SDG indicator review submission

In the United Nations Inter-agency and Expert Group on SDG (IAEG-SDGs) 2025 Comprehensive Review of the Sustainable Development Goal indicators, GAPA made the following submission:

The Global Alcohol Policy Alliance is a network of non-governmental organisations and people working in public health. Our goal is to reduce alcohol-related harm worldwide by promoting science-based policies independent of commercial interests. We appreciate the opportunity to make the following submission regarding indicator 3.5.2 in the 2025 Comprehensive Review.

The proposal by the International Alliance for Responsible Drinking (IARD) to amend indicator 3.5.2 (alcohol per capita consumption (APC)) with prevalence of heavy episodic drinking (HED) and alcohol-related morbidity and mortality is in line with previous proposals they submitted in 2015 (IAEG-SDG 2015) and 2020 (IAEG-SDG 2019a and b – cell 65E). On both occasions the UN Statistical Commission deemed the present indicator, measuring alcohol per capita consumption (APC) to be a sufficient indicator. We see no reason why this should be different this time around.

IARD is formed by 12 of the biggest beer, wine and spirits corporations and clearly has a conflict of interest in this matter. The proposal by IARD must be seen in the light of the organisation’s role as vehicle for these 12 major alcohol corporations (Lesh and Mc Cambridge 2023). There is an underlying conflict between protecting the public health and the goal of the alcohol producers to sell as much alcohol product as possible. As part of this, advocacy for a more complex indicator which has less relationship with alcohol attributable harm is to be expected (Rehm et al 2020).

The thorough submission in the 2020 review consultation by the Center for Addiction and Mental Health (IAEG-SDG 2019b – cell 44E) lays out the rational for maintaining APC as the sole 3.5.2 indicator. We want to draw the attention to that submission and hence, keep our further observations brief.

APC is the recognised indicator for alcohol harm widely used, including by WHO. It is a comprehensive indicator drawing on data both from governments and the alcohol industry, available in most countries of the world. It is reliable and is strongly linked to the burden of disease from alcohol use. While for many alcohol-related harms there is a dose response relationship, with increased risk with heavier drinking, there has been increasing awareness of evidence that increased health risk begins at low levels of consumption, often referred to as ‘no safe level’ (Griswold 2018).

APC is a suitable indicator for harmful us of alcohol as it is sensitive to the shifts in alcohol related harm and captures the fluctuation in alcohol consumption in response to the implementation of evidence-based policies that influence both alcohol consumption and alcohol harm (IAEG-SDG 2019b – cell 44E).

Amending the SDG indicator with two further indicators would increase the workload for the member states and be beyond the resources of many LMICs. There are a number of measurement and methodological problems (IAEG-SDG 2019b – cell 44E)) that reduces the validity, reliability and comparability of a proposed survey-based HED indicator.

References:

Griswold, M.G., Hawley, C., Arian, N., Zimsen, S. R. M., Tymeson, H. D., Venkateswaran, V., Tapp, A. D., Forouzanfar, M. H., Salama, J. S., Abate, K. H., Abate, D., Abay, S. M., Abbafati, C., Abdulkader, R. S., Abebe, Z., Aboyans, V., Abrar, M. M., Acharya, P., . . . Gakidou, E. (2018). Alcohol use and burden for 195 countries and territories, 1990-2016: a systematic analysis for the Global Burden of Disease Study 2016. The Lancet, 392(10152), P1015-1035, https://doi.org/10.1016/S0140-6736(18)31310-2

IAEG-SDG. (2015), “Open Consultation on Green Indicators: Compilation of Inputs by the Observers of IAEG-SDGs and Other Stakeholders (4 Nov – 7 Nov 2015)”. Goal 3, cell 92N  https://unstats.un.org/sdgs/files/open-consultation-iaeg-2/Open%20Consultation%204-7%20Nov%202015_All%20Goals_V6.xlsx

IAEG-SDG. (2019a), Compilation of 2020 Comprehensive Review Proposals Received 24 June 2019. Page 19, https://unstats.un.org/sdgs/files/2020%20Comprehensive%20Review%20Proposals_web.pdf

IAEG-SDG. (2019b), “Compilation of Inputs from the IAEG-SDG Open Consultation for the 2020 Comprehensive Review 20 September 2019” 3.5.2 Replacement

Lesh, M and McCambridge, J. 2023. Evolution of the major alcohol companies key global policy vehicle through the prism of tax records 2011–19. Globalization and Health 19(34): 1-10. https://globalizationandhealth.biomedcentral.com/articles/10.1186/s12992-023-00933-w

Rehm, J., Crépault, J.-F., Wettlaufer, A., Manthey, J. and Shield, K. (2020), What is the best indicator of the harmful use of alcohol? A narrative review. Drug Alcohol Rev., 39: 624-631. https://doi.org/10.1111/dar.13053

Submitted via web form 15 August 2024