Select Committee on Health Written Evidence


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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