public health specialists write to WHO about alternatives to smoking – here’s the letter
Here below is the text of the letter sent to WHO this week, and full list of signatories (as a PDF here). Coming soon – a reader’s guide to the letter.
Statement from specialists in nicotine science and public health policy
Dr Margaret Chan
World Health Organisation
CC: FCTC Secretariat, Parties to the FCTC, WHO Regional Offices
26 May 2014
Dear Dr Chan
Reducing the toll of death and disease from tobacco – tobacco harm reduction and the Framework Convention on Tobacco Control (FCTC)
We are writing in advance of important negotiations on tobacco policy later in the year at the FCTC Sixth Conference of the Parties. The work of WHO and the FCTC remains vital in reducing the intolerable toll of cancer, cardiovascular disease and respiratory illnesses caused by tobacco use. As WHO has stated, up to one billion preventable tobacco-related premature deaths are possible in the 21st Century. Such a toll of death, disease and misery demands that we are relentless in our search for all possible practical, ethical and lawful ways to reduce this burden.
It is with concern therefore that a critical strategy appears to have been overlooked or even purposefully marginalised in preparations for FCTC COP-6. We refer to ‘tobacco harm reduction’ – the idea that the 1.3 billion people who currently smoke could do much less harm to their health if they consumed nicotine in low-risk, non-combustible form.
We have known for years that people ‘smoke for the nicotine, but die from the smoke’: the vast majority of the death and disease attributable to tobacco arises from inhalation of tar particles and toxic gases drawn into the lungs. There are now rapid developments in nicotine-based products that can effectively substitute for cigarettes but with very low risks. These include for example, e-cigarettes and other vapour products, low-nitrosamine smokeless tobacco such as snus, and other low-risk non-combustible nicotine or tobacco products that may become viable alternatives to smoking in the future. Taken together, these tobacco harm reduction products could play a significant role in meeting the 2025 UN non-communicable disease (NCD) objectives by driving down smoking prevalence and cigarette consumption. Indeed, it is hard to imagine major reductions in tobacco-related NCDs without the contribution of tobacco harm reduction. Even though most of us would prefer people to quit smoking and using nicotine altogether, experience suggests that many smokers cannot or choose not to give up nicotine and will continue to smoke if there is no safer alternative available that is acceptable to them.
We respectfully suggest that the following principles should underpin the public health approach to tobacco harm reduction, with global leadership from WHO:
1. Tobacco harm reduction is part of the solution, not part of the problem. It could make a significant contribution to reducing the global burden of non-communicable diseases caused by smoking, and do so much faster than conventional strategies. If regulators treat low-risk nicotine products as traditional tobacco products and seek to reduce their use without recognising their potential as low-risk alternatives to smoking, they are improperly defining them as part of the problem.
2. Tobacco harm reduction policies should be evidence-based and proportionate to risk, and give due weight to the significant reductions in risk that are achieved when a smoker switches to a low risk nicotine product. Regulation should be proportionate and balanced to exploit the considerable health opportunities, while managing residual risks. The architecture of the FCTC is not currently well suited to this purpose.
3. On a precautionary basis, regulators should avoid support for measures that could have the perverse effect of prolonging cigarette consumption. Policies that are excessively restrictive or burdensome on lower risk products can have the unintended consequence of protecting cigarettes from competition from less hazardous alternatives, and cause harm as a result. Every policy related to low risk, non-combustible nicotine products should be assessed for this risk.
4. Targets and indicators for reduction of tobacco consumption should be aligned with the ultimate goal of reducing disease and premature death, not nicotine use per se, and therefore focus primarily on reducing smoking. In designing targets for the non-communicable disease (NCD) framework or emerging Sustainable Development Goals it would be counterproductive and potentially harmful to include reduction of low-risk nicotine products, such as e-cigarettes, within these targets: instead these products should have an important role in meeting the targets.
