Brad S. Krevor, Ph.D, Heller Graduate SchoolBrandeis UniversityMarch 30, 2005

The Integrated Responsible Retailing Systems Project

A new model to reduce the sale of age-restricted products to underage customers

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Background

Attorney General Consumer Protection Initiative:

4 Regional meetings (1999)

National CDC-sponsored meeting (March 2000)

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Background

Report on Best Practices for RR

Commissioned by Center for Substance Abuse Prevention (CSAP)

Diverse Report Committee

Review of evidence

Alcohol enforcement

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Background

Innovations of CSAP Report: • Completed a systematic review of components of RR

• Identified the critical nature of management systems

• Role of public agencies: enforce and assist licensees identify and implement Best Practices for RR

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Background

Paradox of enforcement:Enforcement is sine qua non of compliance…

… but public agencies have inadequate resources to inspection frequently

“Educate into compliance”: … but not when turnover rates > enforcement frequency

Wagenaar study (2005)

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Background

Paradox of enforcement:

Deterrent effect is undermined by uncertainty of how to avoid risk:

Policies do not translate into consistent clerk (or manager) performance

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Background

EAV Study for Miller Brewing Company:

Clerk is important determinant of whether the store is found to be compliant (EAV study)

TobaccoInspections

Baseline 1Compliance

Baseline 2Compliance

CompliantB1 & B2

Florida 81% 86% 66%

Iowa 43% 51% 33%

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Clerk characteristics: • Little or no loyalty to job or employer

• Aversion to confrontation

• Personal use of alcohol and tobacco, now or as

minor, may affect age-verification behavior

• Willful collusion

Impact of tight labor market and limited hiring pool

Background

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Integrated Responsible Retailing Model

a continuous system supported by the efforts of retailers, agencies, and other public and private stakeholders

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Protocols for age verification/ sales declination

Point-of-sales aids:

Signage

Specialty calendars

ID scanning

Hiring, Supervision,

Training

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A “Community Policing” model employs a “problem-solving” approach to underage access and use.

Identify and address actual sources of age-restricted products in the community

An involved, concerned community is decisive in motivating public agencies, which in turn can engage—and assist—retailers.

“Retailers as Active Partners”

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Responsible Retailing

Policies

• Laws and Regulations

• Enforcement protocols

• Penalties

• Funding

What Policies will encourage adoption of effective RR practices?

Public PolicyPublic Policy

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Background

2003 RR Forum 1st priority recommendation:Demonstrate and evaluate the integrated RR systems model.

Project partners:Alabama Alcohol Beverage Control Board

Iowa Division on Alcoholic Beverages

Missouri Dept. of Alcohol and Tobacco Enforcement

New Mexico Alcohol and Gaming Division

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Developing an operational model

1. Health care analogue: implementing clinical guide-lines in medical practice sites.

Example: In a1991 study, 60% of tobacco users reported that their primary care physician had not advised them to quit. What factors impede the adoption of clinical guidelines (1996) for treating tobacco dependence.

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Developing an operational model

Why primary care physicians don’t adopt guidelines: Unfamiliarity Time constraints: too busy Inability to overcome inertia of prior practice Doubts regarding effectiveness Doubts regarding self-efficacy (for tobacco) Aversion to confrontation

[note similarity to explanations for not checking IDs]

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Developing an operational model

Why primary care physicians do adopt guidelines:

Training (mixed results) Feedback on peer performance

Brandeis—Harvard study (1999): absence of resources and mechanisms is impediment.

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Developing an operational model

Assisting medical practice sites to implement clinical guidelines:

Planning Guide for Primary Care Practice Sites [and for Pre-Natal Care Practice Sites]

Promulgated by State of Vermont health department

Local hospital / health dept. provides medical sites with training and counseling

[Similar delivery system designs in Massachusetts, New Mexico, Oregon et al.]

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Developing an operational model

2. Business analogue for implementing Best Practices:

ExxonMobil Assurance of Voluntary Compliancea. Adoption of many Best Practices in CSAP Report

b. Continual monitoring

c. Remedial response to age-verification failures

d. Company-wide commitment

Transparency

How would one replicate the ExxonMobil model at the level of community?

