National Drug Strategy
National Drug Strategy

British American Tobacco Australia - Response to the draft National Tobacco Strategy 2012-2018 - 25 June 2012

Response of British American Tobacco Australia to the draft National Tobacco Strategy 2012-2018

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Executive Summary

Introduction

BATA welcomes the opportunity to respond to the Intergovernmental Committee on Drugs, Standing Committee on Tobacco’s (the Standing Committee) draft for consultation of the National Tobacco Strategy 2012-2018 (the draft NTS).

We acknowledge and support the goal of the Standing Committee to improve the health of all Australians by reducing the prevalence of smoking and its associated health, social and economic costs, and the inequalities it causes.

BATA believes that the hallmark of sensible regulation lies with its workability and enforceability, as well as its ability to demonstrate clear and measurable public policy objectives. Any proposal should meet this benchmark before being enshrined in law.

Our approach to regulation, and what we believe to be the most appropriate approach, is that it should be evidence based, with measurable results, that can be demonstrated to achieve public health objectives whilst not creating unintended consequences, as is explained further in this document.

The following document outlines BATA’s view on the issues raised by the draft NTS and proposes some additional initiatives for dealing with tobacco control in a sensible manner.

Where the draft NTS raises concepts for consideration we offer preliminary comments. If any of these concepts were later to be developed into specific regulatory or legislative proposals, we would expect to be consulted so that we could respond more specifically.

BATA background

With approximately 45.6 percent of the legitimate cigarette market1, BATA is the country’s leading tobacco company. We manufacture and distribute cigarettes and roll your- own tobacco and distribute pipe tobaccos and cigars. Our brands include Winfield,Benson & Hedges, Dunhill, Pall Mall and Holiday.

Our company currently employs approximately 1,000 people, with operations in every Australian state and territory, and our federal tax contribution alone is approximately $4.5 billion annually.

There are approximately 35,000 retailers throughout Australia that sell tobacco products and indirectly, tobacco accounts for almost 50,000 jobs in the retail sector alone.
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Working for sensible regulation

Contrary to the views of some commentators , BATA supports sensible regulation of the tobacco industry. We support regulation that is balanced and, most importantly, has a robust evidence base – actually helping to achieve the intended public health objective.

Badly drafted and ill conceived regulation can, however, result in unintended consequences, such as a possible further rise in the already growing black market in illicit tobacco, making cheaper tobacco available and therefore more affordable. Not only does this damage our business but it deprives government of significant revenue.

BATA and smoking

With smoking comes real risks of serious diseases. Our business is not about persuading people to smoke, it is about offering quality products to people who have already made the informed decision to smoke.

The only way to avoid the risks of smoking is not to smoke, but a real world view suggests that a large number of people will continue to choose to smoke even though they are aware of the risks.

Tobacco continues to be one of the most highly regulated consumer goods in the Australian market. To ensure that any further regulation is workable, achievable and evidence based, it is important that tobacco manufacturers and retailers are part of the policy process, otherwise such measures could bring with them serious unintended consequences that can undermine public health efforts.

We also believe that whilst it is important to respect the rights of non smokers, there is also an obligation on the part of regulators to respect the rights of informed adult consumers to choose whether they wish to use legal tobacco products or not.

Such regulation should also respect the rights of legitimate tobacco companies, who produce a legal product and conduct their business in a responsible manner.

Core areas of focus for sensible tobacco regulation

We note that the draft NTS asks for feedback on various matters, including whether there are any gaps in the eight identified priority areas.

BATA thinks that one priority area which has not been fully explored is in relation to “tobacco harm reduction” and potential public health and regulatory approaches that could be considered to help reduce the impacts of tobacco use on public health, in addition to continuing traditional prevention and cessation efforts.

