Brad S. Krevor, Ph.D, Heller Graduate School Brandeis University March 30, 2005

1. The Integrated Responsible Retailing • Systems Project • A new model to reduce the sale of age- • restricted products to underage customers • Brad S. Krevor, Ph.D, • Heller Graduate School • Brandeis University • March 30, 2005

2. Background Attorney General Consumer Protection Initiative: 4 Regional meetings (1999) National CDC-sponsored meeting (March 2000)

3. Background Report on Best Practices for RR • Commissioned by Center for Substance Abuse Prevention (CSAP) • Diverse Report Committee • Review of evidence • Alcohol enforcement

4. 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

5. 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)

6. 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

7. Background EAV Study for Miller Brewing Company: Clerk is important determinant of whether the store is found to be compliant (EAV study)

8. Background • 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

9. Integrated Responsible Retailing Model a continuous system supported by the efforts of retailers, agencies, and other public and private stakeholders

10. Protocols for age verification/ sales declination • Point-of-sales aids: • Signage • Specialty calendars • ID scanning Hiring, Supervision, Training

11. 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”

12. Responsible Retailing • Policies • Laws and Regulations • Enforcement protocols • Penalties • Funding Public Policy What Policies will encourage adoption of effective RR practices?

13. 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

14. 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.

15. 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]

16. 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.

17. 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.]

18. Developing an operational model 2. Business analogue for implementing Best Practices: ExxonMobil Assurance of Voluntary Compliance • Adoption of many Best Practices in CSAP Report • Continual monitoring • Remedial response to age-verification failures • Company-wide commitment Transparency How would one replicate the ExxonMobil model at the level of community?

19. 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

20. 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

21. 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

22. 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

23. RR Systems Project What we’ve learned in Phase 1: Experimental design undermined by: • Change for chain stores occurs through district supervisor / trainer, not through individual store manager • Some chains introduced changes following state RR Forum

24. 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

25. 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”

26. RR Systems Project Lessons from Phase 1: Variability of retailers ChainsOwner-operated high Number of employees low “ Turnover “ “ Need for Systems “ “ Level of technology “ “ Explicit policies “ no Manager is change agent? yes

27. 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

28. 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.

29. Questions raised by RR Systems Project Q. #1: How do we raise the level of performance in individual stores? • Andy’s Liquorette • ExxonMobil

30. 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

31. 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

32. 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

33. 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?

34. The Integrated Responsible Retailing Systems Project • Brad S. Krevor, Ph.D, • Heller Graduate School • Brandeis University • March 30, 2005