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RR Systems Project

Phase 1 (Sept 2003 – May 2005):

Focus upon Tier 1: Retail-level

Objective: Develop tools to assist retailers and implementation strategies

Study Sites: Birmingham, AL Springfield, MO Santa Fe, NM Des Moines, IA

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RR Systems Project

Assistance to retailers:

1. Develop “A Planning Tool for [Iowa] Retailers” a quality improvement tool to assess current practices identifies absent Best Practices Promoted and supported by state Regulatory /

Enforcement agency: R / E Agency is engine that drives the model

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RR Systems Project

Assistance to retailers:2. Monitoring / Feedback

Multiple inspections by young adults Reports to retailers on individual inspections

Feedback—not penalties

Will include inspections by pseudo-intoxicated

customers

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RR Systems Project

Experimental Design: Arm #1: use of Planning Tool for Retailers Arm #2: use of Mystery Shopper reports Arm #3; use of both PT and MS reports Arm #4: control stores

60-80 stores per community (36 in Santa Fe)

Mostly gas station / C-stores (some package stores)

Mostly chains

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RR Systems Project

What we’ve learned in Phase 1:

Experimental design undermined by:

1. Change for chain stores occurs through district supervisor / trainer, not through individual store manager

2. Some chains introduced changes following state RR Forum

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RR Systems Project

Lessons from Phase 1:

Planning Tool for … Retailers

Useful self-assessment tool, especially for chains

Could be more explicit

Could be more prescriptive

Focus groups will be held in spring 2005

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RR Systems Project

Lessons from Phase 1:

Mystery Shopper Reporting

“50 year-old native American woman”

Use of feedback (Missouri experience)

Expand to capture opportunity of “teachable moment”

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RR Systems Project

Lessons from Phase 1: Variability of retailers

Chains Owner-operated

high Number of employees low

“ Turnover “

“ Need for Systems “

“ Level of technology “

“ Explicit policies “

no Manager is change agent? yes

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RR Systems Project

Phase 2 (beginning May 2005):

Focus: Community context (2nd tier of model)

Objective: Employ community policing principles to identify actual sources of alcohol (both commercial and social) in the community

“If you were 100% successful . . .”

Expand intervention

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RR Systems Project

Phase 3 (2006?):

Objective: conduct a multi-state community trial to evaluate the effectiveness of the “enforcement + assistance” model at the level of county, with study arms that employ various implementation strategies (e.g. voluntary, compulsory for violators, incentives) to engage retailers.

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Questions raised by RR Systems Project

Q. #1: How do we raise the level of performance in individual stores?

Andy’s Liquorette

ExxonMobil

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Questions raised by RR Systems Project

Q. #2: How do we engage retailers to adopt and sustain RR Best Practices?

Voluntary adoption: Corporate leadership Increase enforcement Build capacity: Field of Dreams fallacy Adopt BPs to discharge citation Mandatory adoption Retailer Incentives

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Questions raised by RR Systems Project

Q. #2: Potential retailer incentives

Reduced license fees

Mitigation for future infractions

Affirmative Defense for future infractions

Curtailment of routine compliance checks

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Questions raised by RR Systems Project

Q. #2: Incentives to engage retailers are problematic

Objections of Regulatory / Enforcement agencies

Compare: Susan Curry study Treatment for TB Brazil: payments to parents for 16 million school

children

Public health outcomes vs. personal responsibility Good Policy may be counterintuitive

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Questions raised by RR Systems Project

Q. #3: How do we create the capacity to sustain an RR system at the level of state and community?

Beyond current resources of R/E agencies

What would it cost to provide training, mystery

shopper feedback, enforcement?

Which entities can provide the “assistance” in the

“enforcement + assistance” model?

How can public resources be best applied?

How can public resources be leveraged?

Brad S. Krevor, Ph.D, Heller Graduate SchoolBrandeis UniversityMarch 30, 2005

The Integrated Responsible Retailing Systems Project