IPH response to Department for Regional Development's Regional Development Strategy

Key points from the IPH response include: There is growing recognition that the leading causes of illness and death, including heart disease, cancer, respiratory diseases and injuries, may be exacerbated by elements within the built environment which contribute to sedentary lifestyles and harmful environments.  IPH call for greater recognition of the links between regional development and health.   Health inequalities are the preventable and unjust differences in health status experienced by certain population groups.  The RDS has a role to play in tackling health inequalities experienced in Northern Ireland.   Supporting a modal shift in transport methods can lead to improved health and reduced health inequalities.   The RDS plays an important role in addressing climate change which is identified as a major public health concern for the 21st Century.  Creating healthy sustainable places and communities can go hand in hand with reducing the negative impacts of climate change.   IPH recognise the RDS is an overarching strategic framework which will be implemented by a range of other agencies.  To fully appreciate the potential health impacts of the RDS, IPH call for a Health Impact Assessment to be undertaken to fully determine the links with health and potential impact on health inequalities particularly in relation to the implementation strategy.

IPH response to Phase 2 of the New Strategic Direction for Alcohol and Drugs 2011-2016 (Northern Ireland)

The IPH response to the New Strategic Direction for Alcohol and Drugs questionnaire which has been designed to help stakeholders respond to New Strategic Direction for Alcohol and Drugs Phase 2 (2011-2016) consultation document.

IPH response to NI Health and Social Care Board 'Tranforming Your Care' consultation

The 'Transforming Your Care (TYC)' consultation relates to proposals for changes in the delivery of Health and Social Care in Northern Ireland in the context of the TYC report published in December 2011. TYC is about making changes to ensure safe, high quality and sustainable services for patients, service users and staff. TYC sets out proposals in respect of how health and social services will need to adapt and be organised to best meet the needs associated with population ageing, increasing long-term conditions and other challenges. Key points from IPH response include: IPH welcomes the HSC commitment to transform health and social care services to meet Northern Ireland’s changing population health needs Inequalities are a dominant feature of health service utilisation patterns in Northern Ireland – for example hospital admission rates for self-harm and alcohol-related admissions in the most deprived areas are double the regional figure. IPH recommends that

IPH response to DSD consultation on proposed changes to the law regulating sale and supply of alcohol

This consultation was intended to test public opinion on proposed changes to the law regulating the sale of alcohol in Northern Ireland. The proposed changes relate to-    regulating the sale of alcohol in supermarkets and off-sales premises-    regulating the sale of alcohol in pubs and other on-sales premises-    regulating private member clubs-    codes of practice Key points from IPH response -    IPH welcomes the opportunity to submit our views on this review of regulations related to the sale and supply of alcohol in Northern Ireland. IPH notes that the reduction of alcohol-related harm is a stated aim of the review. -    International evidence clearly supports the role of regulation of the sale and supply of alcohol in reducing alcohol consumption and in reducing alcohol-related harm. -    The consultation document does not present any meaningful estimation of the scale or nature of potential positive or negative effects on alcohol-related harm arising from the proposed changes. On this basis, IPH recommends that a Health Impact Assessment should be conducted on the proposed regulations. -    IPH shares the concerns raised in respect of increases in the number of people drinking at home and the availability of large volumes of low cost alcohol in supermarkets. In this regard, we welcome the proposals to enhance the regulation of sale of alcohol in mixed trading premises by more stringent structural separation measures and restricted advertising. -    IPH wishes to emphasise the importance of the work underway to explore the introduction of minimum unit pricing of alcohol on the island of Ireland as this measure will be significant in enhancing the proposals on regulating sale of alcohol in mixed trading premises -    In light of evidence of increased alcohol consumption and harm associated with increased hours and days of sale of alcohol, IPH does not support the proposal to introduce additional late opening hours or extended drinking up time.

