ‘good’ research? We suggest the following five principles as a start:
- There will never be enough funding – nor enough researchers – available to undertake all possible research. Whatever resources are available must be optimised: focusing the correct resources on the most relevant and pressing needs.
2. NEUTRALITY AND OBJECTIVITY
- As noted above, industry questions the objectivity of activist researchers as it appears that some research projects are used merely as a means to support pre-decided policy approaches. At the same time, NGOs clearly question and challenge industry involvement in research. Policy-makers too can express this bias by declaring an ‘everybody’s science is welcome approach’ but then ultimately paying lip-service to it. The citizen is the loser here.
- We believe good research is conducted by experts in the particular field of research, rather than by advocates with a pre-existing policy viewpoint.
- Policy-makers should consult more widely. Industry contributions should be given the same level of attention as academic contributions and evaluated according to the same criteria as NGO contributions.
3. FAIRNESS AND TRANSPARENCY
- In the allocation of funding: The process of applying for EU funding seems convoluted and complicated enough to become almost a full-time job, which may explain why the same activist researchers appear to get funded time and time again. Recent efforts to cut red-tape are welcome, but will not resolve the issue of industry science being de-facto disadvantaged in entering the race.
- In the methodology used in the research: Before the research starts, some consultation with those stakeholders likely to be most affected by the research would be useful, allowing researchers to avoid potential problems with their proposed methodology.
- In the manner in which the conclusions are presented: Frequently, research funded by the European Commission is also accompanied by recommendations for public policy changes. Researchers/authors should be required to disclose their associations not only with business, but also with any policy advocacy groups (for example, temperance groups, health lobbies, etc.). A good start would be to have all ‘advisers/experts/reviewers/funding allocators’ to DG Research & Innovation and its family of sister agencies complete the new Transparency Register.
- In allowing the right to reply: All stakeholders should be provided with a right of reply – allowing the (industry, or other) response to be published next to the original research on the European Commission website. A more visible ‘Science Ombudsman’ would also add value to Horizon 2020.
- Those involved must respect principles of good research and work in accordance with the accepted standards of the discipline.
- Benchmarking excellence while rooting out mediocrity should be a greater priority and not just funding for the sake of funding to get the money spent.
- Data sources should be transparent and accessible.
- There should be unbiased geographical coverage / broad baseline if results are extrapolated to inform EU policy. The research must also ensure the whole spectrum of credible research is reviewed and taken into account.
- Published research is generally of higher standard than that which remains unpublished. However, if peer review is the best system that we have, it is not the panacea if the ‘peers’ share the same bias as the author.
- Consultation with, and participation of, all interested parties during the process is a must. It is a no-brainer that policy-making that involves all stakeholders stands a better chance of success, take-up and consumer acceptability. Policy-makers must also be receptive to scientific advice, even when this advice is uncomfortable. Finally, we are talking about tax-payers’ hard earned cash here, so policy-makers must do more, in tandem with industry, to challenge ‘science’ to deliver on their public investment.
Why industry, academia & society should worry
Alcohol-related harm is a serious and a complex issue. There is no escaping that. Policy-makers who look to set the appropriate policies to address that harm deserve all the support and help that we, and other stakeholders, can give them. We can learn a lot from those national strategies that have taken up harm reduction science and a more health-focused approach above the reflex for a short-sighted, repressive reaction as Professor Kazatchkine espouses above.
We live in a Europe anchored by the principle of a Common Market that brings endless benefits, no question, but necessitates a permanent, creative tension between 28 largely homogeneous, but still very different systems that when it comes to alcohol, have clearly different consumption patterns, cultures, traditions and policy-responses. As our Consultation Event participant, Professor Klaus Bock, Member of the European Research Council, Euroscience Open Forum 2014 Copenhagen Champion and former Executive Vice-President for Research at Carlsberg explained, “you can do what you like with restrictive alcohol policies in Denmark but people will simply cross the border to Germany or elsewhere”.
Similarly, adapting a one-size fits all approach from Brussels might look good on paper but is hardly going to work in practice if not well thought through. This requires serious scientific engagement at all levels. If policy-makers from the European Commission, Parliament or Council do not heed Sir Peter Gluckman’s advice that you need to start out with an open mind, get the right people around the table, gather the right evidence and then think about the right policy, then things are doomed to fail before they start.
Above all, our policy-makers deserve to be briefed in a fair and honest manner. They deserve to receive the best available research, whether that comes from activist scientists, or has been funded by industry. As I try to explain in a back-to-basics plea above, good research is good, no matter its source. Bad research should be called out. But who will do that?
REFERENCES IN THIS ARTICLE
32 See Awareness Week on Alcohol-Related Harm 2014 by United European Gastroenterology http://tinyurl.com/mdmvnf8
33 WHO 2012 ‘European action plan to reduce the harmful use of alcohol 2012–2020’, p. 1
34 http://ec.europa.eu/research/ ; http://ec.europa.eu/chafea/health/funded_projects.html
35 Di Castelnuovo et al 2006 (2437) Or very recently, Valencia et al (2013, 703) conclude: ‘Alcohol drinkers, including those with heavy drinking, reported better physical HRQL [health related quality of life] than non-drinkers’.
36 Arntzen et al, 2010
37 Chan et al, 2009 (294)
38 Goldberg et al, 1999 (505)
39 Valencia et al, 2013 (703)