HC 1048-III Health CommitteeWritten evidence from the UK Centre for Tobacco Control Studies (PH 18)

1. This submission is made on behalf of the UK Centre for Tobacco Control Studies, a UKCRC Public Health Research Centre of Excellence established in 2008 and comprising a network of leading tobacco control researchers from nine UK universities. A full listing of the researchers involved in the Centre, and information on the objectives and activity of the Centre, are provided at www.ukctcs.org.

2. Tobacco smoking is the largest avoidable cause of premature morbidity and mortality, and of social inequality in life expectancy in the UK. Smoking prevention should therefore be the highest priority in public health.

3. Effective policies to prevent smoking have been identified for over 50 years. Therefore, whilst smoking prevalence has fallen substantially over the past half century, the facts that 10 million people in the UK are still regular smokers, that smoking prevalence is still highest among young people, and that smoking rates have changed little among the most disadvantaged in society in recent decades reflect a systematic failure of UK public health policy in dealing with a major health risk.

4. In contrast to both food and alcohol, eradication of smoking and the industry that drives the smoking epidemic would represent a major benefit to society, with little if any disadvantage. The failure of public health policy to prevent smoking in the UK therefore bodes ill for likely success in dealing with the more complex problems of obesity and alcohol misuse.

5. The proposal to reform public health in the Healthy lives, healthy people white paper is therefore welcomed in principle, as an opportunity to create a system better able to deal with smoking, obesity, alcohol abuse and other “lifestyle” problems.

6. Sadly the principles of the reform of public health in the White Paper, and detailed Tobacco Control Plan for England that has followed, exhibit serious flaws in the approach to dealing with tobacco, and hence also for the likely success of approaches to these other lifestyle problems.

7. First and foremost of these is the lack of clear leadership responsibility for national level population strategies that discourage uptake of smoking, and encourage existing smokers to quit. The plan delegates tobacco control activity to local authorities and communities, but many key policies to make cigarettes less accessible and affordable, and reduce the perception (particularly for children) that smoking is a normal adult behaviour, need to operate across all such communities. Comprehensive implementation of all of these policies has proved key to the success of some countries and states in achieving much more marked declines in smoking prevalence in recent years than has been the case in the UK. Examples of policies that need to be implemented nationally include:

7.1Using price to reduce the affordability of cigarettes. Above-inflation price rises have not kept pace with incomes, so cigarettes are now more affordable in the UK than they were in 1965.

7.2Preventing illicit trade in tobacco, which undermines price policy and is a source of tobacco for children.

7.3Protection of children and adults from exposure to smoking behaviour through wider extension of smoke-free policy to outdoor areas not currently covered by smoke-free legislation, and prohibition of smoking in private vehicles.

7.4Delivery of innovative and varied media campaigns promoting non-smoking as the norm, discouraging uptake, encouraging cessation, and explaining and promoting harm reduction.

7.5Default adult (18) classification of films containing smoking imagery.

7.6Changing the retail environment of tobacco by removing point of sale displays, licensing retailers to concentrate tobacco sales into a smaller number of outlets with effective sanctions on those that sell to children.

7.7Introducing plain and standardised tobacco product packaging.

7.8Reforming nicotine regulation to encompass all nicotine products and promote the use of safer alternatives to tobacco smoking in a proactive harm reduction strategy.

The 2011 Tobacco Control Plan for England acknowledges most of these needs, but provides little if any concrete indication of how they will be pursued or delivered during the term of this government, and indeed substantially delays the implementation of point of sale display prohibitions enacted under the 2009 Health Bill. This lack of leadership at national level, and of clear identification of who will be responsible for coordinating the many government departments that need to be involved in this activity in relation to tobacco and other health threats, is a major omission.

8. Second is the extent of reliance on personal enablement and responsibility for healthy choices. Whilst welcoming the recognition of the importance of these factors, and agreeing that change arising from voluntary or self-motivated actions is preferable to that achieved by regulation or coercion, experience of the smoke-free legislation in 2007, and indeed from many other areas such as seat belt and drink-drive legislation indicates that legislation is also key to ensuring that change happens quickly. As an example, the Tobacco Control Plan promotes a voluntary approach to non-smoking in cars carrying children, when recent evidence from Canada demonstrates that exposure of children falls more quickly and more substantially when campaigns promoting individual responsibility are supported by legislation. Effective smoking prevention requires the balanced and pragmatic use of all relevant policy levers; dependence on any to the exclusion of others is illogical and detrimental to public health.

9. Third is the reliance on voluntary agreements rather than regulation of industry to protect public health. Although the tobacco industry is specifically excluded from the responsibility deal, experience in tobacco indicates very clearly that voluntary agreements generally fail. The promotion of voluntary agreements with the alcohol and food industries in the responsibility deal thus reflects a failure to learn from past mistakes.

10. There are some aspects of the Tobacco Control Plan that are strong; particularly in the commitment to extend the use and variety of smoking cessation interventions in the NHS and wider society. However the uptake and success of local services is highly dependent on motivation to quit, and that in turn is driven by national as well as local policies.

11. Thus in our view overall the Plan disappoints, and as outlined above, particularly by failing to recognise the importance of a pragmatic approach to prevention that uses all viable options, and coordinates the activities of different government departments.

12. We also share broader concerns outlined by others in the public health community that Public Health England at national level, and Directors of Public Health at local level, must be provided with the resources, independence and executive power necessary to deliver their contributions to dealing with these and other crucial threats to public health.

13. We therefore request the Health Committee to consider solutions to these deficiencies, and to the problem of cross-department coordination in public health policy, in its deliberations.

June 2011

Prepared 28th November 2011