Public Submission by Cancer Council,Queensland - Draft National Tobacco Strategy 2010 - 2018
25 June 2012
Draft NTS 2012
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National Tobacco Strategy 2012-2018 Thank you for the opportunity to comment on the draft National Tobacco Strategy 2012-2018.
Cancer Council Queensland Response to the Draft for Consultation
This submission is sent on behalf of Cancer Council Queensland, Queensland’s leading independent organisation in cancer control. Cancer Council Queensland is a Member Organisation of Cancer Council Australia and the recommendations provided herein can be read in conjunction with the recommendations of other state and territory Cancer Councils and Cancer Council Australia.
Cancer Council Queensland fully supports the intention of the strategy 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.
Cancer Council Queensland makes the following recommendations in relation to the strategy:
Priority AreasWhile no major gaps have been identified in the supporting evidence for the priority areas, the statements for priority areas six and seven could be strengthened, as follows:
6. Progress further regulation of the contents, product disclosure and supply of tobacco products and non therapeutic nicotine delivery systems;
Note : That is First word of the statements for priority areas six which is Consider removed and replaced with Progress as shown
7. Eliminate exceptions to smoke free workplaces, public places and other settings;
Note : That is First word of the statements for priority areas seven which is Reduce can be removed and replaced with Eliminate as shown
The rigour of the strategy framework in part five of the strategy could also be improved in several key areas which have been identified on the next page.
Part Two: The Size of the ProblemIn analysing the size of the problem and the effectiveness of proposed interventions for high risk groups, there is an urgent need for greater evidence for disadvantaged populations. This lack of evidence currently impedes the evaluation of tobacco control programs and limits understanding of tobacco usage among this high-risk group. i
Part two of the strategy should also include an additional section on smoking prevalence among Australian soldiers, in response to evidence that Diggers smoke at twice the rate of the wider community.ii
Part Five: The Framework
5.2 The ObjectivesIt is recommended that an additional objective be included to limit the interference of tobacco companies in tobacco control policy formulation, development and implementation. The additional objective should make reference to Article 5.3 of the World Health Organization’s Framework Convention on Tobacco Control, which states:
In setting and implementing their public health policies with respect to tobacco control, Parties shall act to protect these policies from commercial and other vested interests of the tobacco industry in accordance with national law. iii
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5.6 Building the Evidence Base for Tobacco ControlThe draft strategy correctly recognises the importance of the comprehensive online resource Tobacco in Australia: Facts and Issues. It should be noted that this vital resource is currently jointly funded by Cancer Council Victoria and Quit Victoria. It is recommended that the Federal Government embrace full funding responsibility for this online resource as a part of the National Tobacco Strategy.
5.7 Protection of Tobacco Control PoliciesIt is recommended this section of the strategy be amended to include specific articulation of the background to tobacco industry interference in policy setting in the Australian context and to clearly define Australia’s options for meeting its obligations under Article 5.3 of the WHO FCTC.
Part Six: Priority Areas and ActionsCancer Council Queensland makes numerous recommendations in response to the specific actions outlined in the draft strategy:
Action 6.1.2Campaigns targeted to Aboriginal and Torres Strait Islander people should not be 'mass media' campaigns and need to be narrowcasted. Narrowcasting, in contrast to broadcasting, involves aiming media messages at specific segments of the public defined by values, preferences, or demographic attributes and selecting media channels with the greatest penetration of the target segment. It is Cancer Council Queensland’s view that the effectiveness and cost efficiency of media campaigns targeted to Aboriginal and Torres Strait Islander people would be better achieved through narrowcasting.
Further, it is recommended that campaigns be developed and implemented with the full participation of Aboriginal and Torres Strait Islander communities, through comprehensive consultation.
Proposed Additional Action for Section 6.1It is recommended that a specific action be created in relation to the development of digital campaigns that harness new media technologies to reduce smoking.
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Action 6.2.2It is recommended this action be tightened by proposing a timeline for staged increase of the tobacco excise.
