Quit Victoria and Cancer Council Victoria Submission: Draft for Consultation of the National Tobacco Strategy 2012 - 2018
June 25, 2012
Quit Victoria and Cancer Council Victoria Submission: Draft for Consultation of the National Tobacco Strategy 2012 – 2018
25th June 2012
Contents
Introduction
Part One – Overarching Issues
Part Two – Response to Part 6: Priority Areas and Actions
6.1 Strengthen social marketing campaigns to motivate smokers to quit; discourage uptake of smoking; and reshape social norms about smoking
6.2 Continue to reduce the affordability of tobacco products
6.3 Bolster and build on existing programs and partnerships to reduce smoking rates among Aboriginal and Torres Strait Islander (ATSI) people.
6.4 Strengthen efforts to reduce smoking among people in disadvantaged populations with high smoking prevalence
6.5 Eliminate remaining advertising, promotion and sponsorship of tobacco products
6.6 Consider further regulation of the contents, product disclosure and supply of tobacco products and non-therapeutic nicotine delivery systems
6.7 Reduce exceptions to smokefree workplaces, public places and other settings
6.8 Provide access to a range of evidence based cessation services to support smokers to quit
Part Three – Monitoring Progress
Introduction
Cancer Council Victoria and Quit Victoria welcome the opportunity to comment on the Draft National Tobacco Strategy 2012-2018. We believe the document represents a comprehensive evidence based approach to tobacco control that will guide the work necessary to be undertaken by government and non-government organisations if Australia is to reach its target of reducing adult smoking rates to 10 per cent or less and halving the Indigenous smoking rate by 2018.
Part 1 of our submission outlines overarching issues that apply to the strategy as a whole. This includes areas which we believe either need to be elevated in the final version of the National Tobacco Strategy (the Strategy) or issues which, while they may not be documented in the Strategy, should be considered when adopting and implementing the Strategy.
Part 2 are our comments on the eight priority areas outlined in the draft Strategy and the activities under each of these areas. Included in this section are references, some of which are more recent than those cited in the draft Strategy.
Part 3 includes our comments on monitoring progress.
Part One – Overarching Issues
a. Greater recognition of Australia’s obligations under the World Health Organisation Framework Convention on Tobacco Control (WHO FCTC)
The WHO FCTC is the first treaty negotiated under the auspices of the World Health Organization and is one of the most widely embraced treaties in UN history. The WHO FCTC is an evidence-based treaty that was developed in response to the globalisation of the tobacco epidemic. Its stated objective is to ‘protect present and future generations from the devastating health, social, environmental and economic consequences of tobacco consumption and exposure to tobacco smoke by providing a framework for tobacco control measures to be implemented by the Parties at the national, regional and international levels in order to reduce continually and substantially the prevalence of tobacco use and exposure to tobacco smoke.’
Australia signed the WHO FCTC on 5 December 2003, and became a full Party on 27 February 2005, the date on which it came into force. Australia is legally bound to perform, in good faith all of its obligations under the treaty including demand reduction provisions contained in articles 6-14, and supply reduction provisions contained in articles 15-17.
We do not believe that the significance of the FCTC or the importance of Australia’s obligations under the FCTC is sufficiently addressed in the current draft of the Strategy. Cancer Council Victoria and Quit Victoria suggest that an additional Objective be added to the Strategy which reads:
“to give effect to obligations that Australia has as a party to the WHO Framework Convention on Tobacco Control”
We note that the last paragraph on page 14 of the draft Strategy does not provide a full list of policies as outlined in the FCTC and if this section of the draft is to remain in the final Strategy it should be changed along the lines of the first two paragraphs above.
The introduction to the Priority Areas (5.4) in the draft Strategy should also highlight that the comprehensive approach to tobacco control taken in the Strategy is also consistent with the requirements of the WHO FCTC.
Lastly it is unclear whether Part Four ‘Progress and Future Challenges’ will remain in the final Strategy. If so, then Australia’s important role in negotiation of the FCTC and its ratification in 2005 should be included as significant achievements during the period of the last strategy 2004-2009.
b. Protecting the National Tobacco Strategy 2012–8 from tobacco industry interference in public health measures
Article 5.3 of the WHO FCTC requires Parties to act to protect their tobacco control policies from commercial and other vested interests of the tobacco industry.
In the draft Strategy there is simply a description of Article 5.3 on page 21 under section 5.7 with no comment on how the Strategy will address Australia’s obligations in relation to Article 5.3. The only other place Article 5.3 is mentioned is under Priority 6.5, action 6.5.10. Given that Article 5.3 applies to all tobacco control policies, we do not believe that the specific priority area regarding advertising, promotion and sponsorship is an appropriate place for actions under Article 5.3 to be located.
