Memorandum by Thomas Holdings Ltd (SP07)
We represent British gaming industry operators
involved in many sectors of the current leisure market—including
bingo halls, betting offices, adult gaming centres (AGCs), seaside
arcades and piers, pubs, restaurants and machine manufacturing
companies. Our businesses, comprising outlets across the UK, directly
support up to 15,000 jobs.
I write in connection with your committee's
investigation into the Government's plan to ban smoking in confined
public spaces. I have set out below a summary of the arguments
we have submitted to the Department of Health (DoH)'s consultation
process.
Our key recommendations are that:
— A level playing field should exist
across all types of leisure operators as the anti-smoking provisions
of the Health Protection and Improvement Bill are introduced.
— Steps taken to improve the health
of employees in all types of leisure establishments should apply
equally regardless of the type of establishment.
We make a number of representations specific
to the DoH consultation document, using their numeration:
QUESTION 4
Exceptions—all licensed premises (receive
a longer lead-in time)
There is no basis for giving special treatment
to bars and pubs when the effect would be that staff in these
venues would continue to suffer the effects of smoking, whereas
in venues where smoking was banned, they would not. We can see
no reason why bar and pub employees should be exposed to risk
compared to those working in venues to which the smoking ban would
apply.
QUESTION 5
Exceptions—All Licensed Premises that do
not prepare and serve food—definition of "prepare and
serve food"
The preparation and service of food should not
be a determining factor. The objective of the Government's policy
is set out at paragraph 2 of Annex B to the Consultation Document.
There is nothing within that objective which justifies the exclusion,
from the effect of a ban, of premises where food is prepared and
served.
QUESTION 7
Exceptions—Membership Clubs
There is no reason to assume that those working
in members' clubs should be any less entitled to the benefits
of a reduction in the risk to health from exposure to second-hand
smoke. Cumulatively, members clubs of the sort referred to in
paragraph 24 of the Consultation Document employ vastly more people
than do, for instance, the country's bingo halls, AGCs, seaside
amusement arcades or even licensed betting offices. Why should
those employed in prospectively exempted clubs be viewed differently
to their fellow workers in other sectors of the leisure industry?
QUESTION 10
Offences and Penalties
If there are going to be complex regulations
and procedural requirements affecting the implementation of restrictions,
it seems iniquitous that the penalties should be higher for the
company, manager or operator of premises than for the individual
who, in the face of clear signs explaining any ban, deliberately
"lights-up" in breach of it.
CONCLUSION
In summary, if there is to be a ban on smoking,
it should apply to all leisure outlets and there should be no
exemptions. On this basis, we favour Option 2 from the DoH consultation
document. However, because such a ban would have wider-reaching
consequences than a ban with exemptions, we believe it would be
best for its introduction to be delayed until 2009, to give those
likely to be affected time to adapt to its effect.
A full copy of our submission to the Department
of Health consultation is attached for your reference[21].
September 2005
21 Not printed. Back
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