Memorandum by Imperial Tobacco Limited
(SP11)
In response to the Health Select Committee's
call for submissions to its Inquiry into Smoking in Public Places,
please find enclosed the following brief memorandum from Imperial
Tobacco Limited United Kingdom ("ITL").
As the Committee has indicated that it will
consider the relevant responses already made to the Government's
consultation on the Health Improvement & Protection Bill,
we trust that our submission to that consultation will be accepted
in that context. Further, as a principal member of the UK Tobacco
Manufacturers" Association ("TMA") ITL has contributed
to and fully supports all documents already submitted by the TMA
to various government and parliamentary consultations throughout
the UK.
ITL is a long-established UK business and a
subsidiary of the Imperial Tobacco Group PLC ("ITG").
ITL is the UK division of ITG and is responsible for the manufacture,
sales and distribution of Imperial's tobacco products in the UK
to approximately 100,000 trade customers. ITL employs in excess
of 2,600 people in the UK.
This memorandum focuses on ITL's views with
regard to the science of environmental tobacco smoke ("ETS")
in order to explain that the level of risk associated with ETS
and various diseases has been exaggerated. It will also address
the issue of our ability to properly conduct our business if such
a ban, as proposed by the Government, is instituted.
ITL has given our submission thoughtful consideration
and we trust it will be of benefit to the Committee's deliberations.
It is my view that:
— Effective health policy must be based
on sound science. In our view, many of the so-called health messages
on smoking in public places as presented by a range of interest
groups and represented in the media are not based on the most
accurate and reliable science.
— The risks associated with Environmental
Tobacco Smoke (ETS) have not been proved to be greater than other
potentially detrimental risks to human health such as diesel emissions
and RF radiation from mobile phones and mobile phone base stations
which, although subject to precautionary and advisory measures,
are not subject to blanket prohibitions.
— If there is any risk to health from
ETS smoke to persons that do not themselves smoke, then that risk
is small and impossible to measure.
— Messages to the general public about
the levels of risk between ETS and various diseases have been
exaggerated. Not only are the majority of the published scientific
studies inconclusive, but in the minority of studies that do report
a small increase in relative risk, this increase is weak and well
below the criteria that the UK Government would normally accept
as indicative of a risk factor for disease.
— Chemicals are ubiquitous—there
is no such thing as "clean" air, especially inside buildings.
There are very few substances that are specific to ETS, and the
presence of ETS itself has a minimal effect on the overall level
of chemicals present in enclosed spaces.
— Ventilation can greatly improve the
quality and feel of indoor environments, and ITL advocates the
use of ventilation as part of an overall strategy towards reducing
ETS in public places.
— Although some groups claim that ventilation
is ineffective at removing the carcinogens present in ETS, it
is a scientific impossibility to remove some substances and to
leave others. This is because all components of ETS mix with air
and are diluted to the same extent by ventilation. This is a fundamental
property of gases, and a tenet of basic physics.
Uncertainty is unsatisfactory for both sides
of the debate, but with regard to the science of indoor air quality,
it will remain. It is not helpful for either side to present the
health argument as clear-cut, and some recognition of this will
surely allow decision makers the scope to make choices that, whilst
minimising involuntary exposure to ETS, give adult smokers reasonable
opportunities to continue to enjoy tobacco products in a social
setting.
ITL has some specific concerns about our ability
to properly conduct our business in the UK within the regulatory
framework required, especially if the proposed definition that
defines smoking as ". . . holding or otherwise in possession
of lit tobacco" remains. ITL tests products and uses smoke
testing machines as part of our regulated product testing requirements
in our premises including Bristol, Liverpool and Nottingham. This
testing is mandatory to comply with the legislation regarding
the marking of tar and nicotine yields which must be displayed
on every pack of cigarettes sold in the UK.
In terms of ETS, the output from the smoking
machines that we use in this testing process are little different
from the effect of a person physically smoking a cigarette. Similar
quantities of the particulates and gases in ETS are the by-product
of both actions.
ITL requests that our Company, as a tobacco
manufacturer, be added to the list of those premises to be exempt
from the Regulations. This is a necessary derogation in order
for us to be able to test our products for the purpose of regulatory
compliance and quality control.
Furthermore, ITL believes it is very regrettable
that the adult activity of smoking in public places should be
criminalised. 12 million UK adults choose to smoke and it is our
view that they should not be targeted and discriminated against
in such a fashion, particularly when the justification for such
discrimination is based on flawed science.
Our submission has been developed with regard
for the public health objectives of the UK Government, and taking
into account our own expertise in the science of environmental
tobacco smoke and indoor air quality. We ask that the Committee
gives it due consideration.
August 2005
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