The submission, prepared by Public Health South, will go before the board for consideration today.
Among the comprehensive array of proposals in the submission are calls for the removal of liquor law exemptions for police and fire brigade canteens, the alcohol purchase age to be 20 on licensed premises and a ban on managers and employees of licensed premises drinking on the job.
While it supports the general intent of the 271-page Bill, the submission expresses concern that advertising, driver blood-alcohol level and pricing are not addressed.
Requiring local authorities to develop local alcohol policies would ensure communities were given the opportunity to have a say on how alcohol should be managed in their areas, the submission states.
In regions without local alcohol policies, community consultation was denied and councils would have to rely on default national maximum trading hours rather than being able to stipulate reduced opening hours (the wording of the Bill says local authorities may have local alcohol policies).
On the question of exemptions for defence-force messes and police and fire brigade canteens, the submission states there is no monitoring of host responsibility in such premises and this could have adverse consequences for the local community.
Last year, Public Health South and the police were made aware that a rural fire station in Southland was using its premises "like a club and was allowing alcohol to be sold for consumption off the premises".
The submission opposes granting general caterer's licences, saying caterers should have to apply for a special licence for their events.
Existing licences in this area could be used for large-scale and potentially high-risk events without the requirement to inform the police or district licensing authority.
This could result in inadequate host responsibility with potential for harm.
It gave the example of the 2004 Fight for Kidz event at Stadium Southland, where it said a large amount of alcohol was supplied at each table, quickly creating an environment where patrons became intoxicated.
Some of those who attended the event were not provided with a meal option and unopened 24-packs of beer were sold.
This matter went before the Liquor Licensing Authority and resulted in a suspension of the licence for seven days and a one-month suspension of the manager's certificate.
The submission pointed out that public health units were not involved in processing caterers' licences and this meant public health might not be considered.
Late last year, there was a "communicable disease outbreak in Dunedin following a social function" where a caterer's licence had been used and the water supply was found to be contaminated.
This situation would have been averted if a special licence had been required and the application reviewed by a Medical Officer of Health, the submission stated.
The submission asks that it be an offence for managers and employees of licensed premises to consume alcohol while on duty.
Alcohol consumption was not conducive to the vigilance and judgement required and, in Southland, Public Health South was aware some hospitality staff had become alcohol-dependent, which affected their perception of patron-intoxication levels.
In a section on the health burden associated with alcohol, the submission says it is estimated that a third of Dunedin Hospital emergency department presentations were for alcohol-related events.
Data on the percentage of overall admissions to Dunedin's emergency department was still being collated and is not in the submission, but it stated that the number of alcohol-related weekend presentations significantly impacted on staff's ability to meet the six-hour time patients should spend in the department because "staff are dealing with drunkenness".
"The impact of alcohol-related harm on our hospital services is significant."
The submission calls for the age for buying alcohol on licensed premises to be raised to 20 years.
If Parliament decided to retain the purchase age at 18, then it would be essential to introduce other measures to reduce the harmful use of alcohol, not only by young people, but also by the community as a whole, the submission stated.
Public Health South is asking the board to consider developing a policy statement on alcohol to "provide direction to future service provision in this area".
