The Western Australian government has recently been consulting on their second round of liquor licencing reforms by inviting feedback on a Discussion Paper. These reforms are happening in the context of significant national commitments to reduce alcohol-related gendered-violence. The ‘Rapid Review of Prevention Approaches to End Gender-Based Violence’, recommended governments strengthen alcohol laws as part of a harm-reduction approach. This included making prevention of gendered violence a primary objective, restricting sales and delivery hours and advertising. In response, the National Cabinet committed to review alcohol laws and their impact on family and domestic violence.
However, the measures outlined in the Tranche 2 Liquor Reform Discussion Paper do not address the Rapid Review or meet Western Australia’s National Cabinet commitment. Instead, this Discussion Paper highlights industry gains like ‘combined savings’ and ‘increased sales’ and focusses on individual measures (like the Banned Drinker Register) instead of systemic measures like those recommended by the Rapid Review.
FARE is asking the WA Government to approach alcohol law reform through this lens of harm and recognise and act on alcohol as a commercial determinant of harm.
Summary of recommendations
- Make alcohol harm minimisation the paramount object of the Act and include domestic, family and sexual violence in the definition of alcohol-related harms.
- Specify that takeaway and delivery hours are between 10am and 10pm to prevent late night delivery of alcohol which contributes to family violence and suicide. Include a 2-hour safety pause between the online order and the delivery of alcohol to prevent higher-risk rapid delivery.
- Do not the change licence categories, other than implementing an Online Sale and Delivery (OS&D) license category. Instead, implement proposals to support applicants through the licensing framework.
- Establish a separate, specific liquor licence for OS&D, to align the administration, licence fees and conditions with the business model, entities and risks of harms associated with OS&D.
- Require licensees to display a prescribed health notice explaining the National Alcohol Guidelines.
- Prohibit unacceptable marketing practices. Extend the list of unacceptable promotional practices to digital marketing, eg. offering delayed payment; sending direct prompts; ‘buy-now’ buttons or offering incentives for a minimum spend or volume.
- Do not grant any new powers to the Minister to externally impose community-based interventions such as new alcohol restrictions, without community involvement.
- Incorporate a risk factor calculation of supply density, (as an equivalent for outlet density), that includes all alcohol sold and delivered in a geographic area.