We believe that a description of Australia’s obligations under Article 5.3 and an explanation that these obligations apply to all tobacco control policies, and all levels of government, should form part of overarching principles of the Strategy (along with things such as working in partnership). In addition, reference should be made to the Guidelines for Article 5.3 that were adopted by the WHO FCTC Conference of the Parties and actions and responsibilities should be identified based on these guidelines. For example Principle 1 of the guidelines recognises that ‘there is a fundamental and irreconcilable conflict between the tobacco industry’s interests and public health policy interests’. Principle 2 of the guidelines recognises that ‘parties, when dealing with the tobacco industry or those working to further its interests, should be accountable and transparent’. If the current reference to Article 5.3 is to remain under the heading ‘The Framework’ then this would be the appropriate place for further detail on this issue to be contained in the Strategy.
c. Countering illicit trade claims made by the tobacco industry
Cancer Council Victoria and Quit Victoria are concerned about studies commissioned by the tobacco industry that report highly misleading and inflated levels of illicit trade activity in tobacco in Australia and have undertaken critiques of these reports which can be found at: Cancer Council Victoria website. The tobacco industry claims that increasing tobacco excise has already increased the use of illicit tobacco in Australia and measures such as the introduction of plain packaging of tobacco products will further increase this use. In sharp contrast to the claims made by the tobacco industry of 13.4% of the tobacco market in Australia being illicit tobacco, a more realistic estimate of the total use of illicit tobacco products in Australia based on analysis of figures from the National Drug Strategy Household Survey 2010 would be more like 2 to 3% of the total market.
We believe that the tobacco industry, both in Australia and internationally, is attempting to use the spectre of illicit trade to discourage governments from introducing proven tobacco control measures, to divert attention and resources away from proven tobacco control measures into costly anti-illicit trade activity and to re-position itself as ‘legitimate’ and ‘responsible’ .
We are concerned by claims from the tobacco industry that the Australian Government should be doing more to detect counterfeit tobacco products. Counterfeiting is an intellectual property issue (trade mark protection) that is primarily the responsibility of trade mark owners, in this case the tobacco industry. Government tobacco control resources should not be used in protection of the tobacco industry’s intellectual property.
d. Securing funding for the Strategy from all levels of government
While many of the activities outlined in the draft Strategy are low cost to implement, others require allocation of funding to make implementation possible.
Cancer Council Victoria and Quit Victoria believe it is essential that both the Australian government and State and Territory governments commit to providing funding for implementation of the strategy. Some activities will require federal funding, some will require state and territory funding and others will require both levels of government to commit funding in order to achieve the Strategy’s aims. For example it is very important that State governments continue to provide social marketing support to complement Commonwealth Government commitments to social marketing in the area of tobacco control. Without this support there is a danger the optimal levels of exposure to anti-smoking campaign messages amongst the public will not be achieved.
The National Partnership Agreement for Closing the Gap and other funding initiatives by both Commonwealth and State and Territory governments has represented a significant level of investment towards activity in reducing smoking rates among Aboriginal and Torres Strait Islander people. This funding has enabled a significant amount of work to be started such as supporting the development of Aboriginal health workforce, tailoring and promotion of mainstream cessation services to Aboriginal and Torres Strait Islander people to reduce smoking disparities and federally funded dedicated mass media advertising campaigns. However this funding currently expires in 2013 and this work cannot be continued or further developed without further Commonwealth, State and Territory government funding.
Cancer Council Victoria is pleased to see that the free on-line resource Tobacco In Australia: Facts and Issues has been acknowledged as a comprehensive and up to date resource on tobacco control evidence and policies. The website is incredibly well accessed and used (nearly 80,000 hits between January and May 2012), indicating it is invaluable in assisting all those working in tobacco control (policy makers, researchers, academics, health professionals, media). Funding for updating of this resource has now expired and we strongly urge an appropriate level of funding be allocated to ensure this resource remains up to date and its accuracy and utility maintained.
e. The importance of existing and new partnerships
Cancer Council Victoria and Quit Victoria are pleased to see the important role of partnerships in achieving past successes in Australia acknowledged and a commitment to continuing existing and building new partnerships emphasised in the draft Strategy.
A comprehensive Strategy such as that proposed can only be successfully implemented with all levels of government, non-government organisations and increasingly the health and community sector working together. Each of these groups have different jurisdictional responsibilities, skills, expertise and differing capacity to impact on populations identified in the Strategy.
Part Two – Response to Part 6: Priority Areas and Actions
6.1 Strengthen social marketing campaigns to motivate smokers to quit; discourage uptake of smoking; and reshape social norms about smoking
Quit Victoria recommends that the Strategy determine a clear definition of the term “social marketing” which Quit Victoria considers to refer to mass media advertising campaigns delivered through broadcast television, radio and digital media; print and press media, and outdoor and transit media mediums.
Within this range of advertising vehicles, Quit Victoria recommends that television campaigns targeted to smokers aged 18-49 years in low socio economic and blue collar occupations be prioritised within the National Tobacco Strategy over other advertising mediums.
Anti-smoking television campaigns remain one of three main interventions (with tobacco taxation and legislative reform) to reduce population smoking rates both in Australia and internationally.
