It is instructive to compare the WHO working document with the ICAP outline of a

possible WHO approach discussed by the Board at its June 2009 meeting in Napa. The

structure of the WHO working document is almost identical to the ICAP outline, and

90% of WHOs possible policies and interventions for implementation at the national

level are included or implied in the corresponding Member States action sections of

the ICAP outline. In other words, there is very little in the WHO working document that

should come as any surprise.

Equally, the focus of the working document does, indeed, remain solidly on reducing

harmful drinking, which is consistent with, for example, the forthcoming ICAP book

Working Together to Reduce Harmful Drinking, which was made available to the WHO

secretariat in manuscript form and which they acknowledged to have found very

useful. Indeed, many issues raised in that book have found their way into the document.

There is, however, an important difference in emphasis in the WHO working document,

compared to the ICAP outline. The WHO working document focuses almost exclusively

on promoting a strong and rather traditional public health agenda, therefore giving

prominence to regulatory measures. The primacy of government (especially the health

sector) is repeatedly emphasized, as is the lead role of WHO within the international

community. Government departments other than health are only invoked where their

actions can strengthen public health goals; civil society organizations are relegated to a

supportive role; and the private sector is essentially expected to behave well and mind its

own business. Again, this is hardly surprising. The document has been drafted by a

public health agency for an audience of government health officials.

In other words, the spirit of Resolution WHA61.4, which called for extensive

consultation in the preparation of a draft global strategy, does not seem to have found its

way into the WHO working document. Although multi-sectoral engagement could be

read into many sections, the only language promoting it is included in the opening

sections, before specific measures are described, and is rather vague. One of our

consultants notes how, even in relation to encouraging working together on lifestyle and

environmental approaches to other non-communicable diseases, the working document

misses some important opportunities.

Another of our consultants likens this narrowing of the agenda to having the debate

about nuclear energy policy center around the avoidance of the risks from nuclear

reactors, and promoting departments of radiation medicine to take the lead in the

discussion. Another points out that the insistence on the precautionary approach (19.3)

is not consistent with evidence-based policy and could lead to problems later.

Paragraph 9 of the WHO working document notes the increasing availability and

affordability of alcohol beverages in many lo- and middle-income countries linking this

to a weakening of traditional regulation of drinking and the marketing activities of

producers and distributors. This analysis takes insufficient account of the informal and

illegal market and, as a result, the portfolio of options for addressing noncommercial

alcohol is rather narrow.

In preparing this commentary, we were asked to look in particular at the strength of the

scientific evidence on which WHO based its recommendations. Recognizing the areas

likely to be of particular interest to the Board, attached as Annex 1 to this commentary is

an analysis by Marjana Martinic of the scientific literature on: availability of alcohol;

marketing of alcoholic beverages; and pricing policies. In this connection, the footnote to

paragraph 6 of the WHO working document (referencing the WHO Expert Committee

Report and the Anderson article in Lancet) begs the question regarding the balance of

evidence and should be omitted.

In summary, although alcohol producers may not like everything that is included in

the WHO working document, there is little here that is unexpected. It is certainly

possible to challenge the alleged strength of the evidence base for some of the more

extreme regulatory measures proposed, which could lead to a less whole-hearted

endorsement of them in the draft strategy, when it is finally made available.