Public Submission by Consumers Health Forum of Australia - Draft National Tobacco Strategy 2010 — 2018
Representing consumers on national health issues
Consumers Health Forum of Australia
21 June 2012
Draft NTS 2012
Healthcare Management Advisors PO Box 1311
Fitzroy North Vic 3068
Draft National Tobacco Strategy 2012-18
The Consumers Health Forum of Australia (CHF) welcomes the opportunity to provide a submission to the consultation on the Draft National Tobacco Strategy 2012-18 (the Draft Strategy).
CHF is the national peak body representing the interests of Australian healthcare consumers. CHF works to achieve safe, quality, timely healthcare for all Australians, supported by accessible health information and systems.
CHF welcomes any effort that aims to improve the health of Australians by decreasing their use of tobacco. We have provided numerous submissions in support of the Australian Government's tobacco plain packaging initiative, and are similarly supportive of the broader framework to reduce tobacco related harm set out in the Draft Strategy.
Overall CHF is supportive of the Draft Strategy. Brief comments are provided below on elements of the Draft Strategy that are particularly welcome, as well as on areas where we consider the Draft Strategy could be strengthened.
Welcome elements of the Draft Strategy
CHF welcomes several features of the Draft Strategy:
- The Draft Strategy is evidence-based. The priority areas and actions are based on a body of research and evaluation, taking into account where interventions can be most effectively targeted and what actions are likely to be most effective, based on past experience.
- The Draft Strategy recognises higher rates of smoking, and barriers to smoking cessation, faced by certain demographic groups. It contains actions that are targeted at Aboriginal and Torres Strait Islanders, people from low socioeconomic groups, people experiencing mental illness, and prisoners. Actions that aim to ensure that these groups can access support for smoking cessation at an affordable cost (including subsidised medicines and nicotine replacement, and evidence-based cessation services).
- The Draft Strategy recognises the importance of working in partnership. There is recognition that key roles will be played by governments, non-government organisations, social service organisations and others, particularly in targeting the needs of disadvantaged groups. CHF particularly welcomes the recognition that smoking reduction initiatives targeted at Aboriginal and Torres Strait Islander people need to be community-led and involve partnerships with community controlled organisations.
- The Draft Strategy includes ongoing monitoring. Outcome indicators are defined, and the importance of monitoring and surveillance, particularly in addressing current evidence gaps, is clearly stated. CHF strongly supports the focus on evaluation and monitoring in the Draft Strategy, as this will provide insights into whether the Strategy is meeting its objectives as well as informing future initiatives.
Strengthening the Draft Strategy
While CHF supports the Draft Strategy, we have identified some areas where it could be strengthened or clarified, drawing on some of the recommendations of the Preventative Health Taskforce relating to tobacco.
- Increases in tobacco excise: The Preventative Health Taskforce recommended a 68 percent increase in excise on tobacco products. The Government raised the excise on tobacco products by 25 percent in April 2010, but in its response to the Preventative Health Taskforce recommendation advised that it did not intend to pursue the full 68 percent increase.
- Tax and duty free sales: The Preventative Health Taskforce recommended that tax and duty concessions on tobacco products for travellers entering Australia be abolished. This was also a recommendation of the Henry Review of Australia's tax system. In the Government's response to the Preventative Health Taskforce, it stated that it would consider this recommendation further. Action 6.2.10 of the Draft Strategy is Keep under review the possibility of reducing duty-free sales of tobacco. While CHF commends the Government's recent moves in the 2012-13 Budget to reduce the duty free allowance to 50 cigarettes or 50 grains of tobacco, we would welcome a commitment to further reducing or abolishing duty free allowances for tobacco products.
- Specificity of actions: CHF notes that some of the actions outlined in the Draft Strategy (eg 6.5.4, 6.5.5, 6.5.8, 6.6.3, 6.6.7, 6.7.8) refer to 'investigation' or 'consideration' of policy or regulatory options. Given the Strategy covers a six-year period, CHF considers that these actions should also refer to implementing policy or regulatory options that have been identified as appropriate.
CHF appreciates the opportunity to provide comments on the Draft Strategy, and welcomes efforts to reduce the burden on the health system resulting from tobacco use. We look forward to reviewing the final version of the Strategy.
If you would like to discuss the issues raised in this letter in more detail, please contact CHF Senior Policy Manager, Ms Anna Greenwood.
Chief Executive Officer
PO Box 3099. Manuka ACT 2603
Unit 10, 11 National Circuit, Barton ACT 2600
Tel: (02) 6273 5444
Fax: (02) 6273 5888
Email: Info at Consumers Health Forum of Australia
For more information please visit : Consumers Health Forum of Australia Website
ABN 59 369 286 137
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