The draft NTS refers to the National Tobacco Strategy being “a sub-strategy of the National Drug Strategy 2010-15 which provides a framework for action to minimise the harm to individuals, families and communities from alcohol, tobacco and other drugs. Central to this approach are the three pillars of demand reduction, supply reduction and harm reduction, which are applied together to minimise harm.”2

The National Drug Strategy 2010-15 states that “(t)he overarching approach of harm minimisation, which has guided the National Drug Strategy since its inception in 1985, will continue through 2010-2015.”3 This concept of “harm minimisation” is similar to the definition of “tobacco harm reduction” adopted by the US Institute of Medicine (IOM) of “minimizing” the “harms and decreasing total morbidity and mortality without completely eliminating tobacco and nicotine use.”4 This IOM concept is gaining acceptance among a section of the public health community who believe it to be an important addition to current smoking prevention and cessation efforts.

The National Drug Strategy 2010-15 encompasses the three pillars of demand reduction, supply reduction and harm reduction as “being applied together in a balanced way.”5 The three pillars are to be underpinned by “commitments to: BATA supports the Government’s continued efforts to reduce tobacco related harm in the community, and the nature of its “commitments” to achieve this (as stated above), as working towards the goal of reducing the harm caused by tobacco use is something that should be of benefit to society.
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We support pragmatic public health and regulatory approaches to “tobacco harm reduction” which recognise this reality of continuing tobacco use among a significant number of adult consumers worldwide (the World Health Organisation has estimated that there could be between 1.5-2.2 billion smokers worldwide by 20507) and which take a broader perspective on potential options for harm reduction as a pillar of tobacco regulatory policy, alongside traditional smoking prevention and cessation initiatives. An example of this broader approach to tobacco harm reduction among regulators can be seen with the US Food and Drug Administration (FDA), which is currently the only regulator with a mandate to evaluate submissions on candidate “modified risk tobacco products.”8

There is available evidence from various countries around the world that a number of smokers want to try or are trying alternative tobacco or nicotine products (such as, for example, electronic nicotine delivery systems and/or smokeless tobacco products (STPs))
in substitution for their usual cigarettes and that, among those who have done so, a proportion have been successful in reducing their use of cigarettes or completely quitting cigarettes. There is some evidence to suggest that this might also be the case among
Australian smokers. 9 10

There is also increasing scientific consensus that certain low-toxicant STPs (such as Swedish-style snus) present substantially lower overall health risks than cigarettes. In relation to the risk profile of nicotine, the view of the Tobacco Advisory Group of the Royal College of Physicians is that “nicotine itself is not especially hazardous, and that if nicotine could be provided in a form that is acceptable and effective as a cigarette substitute, millions of lives could be saved.”11

Our view is that potentially reduced-risk tobacco and nicotine products may well have a role to play in helping to reduce the public health impacts of cigarette smoking and other tobacco use in Australia, and we recommend that the draft NTS should explore further potential regulatory options in this regard.

A regulatory framework could be established to, for example, set science-based product and quality standards for these types of products, to facilitate monitoring of these products in use by consumers and to allow communication of clear and accurate information to consumers to enable them to understand the relative risks of different products.


1 BAT exchange of sales 2010 FY share source: PWC/AC Nielsen 2011)
2 Draft NTS, pg 13
3 The National Drug Strategy 2010-15, pg ii
4 Clearing the Smoke – Assessing the Science Base for Tobacco Harm Reduction, Institute of Medicine (2001)
5 The National Drug Strategy 2010-15, pg 2
6 The National Drug Strategy 2010-15, pg 3
7 The Tobacco Atlas, WHO, MacKay, Eriksen & Stafey, 2006
8 Family Smoking Prevention and Tobacco Control Act (11 June 2009), Section 911
9 Smokeless tobacco use in Australia, C.E. Gartner & W.D.Hall, Drug and Alcohol Review (May 2009), 28, 284-291
10 Are Australian smokers interested in using low-nitrosamine smokeless tobacco for harm reduction? CE Gartner, EV Jimenez-Soto, R Borland, RJ O’Connor, WD Hall, Tob Control 2010; 19: 451-456 doi
11 Royal College of Physicians. Harm reduction in nicotine addiction: helping people who can’t quit. A report by the Tobacco Advisory Group of the Royal College of Physicians. London: RCP, 2007

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