5. Tobacco harm reduction is strongly consistent with good public health policy and practice and it would be unethical and harmful to inhibit the option to switch to tobacco harm reduction products. As the WHO’s Ottawa Charter states: “Health promotion is the process of enabling people to increase control over, and to improve, their health”. Tobacco harm reduction allows people to control the risk associated with taking nicotine and to reduce it down to very low or negligible levels.
6. It is counterproductive to ban the advertising of e-cigarettes and other low risk alternatives to smoking. The case for banning tobacco advertising rests on the great harm that smoking causes, but no such argument applies to e-cigarettes, for example, which are far more likely to reduce harm by reducing smoking. Controls on advertising to non-smokers, and particularly to young people are certainly justified, but a total ban would have many negative effects, including protection of the cigarette market and implicit support for tobacco companies. It is possible to target advertising at existing smokers where the benefits are potentially huge and the risks minimal. It is inappropriate to apply Article 13 of the FCTC (Tobacco advertising, promotion and sponsorship) to these products.
7. It is inappropriate to apply legislation designed to protect bystanders or workers from tobacco smoke to vapour products. There is no evidence at present of material risk to health from vapour emitted from e-cigarettes. Decisions on whether it is permitted or banned in a particular space should rest with the owners or operators of public spaces, who can take a wide range of factors into account. Article 8 of the FCTC (Protection from exposure to tobacco smoke) should not be applied to these products at this time.
8. The tax regime for nicotine products should reflect risk and be organised to create incentives for users to switch from smoking to low risk harm reduction products. Excessive taxation of low risk products relative to combustible tobacco deters smokers from switching and will cause more smoking and harm than there otherwise would be.
9. WHO and national governments should take a dispassionate view of scientific arguments, and not accept or promote flawed media or activist misinterpretations of data. For example, much has been made of ‘gateway effects’, in which use of low-risk products would, it is claimed, lead to use of high-risk smoked products. We are unaware of any credible evidence that supports this conjecture. Indeed, similar arguments have been made about the use of smokeless tobacco in Scandinavia but the evidence is now clear that this product has made a significant contribution to reducing both smoking rates and tobacco-related disease, particularly among males.
10. WHO and parties to the FCTC need credible objective scientific and policy assessments with an international perspective. The WHO Study Group on Tobacco Product Regulation (TobReg) produced a series of high quality expert reports between 2005 and 2010. This committee should be constituted with world-class experts and tasked to provide further high-grade independent advice to the WHO and Parties on the issues raised above.
The potential for tobacco harm reduction products to reduce the burden of smoking related disease is very large, and these products could be among the most significant health innovations of the 21st Century – perhaps saving hundreds of millions of lives. The urge to control and suppress them as tobacco products should be resisted and instead regulation that is fit for purpose and designed to realise the potential should be championed by WHO. We are deeply concerned that the classification of these products as tobacco and their inclusion in the FCTC will do more harm than good, and obstruct efforts to meet the targets to reduce non-communicable disease we are all committed to. We hope that under your leadership, the WHO and FCTC will be in the vanguard of science-based, effective and ethical tobacco policy, embracing tobacco harm reduction.
We would be grateful for your considered reaction to these proposals, and we would like to request a meeting with you and relevant staff and a small delegation of signatories to this letter. This statement and any related information will be available on the Nicotine Science and Policy web site (http://nicotinepolicy.net) from 29 May 2014.