Action 6.2.4There is consistent evidence that the cost of NRT products is a barrier to use among highly disadvantaged groups.iv Another barrier is the requirement to consult a General Practitioner to get a prescription for NRT, v which then has to be issued by a pharmacist. Not only should low income smokers be encouraged to access subsidised medications but ease of access and availability of subsidised medications should urgently be improved.
Action 6.2.9It is recommended that Government tobacco control resources should not be used in protection of the tobacco industry’s intellectual property. Resources allocated to illicit trade in tobacco control should be concerned only with public health, through the effect of the evasion of taxes and duties on tobacco use.
Action 6.2.10It is recommended that this action be strengthened by pursuing legal and diplomatic advice on amendment of international obligations to enable tougher restrictions on duty-free sales and import of tobacco.
Proposed Additional Action for Section 6.2It is proposed that a specific action be created to commission a report on the economics of tobacco in Australia, including recommendations for transitioning away from all reliance on tobacco-related revenue and economic activity.
General Comments on Actions 6.3Consideration should be given to involving local governments and Aboriginal Shire Councils in these actions, in recognition of the close partnerships between many of these bodies and Aboriginal and Torres Strait Islander communities and organisations.
The Committee should make note that funding for the Closing the Gap Workforce Initiative and Quitline enhancement has not been guaranteed beyond 2013. It is recommended the strategy be amended to include an explicit commitment to ongoing funding of these important measures to promote tobacco control.
Action 6.3.8Consideration should be given to alternative options for the provision of subsidised NRT to those populations who have limited access to GPs.
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Action 6.3.10It is recommended that social marketing campaigns more broadly include promotion of Quit supports that are available to Aboriginal and Torres Strait Islander peoples, such as the Quitline and subsidised NRTs, rather than having a limited focus on raising awareness of smoking as a health issue.
General Comments on Actions 6.4Consideration should be given to the development, implementation and evaluation of multi-faceted programs that jointly target tobacco and alcohol use among disadvantaged populations.vi Consideration should also be given to the cross-structural expansion of supportive tobacco control measures, for example, by introducing a smoke free program linked to Newstart Allowance and other pensions, as appropriate (please note that any such programs should not be punitive measures).
Proposed Additional Action for Section 6.4Consideration should be given to the addition of an action specific to addressing smoking cessation among culturally and linguistically diverse populations, similar to the specific actions regarding people with mental illness and people in prisons.
General Comments on Actions 6.5Many of the actions under this priority are exploratory and/or investigative in nature (6.5.4, 6.5.5, 6.5.6, 6.5.8, 6.5.9, 6.5.10). It is recommended that the articulation of these actions be strengthened in recognition of the health benefits to be gained from restricting tobacco industry promotions and in particular the potential to reduce smoking uptake among young people.
Action 6.5.4It is recommended this action be further strengthened by requiring tobacco companies to routinely report on sponsorships, donations and payments to organisations and third parties. Consideration should also be given to reciprocally requiring companies to report on and disclose all payments received from tobacco companies.
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Action 6.5.11At present, we are not aware of any government or non-government organisation monitoring the classification of smoking in television, cinema, computer games or other forms of online entertainment. It is recommended this action be broadened to include monitoring of the portrayal of smoking across the spectrum of popular media, particularly popular media targeted at young people.
Action 6.6.6This action should be further strengthened by legislation to prohibit the sale of tobacco by minors.
Proposed Additional Action for Section 6.7It is recommended a specific action be created to urge greater cooperation between state and territory governments, via the Council of Australian Governments reform process, to prioritise the creation of uniform state and territory legislation regulating tobacco control, in 10 key areas:
1. Uniform Statewide laws to ban smoking in public places.
2. Bans on smoking in licensed premises.
3. Bans on the sale of menthol and flavoured cigarettes.
4. Bans on vending machines dispensing tobacco products.
5. Bans on tobacco companies from providing sales incentives to retailers.
6. Bans on smoking in premium gaming rooms.
7. Licensing of all tobacco retailers.
8. Bans on the sale of tobacco products by people under the age of 18.
9. Total bans on smoking in cars.
10. The revision of Strata Titles legislation to regulate smoking in multi-unit dwellings.
Action 6.7.7This measure is supported and it is recommended that the adoption of these policies by State and Territory Governments should occur as a matter of priority. Queensland legislation currently prohibits smoking in six major sport stadia across the state. However, no legislation exists to the protect the health of staff, participants or spectators who attend events at other outdoor sporting grounds across Queensland.
