Comments on the Proposed Amendments to Responsible Beverage Service Training Program Update for Drink Spiking

Comment #2

Hi there,

My name is Elizabeth, and I am the Program Director of The Night’s Watch: a San Francisco-based
nightlife advocacy organization that focuses on sexual & gender-based violence prevention in nightlife &
music festival spaces. I am reaching out to provide written comment on the Pending Regulatory Package
for the Responsible Beverage Service Training Program Update. My comments mostly concern the Text of
Proposed Regulations & Initial Statement of Reasons and can be found in the attached PDFs. I will
summarize them below.
I also want to add that you could consider requiring that the training providers for AB2402 must have a
background/qualifications in sexual violence prevention in addition to the background and expertise that
is currently required.

Written Comment Key Takeaways:

•  “Creating a safe environment” – Consider rephrasing to “preventing drink spiking in service of
  creating a safer environment” or striking all together. Creating a safe environment requires
  addressing & preventing additional predatory behaviors that fall along the spectrum of sexual
  violence, inclusive of & beyond drink spiking.
• Consider including “maintain a list of local support resources for victims” as one of the steps
  alcohol servers should take if they receive a report that someone has been drugged as a result of
  drink spiking.
• Consider acknowledging the technical limitations of the test kits & the liability limitations for
  establishments who carry test kits (as specified in AB1013). Many of the most commonly
  available on the market have limits of detection that are much higher than a standard dose of the
  controlled substances that they commonly test for (GHB & ketamine), which runs the risk of false
  negatives. This could result in servers placing inappropriate confidence in test results without
  having this context.
• Consider adding some sort of one-page checklist or cheat sheet to have behind the bar for how to
  respond when a server receives a report related to drink spiking. Bristol Nights has an excellent
  Venue Procedure Guide.
• Consider rephrasing “alcoholic beverages” to “beverages” throughout since any beverage can be
  spiked.
• Reconsider conditions for calling emergency services that offer victims more choice as a way to
  give them power back if they are conscious and competent.

Thank you for the opportunity to provide written comment. Please let me know if you have any questions
or feedback. I look forward to applying to become a training provider for this curriculum.

ABC Response

Comments will be addressed at the end of the comment period.

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