IPH response to DSD Urban Regeneration and Community Development Policy Framework Consultation

The Urban Regeneration and Community Development Policy Framework for Northern Ireland sets out for DSD and its partners, clear priorities for urban regeneration and community development programmes, both before and after the operational responsibility for these is transferred to councils under the reform of local government. Four policy objectives have been developed, which will focus on the underlying structural problems in urban areas and also help strengthen community development throughout Northern Ireland. The policy objectives are as follows: Policy Objective 1 – To tackle area-based deprivation: Policy Objective 2 – To strengthen the competitiveness of our towns and cities: Policy Objective 3 – To improve linkages between areas of need and areas of opportunity: and Policy Objective 4 –To develop more cohesive and engaged communities. Key points from IPH response Urban regeneration and community development provide a basis for addressing the social determinants of health and reducing inequalities in health. This policy framework presents an opportunity for coherence and complementarity with ‘Fit and Well - Changing Lives’ as part of government’s overall approach to tackling health inequalities. It is now well established that a focus on early years’ interventions and family support services yields significant returns, so prioritising action in these areas is essential. Defined action plans on child poverty are essential if this policy framework is to make a real and lasting difference in deprived urban areas. Development of the environmental infrastructure to improve health in deprived areas should be supported by well-planned monitoring and evaluation. Linking the policy framework to economic development and local community plans will enhance effectiveness in the areas of education, job creation, commercial investment and access to services, which in turn are critical for the economic growth and stability of urban communities. Community profile data and health intelligence (as available through IPH Health Well) could usefully inform central and local government in terms of resource allocation and targeted service delivery.

IPH response to DHSSPS Consultation on a ten year breastfeeding strategy for Northern Ireland 2012-2022

The Department of Health, Social Services and Public Safety invited submissions on the development of a new ten-year Breastfeeding Strategy for Northern Ireland 2012-2022 between May and September 2012. The draft Breastfeeding Strategy 2012 – 2022 proposes further action in relation to breastfeeding and aims to protect, promote, support and normalise breastfeeding within the population of Northern Ireland. Key points from IPH response IPH welcomes the commitment by the Department of Health, Social Services and Public Safety to develop a comprehensive long-term strategy to support women in Northern Ireland to breastfeed. The timeframe provides scope for developing clear long-term targets and actions and the embedding of breastfeeding culture into allied services, policies and programmes throughout Northern Ireland. The draft strategy’s recognition of the potential of breastfeeding as a means for tackling health inequalities forms a central theme of the IPH submission IPH welcomes the success achieved to date in improving breastfeeding. However, it is clear that the overall breastfeeding rate in Northern Ireland still lags behind the rest of the UK. Inequalities in breastfeeding rates remain an ongoing concern. IPH emphasises the importance of integrating the actions of the breastfeeding strategy with the strategic direction of overall public health policy in particular the forthcoming Fit and Well policy framework and early years strategies. IPH welcomes the inclusion of stipulations regarding weaning practices as an important component of the vision and one which, if achieved, will maximize the benefits from improving breastfeeding rates and duration.

IPH response to Department of Health (ROI) consultation on National Strategy on Dementia

The current prevalence of dementia and its associated economic and social burden presents a challenge for the configuration of dementia care services at present and it is clear that this challenge will become ever more urgent as a consequence of population ageing. IPH supports the development of a Dementia Strategy in Ireland that is comprehensive and holistic. We recommend that the strategy encompasses aspects of prevention as well as optimal management at all stages of the disease. IPH considers that a social determinants of health approach that focuses on the prevention of disease and disability could form an important strand of the strategy. Key points from IPH response IPH would emphasise the following key priorities for inclusion in the Dementia Strategy.   Adoption of a public health approach as set out by WHO (2011) and the development of an implementation plan and structures to support the Strategy A commitment to primary, secondary and tertiary prevention of dementia.  Resourcing of a programme of research to support primary, secondary and tertiary prevention of dementia to ensure a systematic approach to generate an evidence-base and disseminate pertinent findings in the Irish context. Emphasis should be placed on high quality research specifically to:enhance information systems on dementia at a national level A life course approach to tackle the social determinants of dementia and ill-health in later life. Supporting carers for people with dementia

