Mandatory Reporting of Loss of Spirits Due to Theft and Internal Shrinkage: The public comment on proposed rulemaking on this topic will end Wednesday, February 27, 2013. This is a different and distinct window of opportunity for public comment then the one that ended on January 27. (In late January this item progressed to the “proposed rulemaking phase” – known as CR 102 – where a new comment period began specific to the proposed rule.) Proposed language under consideration by the LCB states:
(4) Spirit retail licensees must report to the board quarterly on a form provided by the board, spirits product loss due to theft and internal shrinkage.
The proposed language would be added to the Washington Administrative Code (WAC) that defines the requirements for a spirits retail license. The new language is underlined and can be found on the last page of the attached notice to stakeholders.
The WASAVP Board submitted the following comments to the Liquor Control Board:
Alcohol theft is rampant under I-1183 and spirits are being resold into the black market and finding their way into the hands of kids. In addition, product theft means fewer tax dollars in state coffers to help mitigate social costs. We find that accurate reporting of theft and internal shrinkage will help substance abuse prevention assets across the state in these ways:
1. Substance abuse prevention relies upon accurate data–accurate reporting will allow us to determine appropriate interventions and strategically allocate limited resources. (i.e. if we know vodka is being stolen, then we can educate teachers on identifying student impairment when an alcohol odor is harder to detect.)
2. Substance abuse prevention collaborates with law enforcement– accurate accounting of theft and shrinkage will allow police and prevention coalitions to coordinate enforcement and education efforts with appropriate businesses. (i.e. if a single store is being disproportionately targeted for theft, police can allocate enforcement resources in coordination with prevention coalitions that can implement targeted grassroots alcohol education and local policy efforts.)
3. Substance abuse prevention and treatment communities work together–accurate reporting of theft and shrinkage will inform collaborations between community prevention and treatment (i.e. with accurate reporting of theft and shrinkage, prevention assets can coordinate with substance abuse treatment providers to identify those particular brands or categories of spirits being stolen and/or abused by youth and create marketing and treatment intervention as indicated–is the underage market being flooded with a product typically “shot,” or mixed?–It makes a difference.)