Signatories this statement at 26 May 2014Professor David Abrams Professor of Health Behavior and Society. The Johns Hopkins Bloomberg School of Public Health. Maryland. USA. Professor of Oncology (adjunct). Georgetown University Medical Center, Lombardi Comprehensive Cancer Center. Washington DC. United States of America Professor Tony Axéll Emeritus Professor Geriatric Dentistry Consultant in Oral Medicine Sweden Professor Pierre Bartsch Respiratory physician, Faculty of Medicine University of Liège Belgium Professor Linda Bauld Professor of Health Policy Director of the Institute for Social Marketing Deputy Director, UK Centre for Tobacco and Alcohol Studies University of Stirling United Kingdom Professor Ron Borland Nigel Gray Distinguished Fellow in Cancer Prevention at Cancer Council Victoria Professorial Fellow School of Population Health and Department of Information Systems University of Melbourne, Australia Professor John Britton Professor of Epidemiology; Director, UK Centre for Tobacco & Alcohol Studies, Faculty of Medicine & Health Sciences University of Nottingham, United Kingdom Associate Professor Chris Bullen Director, National Institute for Health Innovation School of Population Health, University of Auckland, New Zealand Professor Emeritus André Castonguay Faculty of Pharmacy Université Laval, Quebec, Dr Lynne Dawkins Senior Lecturer in Psychology, Co-ordinator: Drugs and Addictive Behaviours Research Group School of Psychology, University of East London, United Kingdom Professor Ernest Drucker Professor Emeritus Department of Family and Social Medicine, Montefiore Medical Center/Albert Einstein College of Medicine Mailman School of Public Health Columbia University United States of America Professor Jean François Etter Associate Professor Institut de santé globale, Faculté de médecine, Université de Genève, Switzerland Dr Karl Fagerström President, Fagerström Consulting AB, Vaxholm, Sweden Dr Konstantinos Farsalinos Researcher, Onassis Cardiac Surgery Center, Athens, Greece Researcher, University Hospital Gathuisberg, Leuven, Belgium Professor Antoine Flahault Directeur de l’Institut de Santé Globale Faculté de Médecine, Université de Genève, Suisse/ Institute of Global Health, University of Geneva, Switzerland Professor of Public Health at the Faculté de Médecine, Université Paris Descartes, Sorbonne Paris Cité, France Dr Coral Gartner Senior Research Fellow University of Queensland Centre for Clinical Research The University of Queensland, Australia Dr Guillermo González Psychiatrist Comisión de Rehabilitación en Enfermedad Mental Grave Clínica San Miguel Madrid, Spain Dr Nigel Gray Member of Special Advisory Committee on Tobacco Regulation of the World Health Organization Honorary Senior Associate Cancer Council Victoria Australia Professor Peter Hajek Professor of Clinical Psychology and Director, Health and Lifestyle Research Unit UK Centre for Tobacco and Alcohol Studies Wolfson Institute of Preventive Medicine, Barts and The London School of Medicine and Dentistry Queen Mary University of London, United Kingdom Professor Wayne Hall Director and Inaugural Chair, Centre for Youth Substance Abuse Research University of Queensland Australia Professor John Hughes Professor of Psychology, Psychiatry and Family Practice University of Vermont United States of America Professor Martin Jarvis Emeritus Professor of Health Psychology Department of Epidemiology & Public Health University College London, United Kingdom Professor Didier Jayle Professeur d’addictologie Conservatoire National des Arts et Métiers Paris, France Dr Martin Juneau Directeur, Direction de la Prévention Institut de Cardiologie de Montréal Professeur Titulaire de Clinique Faculté de Médecine, Université de Montréal, Canada Dr Michel Kazatchkine Member of the Global Commission on Drug Policy Senior fellow, Global Health Program, Graduate institute, Geneva, Switzerland Professor Demetrios Kouretas School of Health Sciences and Vice Rector University of Thessaly, Greece Professor Lynn Kozlowski Dean, School of Public Health and Health Professions, Professor of Community Health and Health Behavior, University at Buffalo, State University of New York, United States of America Professor Eva Králíková Institute of Hygiene and Epidemiology Centre for Tobacco-Dependence First Faculty of Medicine Charles University in Prague and General