IPH response to Department of Health (UK) Standardised Packaging of Tobacco Products

Enhanced tobacco control policies and programmes are an important component of any strategic approach to improving population health and tackling health inequalities. The consultation on standardised packaging of tobacco products in the UK is particularly timely in view of the recent publication of the Ten Year Tobacco Strategy for Northern Ireland (DHSSPS, 2012). In this strategy the Department expressed its support for the introduction of further measures to reduce the influence of tobacco advertising and promotion upon children e.g. the introduction of plain packaging for cigarettes and hand rolling tobacco.  IPH key points •    The extent of tobacco-related harm across the island of Ireland and across the UK is unacceptable. Increasingly comprehensive and effective tobacco-control interventions are required. •    IPH recommends the adoption of option 2: require standardised packaging of tobacco products. •    IPH acknowledges that as plain packaging has not yet been introduced in any country, it is not possible at this time to accurately forecast the extent and nature of this intervention on population level health outcomes in the UK context. •    The proposed approach appears comprehensive in addressing the direct and indirect ways in which elements of tobacco packaging can promote brand appeal and can portray impressions in respect of tobacco-related harm. Consideration should be given to include specific provisions relating to roll-your-own (RYO) tobacco packaging. Any approach needs to be regularly reviewed to take into account attempts to bypass restrictions and evaluate responses in respect of consumer choices. •    IPH considers that the introduction of plain packaging has the potential to support the achievement of the goals set out in the Ten Year Tobacco Control Strategy for Northern Ireland ( DHSSPS, 2012). •    Among children in Northern Ireland who reported trying their first cigarette, around one quarter were aged 11 or under and three quarters were 14 or under when they did so (DHSSPS, 2012).  The very young age of these children is concerning on many levels including their susceptibility to sophisticated branding and marketing techniques linked to tobacco packaging.

IPH response to DHSSPS and Food Standards Agency (NI) Front of Pack Labelling consultation

From 2016, it will be mandatory for most pre-packed food to carry nutrition labelling.  This provides an opportunity to review the provision of additional nutrition labelling that is provided voluntarily on the front of packs.  The Governments across the UK are committed to the provision of nutritional information to help consumers make better informed food choices. Key points from IPH response Obesity and related chronic conditions are already very prevalent and are expected to increase over the next decade, placing greater financial burden on health care services. Helping consumers to make informed choices about their diet is an important aspect of tackling obesity. Providing clear consistent and easy to understand front of pack (FoP) nutrition information is important in helping consumers to make healthy choices. IPH would support FoP nutrition information using the traffic light labelling scheme and High/Medium/Low text. FoP nutrition labelling should be supported by a public information campaign to educate consumers about portion sizes and recommended daily intakes of fat, sugar and salt. IPH would support a nutrition labelling approach which empowers and enables consumers to take responsibility for their own health through informed dietary choices. The FoP traffic light labelling scheme has the potential to encourage healthier product formulation as manufacturers pursue market share. This in turn would contribute to wider availability of healthier products.

IPH response to consultation: Introduction of 20mph speed restrictions on smaller residential streets

Conall McDevitt (SDLP MLA) launched a consultation regarding the introduction of 20mph speed restrictions in residential streets as part of his bid to introduce legislation through a Private Members Bill in the Northern Ireland Assembly.  The purpose of the Bill is to increase road safety, particularly for pedestrians and other road users, with additional health and environmental benefits. IPH submitted a response to the Private Members’ Bill regarding the introduction of 20mph speed restriction on smaller residential roads.  IPH recognises the potential public health benefits of this proposal in terms of reduced injuries and fatalities in built up areas; more opportunities for walking and cycling (helping to tackle obesity and reduce the risk of diabetes, heart disease and stroke); greater social cohesion among communities and improved mental health; and reduced emissions that contribute to climate change, air and noise pollution.

