by Professor Hurst Hannum, Fletcher School of International Law and Diplomacy, Tufts University, USA
Following extensive consultations with individuals and organizations in many countries, a group of experts met in Dublin on 26-28 May 1997 at the invitation of the National College of Industrial Relations and the International Center for Alcohol Policies. At the end of the meeting, in their individual capacities, they adopted by consensus the Dublin Principles and expressed the hope that these Principles will be generally adopted.
Participants included scientists, industry executives, government officials, public health experts, and individuals from intergovernmental and nongovernmental organizations.
Dublin Principles Preamble: The ethics of cooperation
"The common good of society requires all its members to assume their fair share of social responsibility. In areas related to alcohol consumption, individuals and the societies in which they live need to be able to make informed choices. In order to further public knowledge about alcohol and prevent its misuse, governments, the beverage alcohol industry, scientific researchers, and the public health community have a common responsibility to work together as indicated in these Principles."
The brief Preamble places the Dublin Principles in the broader context of social and ethical responsibility, which is relevant to public and private entities, including governments, intergovernmental organizations, and business. Although there are some advocates who wish to isolate the beverage alcohol industry from any participation in research, policy formulation, or promotional public health activities, such a position runs counter to the weight of contemporary moral, philosophical, business, and political opinion. The Principles reflect this trend, which calls for greater involvement by business in social issues, not less.
Recognition of such principles of corporate social responsibility may be found in, for example, the Beer Institute Advertising and Marketing Code ("[B]rewers are responsible corporate citizens, sensitive to the problems of the society in which they exist...") and the IDV Code of Business Conduct ("Successful businesses are those which respect and re-invest in the societies from which they draw..."). Among non-alcohol-related companies, references to social responsibility may be found in documents as diverse as the well-known Credo of Johnson & Johnson ("We are responsible to the communities in which we live and work and to the world community as well...") and codes of conduct adopted by, for instance, BankAmerica, Wells Fargo Bank, Citicorp, Hewlett-Packard, the New Zealand Computer Society, the American Chemistry Society, Nortel, and Lockheed Martin.
Alcohol and society: Cooperation among industry, governments, the community, and public health advocates
Precedents for many of the principles in this section may be found in existing codes of conduct or marketing practices developed by beverage alcohol trade associations and individual companies. Of course, the Dublin Principles are tailored so that they respond to the specific context of alcohol production, sale, use, and regulation.
The Jakarta Declaration on Health Promotion into the 21st Century, adopted by the Fourth World Health Organization Conference on Health Promotion in July 1997, states, "There is a clear need to break through traditional boundaries within government sectors, between government and non-government organizations, and between the public and private sector. Co-operation is essential... Health promotion requires partnerships for health and social development between the different sectors at all levels of governance and society... Partnerships offer mutual benefit for health through the sharing of expertise, skills, and resources. Each partnership must be transparent and accountable, and be based on agreed ethical principles, mutual understanding and respect."
Principle I - A: "Governments, nongovernmental organizations, public health professionals, and members of the beveragealcohol industry should base their policies and positions concerning alcohol-related issues upon the fullestpossible understanding of available scientific evidence."
This paragraph emphasizes that all sectors involved in alcohol have a responsibility to base their policies on scientific fact, not preconceived ideas or moral bias; it is complementary to the call for accurate information set out in Principle I - F.
Principle I - B: "Consistent with the cultural context in which they occur, alcohol policies should reflect a combination of government regulation, industry self-regulation, and individual responsibility."
Given the complex nature of alcohol use and its regulation, it is clear that meaningful alcohol policies must involve all of the primary actors. Every government regulates alcohol consumption in some respect, from taxation to restrictions on sale to the criminalization of certain conduct related to excessive drinking. Industry self-regulation also is common, particularly in the area of advertising, but also in defining production and quality standards. Whatever the legal constraints imposed by government, however, many of the most important decisions about drinking alcohol must be made in a particular social context by the individual consumer or abstainer. This Principle recognizes the role of all of these actors, but it does not exclude the participation of others, such as the public health community.
Principle I - C: "Consumption of alcohol is associated with a variety of beneficial and adverse health and social consequences, both to the individual and to society. Governments, intergovernmental organizations, the public health community, and members of the beverage alcohol industry, individually and in cooperation with others, should take appropriate measures to combat irresponsible drinking and inducements to such drinking. These measures could include research, education, and support of programs addressing alcohol-related problems."
There are no doubt some individuals who are unable to drink any amount of alcohol responsibly. It seems equally clear that very low levels of drinking (for example, one drink per day) have no negative effects for most people and may even have some positive impact on health. Beyond that, there is a great deal of disagreement over what constitutes "responsible" drinking, both in terms of the amount of alcohol consumed and patterns of consumption.
Nonetheless, recognition that there are risks associated with the misuse of alcohol beverages is beyond argument and has been explicitly accepted in many existing industry codes, for example, the DISCUS Code of Good Practice, Dutch Code for Alcoholic Beverages, and the IDV Code of Ethical Marketing Practice. Programs designed to minimize these risks have been adopted by WHO and a wide number of government and quasi-government bodies, as well as the public health community.
Principle I - D: "Only the legal and responsible consumption of alcohol should be promoted by the beverage alcohol industry and others involved in the production, sale, regulation, and consumption of alcohol."
The freedom to publish (or otherwise rapidly disseminate research results) is an inviolate principle of academia that is incorporated into University policy. The compromise of this principle is not acceptable. However, because of the nature of private enterprise and the risks underwritten by for-profit sponsors of research, contracts often contain language that allows a time-limited review period during which the sponsor may delay publication in order, for example, to decide whether to file a patent application. This period may be negotiable, but lengthy or unreasonable delays that have the effect of sequestering information are unacceptable.
Despite such lofty statements, recent reports have revealed troubling examples of censorship imposed by both industry and government. For example, the Journal of the American Medical Association published a report of work related to thyroid drugs only years after it was completed, because of opposition from the sponsoring company (see D. Rennie (1997). Thyroid storm. Journal of the American Medical Association, vol. 277). Another report suggests that, while withholding of research results is not widespread, industry-supported researchers are more likely than others to withhold or delay publication of their work (see D. Blumenthal et al. (1996). Participation of life-science faculty in research relationships with industry. New England Journal of Medicine, vol. 335).
Similarly, the U.S. National Institutes of Health reportedly refused in 1972 to allow publication of a paper showing that men who drank moderate amounts of alcohol had a lower risk of coronary heart disease than those who did not drink (see C. C. Seltzer (1997). "Conflicts of interest" and "political science." Journal of Clinical Epidemiology, vol. 50). Dr. Seltzer concluded that "conflicts of interest and pressures on investigators need not arise exclusively from commercial organizations. A non-profit governmental agency that funds research can also suppress some of its findings, and can alter definitions and analyses to make results that originally contradict a governmental policy emerge as supportive. What should be epidemiologic science may then become political science."
This Principle would not interfere with the hiring of any person by industry, government, or an intergovernmental organization to provide expert advice, whether confidentially or publicly. Dissemination of materials developed during such consultancies may be limited by contract or otherwise, and publication would be governed by other Principles requiring disclosure of financial interests, funding sources, and possible conflicts of interest. However, this exception to the normal practice of publication or dissemination should not apply if the results of the research have significant public health implications, in which case the researcher might have an ethical obligation to disclose certain information in spite of contractual obligations requiring confidentiality.