LINKED ON WHO WEBSITE

From:    Jeff Stier, Consumer Choice Center (NGO)

To:         WHO Independent High-level Commission

Date:   13 May, 2018

Re:      Comments on Draft Report

The Consumer Choice Center shares the sentiment of the draft report of the WHO INDEPENDENT HIGH-LEVEL COMMISSION ON NON-COMMUNICABLE DISEASES that “a fresh working relationship must be established” with a wide range of industries to promote health and behavior change.

We believe that the best way to promote health is to recognize the role of individual choices made by consumers and foster robust private sector activity that makes it easier for consumers to make better choices. Advances in public health require partnership between the private and public sector. History shows that improvements in public health are driven by innovation in a wide range of sectors. As such, while a positive and collaborative working relationship must be established with industries including food, non-alcoholic beverages and restaurants, all industries must be treated as allies, employing their knowledge and incentive for profit to promote health. 

For instance, innovation in the alcohol industry has the potential to lower mortality related to alcohol abuse. But despite scientific advances making this possible, industry has yet to embrace the approach. As Dr. David Nutt, professor of neuropsychopharmacology at Imperial College London, and the chair of DrugScience.org.uk wrote in The Guardian in 2013,  “before we can sober up in minutes, the drinks industry needs to embrace this healthier approach.” 

While abstinence is the safest approach, the public health community should also embrace lower-risk options for those who do not abstain. 

The commission is well-aware of the public health gains achieved from the application of harm-reduction in areas including clean needle exchange and condom use. 

The draft report properly points to another area where gains should and must be made given the disease and death caused by smoking. However, the report strikingly fails to distinguish between different forms of tobacco use. Indeed, the type of tobacco use responsible for the vast majority of the harm caused by tobacco is not even mentioned once in the draft report.  The report does not use the word “smoking” or “cigarettes” even once.

The draft report should be revised to recognize the difference in risk between non-combustible tobacco products and the deadly cigarette. The astounding fact that the rate of cigarette smoking in Sweden, where snus is often used instead of cigarettes, is down below 5 percent, and tobacco-related diseases are correspondingly low, should be a wakeup call to those who are resistant to recognizing the promise of tobacco harm reduction. 

Noncombustible tobacco, e-cigarettes, and other forms of nicotine delivery that can replace the combustible cigarette for those who are otherwise unable or unwilling to quit using nicotine should be seen as allies, not threats, to public health.  Consumers should understand that these products should be used exclusively by smokers, and despite their significant lower-risk profile as compared to cigarettes, are still not free of risk.

Regulations, taxes, and public awareness campaigns must all recognize the difference in risk between different products, recognizing that the most important difference between products is whether or not the product delivers nicotine through combustion.

Gains in this area will require that government agencies, public health organizations, and industry put aside their differences to focus on helping consumers reduce the harm they cause themselves and others when they smoke cigarettes.

 Finally, it is important to note that consumers, the very public that the public health community seeks to help, are often left out of policy discussions that affect them, and require their engagement.

We believe that when making lifestyle choices, consumers make decisions based on a number of individual factors, one of which includes what is best for their own health. But a wise choice for one individual may be an unrealistic choice for another. As such, we believe that consumers are best-positioned to make decisions about their own health and the choices they make.

We believe that consumers, and public health as a whole, will benefit when industry is incentivized to innovate, giving consumers more choices to make decisions that are in their best interest.

Sincerely,

Jeff Stier

Senior Fellow

Consumer Choice Center

Washington, DC