IPH response to Road Safety Authority Ireland Road Safety Strategy 2013-2020

The Road Safety Authority has responsibility for co-ordinating the development of Ireland’s Road Safety Strategy.  The Government’s road safety target of no more than 252 deaths per annum by the end of 2012 was achieved in 2009, when the number of road collision deaths in Ireland fell to 239.  The reduction in the number of fatalities was achieved through robust actions in terms of education and awareness, road engineering, and enforcement, including significant legislative milestones.  The challenge is now to ensure that the impact of these measures on collision levels is sustained and enhanced into the future through continuous education, enforcement and road engineering measures and initiatives. IPH welcomes the opportunity to respond to this consultation given the significant burden of injury, disability and mortality associated with road traffic collisions on the island of Ireland.  IPH supports the development of evidence-based strategies and actions which can maintain a transport system, in which the safety of all road users is paramount. 

IPH response to Broadcasting Authority of Ireland (BAI): General and Children's Commercial Communications Codes (June 2012)

IPH submitted their views on the Draft BAI General and Commercial Communications Code. IPH previously submitted views to the BAI in the first phase of consultation (Oct 2011). The final code will regulate the advertising of food and non-alcoholic beverages that are high in fat, salt or sugar on Irish television channels. The submission sets out approaches to appropriate scheduling and content restrictions as well as to possible exemptions.

IPH response to Your Health is Your Wealth – Health and Wellbeing Framework 2012- 2020 (Department of Health)

The remit of the Institute of Public Health in Ireland (IPH) is to promote cooperation for public health between Northern Ireland and the Republic of Ireland in the areas of research and information, capacity building and policy advice. Our approach is to support Departments of Health and their agencies in both jurisdictions, and maximise the benefits of all-island cooperation to achieve practical benefits for people in Northern Ireland and the Republic of Ireland. The Department of Health is developing a Health and Wellbeing policy to improve the health of the population and reduce health inequalities by addressing causes of preventable illnesses. The Policy Framework is at an advanced stage with a number of background analytical documents prepared and published on the Department website to allow views to be incorporated into final drafts.  IPH responded to the consultation call in 2011 and we welcome the placement of these supporting documents on the Department website with the request for additional comments.

IPH response to the DSD consultation on regulations to prohibit or restrict irresponsible promotions of alcohol in Northern Ireland

IPH responded to the Department for Social Development consultation on the banning of certain promotions that may encourage irresponsible and excessive drinking. The consultation relates to regulations Article 57A(2)(d) of the 1996 Licensing Order “involving the supply of unlimited amounts of intoxicating liquor for a fixed charge (including any charge for entry to the premises)” and Article 31A(2)(d) of the Registration of Clubs Order “restricting the price at which the holder of a licence or the licence holder’s servant or agent may sell on licensed premises a package containing two or more intoxicating liquor products”. IPH welcomes this consultation and supports the Department’s proposals to restrict promotions that involve the supply of unlimited amounts of intoxicating liquor for a fixed charge. IPH welcomes this tangible action linked to the renewed commitment to tackling alcohol-related harms on the island of Ireland set out in the Steering Group Report on a National Substance Strategy (Dept of Health, 2012) and in the New Strategic Direction on Alcohol and Drugs (DHSSPS, 2011). IPH considers that irresponsible alcohol promotions can contribute to this burden of physical and mental ill-health, accidental and non-accidental injury and other harms associated with excessive alcohol consumption in Northern Ireland. As previously stated in the IPH submissions on the introduction of powers to prohibit or restrict irresponsible alcohol promotions (Dec, 2010), IPH considers that the issues of promotion and price are inter-related. The effectiveness of the proposed restrictions could be reinforced by the expeditious introduction of minimum unit pricing of alcohol on an all-island basis.