University Hospital in Prague, Czech Republic Professor Michael Kunze Head of the Institute for Social Medicine Medical University of Vienna, Austria Dr Murray Laugesen Director Health New Zealand, Lyttelton, Christchurch, New Zealand Dr Jacques Le Houezec Consultant in Public Health, Tobacco dependence, Rennes, France Honorary Lecturer, UK Centre for Tobacco Control Studies, University of Nottingham, United Kingdom Dr Kgosi Letlape President of the Africa Medical Association Former President of the World Medical Association Former Chairman of Council of the South African Medical Association South Africa Dr Karl Erik Lund Research director Norwegian Institute for Alcohol and Drug Research, Oslo, Norway Dr Gérard Mathern Président de l’Institut Rhône-Alpes de Tabacologie Saint-Chamond, France Professor Richard Mattick NHMRC Principal Research Fellow Immediate Past Director NDARC (2001-2009) National Drug and Alcohol Research Centre (NDARC) Faculty of Medicine The University of New South Wales, Australia Professor Ann McNeill Professor of Tobacco Addiction Deputy Director, UK Centre for Tobacco and Alcohol Studies National Addiction Centre Institute of Psychiatry King’s College London, United Kingdom Dr Hayden McRobbie Reader in Public Health Interventions, Wolfson Institute of Preventive Medicine, Queen Mary University of London, United Kingdom Dr Anders Milton Former President of the Swedish Red Cross Former President and Secretary of the Swedish Medical Association Former Chairman of the World Medical Association Owner & Principal Milton Consulting, Sweden Professor Marcus Munafò Professor of Biological Psychology MRC Integrative Epidemiology Unit at the University of Bristol UK Centre for Tobacco and Alcohol Studies School of Experimental Psychology University of Bristol, United Kingdom Professor David Nutt Chair of the Independent Scientific Committee on Drugs (UK) Edmund J Safra Professor of Neuropsychopharmacology Head of the Department of Neuropsychopharmacology and Molecular Imaging Imperial College London, United Kingdom Dr Gaston Ostiguy Professeur agrégé Directeur de la Clinique de cessation tabagique Centre universitaire de santé McGill (CUSM) Institut thoracique de Montréal, Canada Professor Riccardo Polosa Director of the Institute for Internal Medicine and Clinical Immunology, University of Catania, Italy. Dr Lars Ramström Director Institute for Tobacco Studies Täby, Sweden Dr Martin Raw Special Lecturer UK Centre for Tobacco and Alcohol Studies Division of Epidemiology and Public Health University of Nottingham, United Kingdom Professor Andrzej Sobczak Department of General and Inorganic Chemistry, Faculty of Pharmacy and Laboratory Medicine, Medical University of Silesia, Katowice, Poland Institute of Occupational Medicine and Environmental Health Sosnowiec, Poland Professor Gerry Stimson Emeritus Professor, Imperial College London; Visiting Professor, London School of Hygiene and Tropical Medicine United Kingdom Professor Tim Stockwell Director, Centre for Addictions Research of BC Professor, Department of Psychology University of Victoria, British Columbia, Canada Professor David Sweanor Adjunct Professor, Faculty of Law, University of Ottawa Special Lecturer, Division of Epidemiology and Public Health, University of Nottingham, United Kingdom Professor Umberto Tirelli Director Department of Medical Oncology National Cancer Institute of Aviano Italy Professor Umberto Veronesi Scientific Director IEO Istituto Europeo di Oncologia Former Minister of Health, Italy Professor Kenneth Warner Avedis Donabedian Distinguished University Professor of Public Health Professor, Health Management & Policy School of Public Health University of Michigan United States of America Professor Robert West Professor of Health Psychology and Director of Tobacco Studies Health Behaviour Research Centre, Department of Epidemiology & Public Health, University College London United Kingdom Professor Dan Xiao Director of Department Epidemiology WHO Collaborating Center for Tobacco or Health Beijing Institute of Respiratory Medicine, Beijing Chao-Yang Hospital, China Dr Derek Yach Former Executive Director, Non-Communicable Diseases Former Head of Tobacco Free Initiative, World Health Organisation (1995-2004) Senior Vice President Vitality Group plc Director, Vitality Institute for Health Promotion United States of America