Action 6.7.8It is recommended this action be strengthened to immediately move to developing options to reduce second-hand smoke exposure of residents in multi-unit dwellings. It is critical that the Commonwealth, state and territory governments, and non-government organisations, build on the evidence regarding smoking indoors around young children, to consider mechanisms to support the creation of smoke-free home environments.
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Action 6.8.7It is recommended this action be strengthened to include consideration of the amendment of clinical guidelines to include a screening protocol to identify and manage tobacco addiction, codifying tobacco control in professional practice guidelines across the continuum of health services and systems in Australia.
Further, it is recommended that consideration be given to the introduction of a Medicare rebate for General Practitioners and Practice Nurses to offer counselling and referrals to smoking cessation services.
Proposed Additional Section for Part SixIt is recommended that a specific section be created to address the prevalence of smoking among soldiers serving in the Australian Defence Force. The actions under the additional section should include research into the patterns of tobacco consumption in the Australian Defence Force in order to inform the development of targeted intervention programs. Actions must include the development, implementation and monitoring of dedicated tobacco control programs across the Australian Defence Forces. The actions should support the clear need for the creation of a tobacco control policy in the ADF. These actions must articulate the requirement for programs to be underpinned by the introduction of centralised controls on tobacco pricing for troops stationed overseas and sailors serving in international waters. vii
Part Seven: Monitoring ProgressIt is recommended that the strategy be broadened to include identification of the specific mechanisms that could be deployed to monitor progress and the metrics of success.
Further, it is recommended that the Federal Department of Health and Ageing consult with the state and territory agencies that are responsible for collecting and analysing smoking prevalence, smoking uptake and trend data. This should occur prior to part seven of the draft strategy being finalised, to ensure appropriate and comparable monitoring is possible over the life of the strategy.
Concluding RecommendationsCancer Council Queensland commends the work of the strategy authors and recommends the draft be amended to include explanatory statements about the position of the strategy in relation to other national strategies such as the National Health Reform Agreement.
The strategy would also be strengthened by the inclusion of evidence and specific emphasis on the social determinants of health and the role these factors play on uptake and maintenance of tobacco addiction. It is expected that any revisions in this regard may influence the articulation of various actions in the strategy, strengthening commitments in support of tobacco control.
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i National Preventative Health Taskforce. Australia: the healthiest country by 2020 - National Preventative Health Strategy Canberra2009; Available from: Preventative Health Taskforce website (part 3.7)
ii McPhedran, I. Diggers turning to smoking to fight off stress and boredom. The Daily Telegraph. June 22, 2012. Available from: Daily Telegraph website
iii World Health Organisation. Available from: World Health Organisation website
iv Baker A, Ivers RG, Bowman J, Butler T, Kay-Lambkin FJ, Wye P, et al. Where there's smoke, there's fire: high prevalence of smoking among some sub-populations and recommendations for intervention. Drug and Alcohol Review. 2006;25:85-96.
v Australian Government Department of Health and Ageing. Available from: Pharmaceutical Benefits Scheme website
viBatel P, Pessione F, Maitre C, Rueff B. Relationship between alcohol and tobacco dependencies. Addiction, 2006: 90: 977-980.
vii A. C. McFarlane, S. E. Hodson, M. Van Hooff & C. Davies (2011). Mental health in the Australian Defence Force: 2010 ADF Mental Health and Wellbeing Study: Full report, Department of Defence: Canberra. Available via: Department of Defence website
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