In order to be effective an anti-smoking social marketing program should take a whole - of -population approach where campaigns are created and run to appeal to the widest possible group of smokers to ensure maximum return on investment.
A general-audience strategy where campaigns are produced to convey key messages likely to resonate with all, but not specific to any, population groups provides significantly more value than tailoring advertising message, settings and talent to multiple specific population sub-groups. The latter strategy would not be cost-effective, as it requires funding multiple campaigns to convey a variety of tailored messages or tailored versions of one message
A recent review summarised the impact of mass media campaigns on promoting quitting among adult smokers overall and for subgroups, the influence of campaign intensity and different channels; the effects of different message types.
The review[1] concluded that mass media campaigns to promote quitting are important investments as part of comprehensive tobacco control programmes to educate the broader public on the harms of smoking, set the agenda for discussion, change smoking attitudes and beliefs, increase quitting intentions and quit attempts, and reduce adult smoking prevalence. Jurisdictions should aim for high reach and consistent exposure over time with preference towards negative health effects messages.
It is very important that State governments continue to support social marketing to complement Commonwealth Government commitments to social marketing in the area of tobacco control. Without this support there is a danger the optimal levels of exposure to anti-smoking campaign messages amongst the public will not be achieved.
Actions
6.1.1 Run effective mass media campaigns at levels of reach and frequency demonstrated to reduce smoking.
Responsibility: Australian Government, State and Territory governments (as applicable), non-government organisations.
Recent research has also reinforced the need for repeated cycles of advertising to produce continuous, sustained exposure to anti-smoking messages. A study of Australian smokers found that although anti-smoking media campaigns increase the proportion of smokers who make a quit attempt (both for those who had an interest in quitting in the previous year and those who did not), this impact does not last beyond a few months following the conclusion of the campaign.[2]
This highlights the need for sustained and consistent television campaign exposure if we are to continue to motivate smokers to prioritise making a quit attempt now. It also raises considerable concerns over potential negative effects of any prolonged period of being ‘off-air.’
6.1.2 Continue mass media campaigns targeted to Aboriginal and Torres Strait Islander people including robust evaluation to inform future campaign strategies.
Responsibility: Australian Government, State and Territory governments, non-government organisations.
Please see comments made in relation 6.3.10
6.1.3 Continue to monitor the appropriateness and effectiveness of recommended media weights and mediums/channels.
Responsibility: Australian Government, State and Territory governments; non-government organisations.
A review of mass media campaigns internationally recently completed by the Centre for Behavioural Research in Cancer (CBRC) at the Cancer Council Victoria and published in the British Medical Journal’s Tobacco Control has concluded that a mean of 2,560 Gross Rating Points (GRPs) per quarter (850/mth) was significantly associated with quitting and could be expected to reap proportionally larger returns than 4,800 GRPs per year (400/mth) and that higher levels of exposure could be required to influence adult rather than youth smoking since adults are more hampered by addiction. [3]
Quit Victoria has recently sought advice from its media buying agency, Mitchell and Partners and the CBRC on how Quit’s target audience (low socio-economic smokers, 18-49 years) consume media but also respond to anti-smoking messages.
Information received from both sources confirms television remains the most effective medium to both reach the most smokers and provide an avenue to deliver impactful anti-smoking message most directly. There is substantial evidence that TV campaigns contribute to increased numbers of quit attempts and decreased smoking prevalence.
6.1.4 Continue to implement national tobacco campaigns and state and territory campaigns, including a balance of existing material with proven effectiveness and a suite of new materials.
Responsibility: Australian Government, State and Territory governments; non-government organisations
Cancer Council Victoria and Quit Victoria support the action with the inclusion of non-government organisations within responsibility.
Quit Victoria has worked collaboratively with the Department of Health and Ageing and Australian National Preventive Health Agency to ensure that scheduling of Victorian funded media campaigns complement the Commonwealth campaigns in both TARP levels of exposure and message content.
Quit Victoria remains in regular contact both Commonwealth and State government departments and agencies to ensure the messages communicated in social marketing campaigns are supportive of overarching strategies to reduce smoking rates. Quit Victoria is also in regular contact with other jurisdictions creating new anti-smoking social marketing campaigns to avoid duplication of, and create access to, new creative messages. This ensures all organisations conducting anti-smoking campaigns are working together to result in a broader variety of anti-smoking messages are reaching the public.
The choice of creative executions for Quit Victoria’s advertising program is a mix of graphic health effects, emotional campaigns and more recently positive campaigns, either produced in Victoria or sourced from other Australian and/or international jurisdictions.
Annual advertising plans include new creative executions and regular rotation of older messages to avoid wear out and fatigue of the anti-smoking message.
6.1.5 Enhance collaborative action between the Australian Government, State and Territory governments and non-government organisations to maximise the effectiveness of mass media campaigns.
Responsibility: Australian Government, State and Territory governments and non-government organisations.