Sep 3, 2015 - forefront of developing and expanding the public health workforce and ... to the Department of Health's co
Faculty of Public Health Of the Royal Colleges of Physicians of the United Kingdom Working to improve the public’s health
Department of Health Tobacco Control Team 3 September 2015 UK Faculty of Public Health response to the Department of Health’s consultation on the Tobacco Products Directive About the UK Faculty of Public Health The UK Faculty of Public Health (FPH) is committed to improving and protecting people’s mental and physical health and wellbeing. FPH is a joint faculty of the three Royal Colleges of Public Health Physicians of the United Kingdom (London, Edinburgh and Glasgow). Our vision is for better health for all, where people are able to achieve their fullest potential for a healthy, fulfilling life through a fair and equitable society. We work to promote understanding and to drive improvements in public health policy and practice. As the leading professional body for public health specialists in the UK, our members are trained to the highest possible standards of public health competence and practice – as set by FPH. With 3,300 members based in the UK and internationally, we work to develop knowledge and understanding, and to promote excellence in the field of public health. For more than 40 years we have been at the forefront of developing and expanding the public health workforce and profession. Consultation response The UK Faculty of Public Health (FPH) is pleased to largely support the excellent and comprehensive response submitted to the Department of Health’s consultation on the Tobacco Products Directive by Action on Smoking and Health. FPH, in our own submission, has some caveats to the ASH submission, as follows: Q. 13: For the reasons outlined within FPH’s existing Policy Statement on Electronic Cigarettes, FPH would prohibit cross-border distance sales of e-cigarettes and refills to consumers. Q. 18: FPH considers electronic notification of electronic cigarettes and nicotine containers to be an acceptable approach. In regard to matters of commercial confidentiality, we would recommend an approach based on placing the burden of proof on the party making the notification to show that requested information should properly be considered confidential. This could be supplemented by appropriate online guidance. Q. 19: The electronic cigarette market is still at a relatively early stage of development, and particular products or the product type as whole could in future be shown to cause health damage or significant risks to some or all users. Therefore it is important that any information about suspected adverse health effects is collected and appropriately communicated. To ensure that manufacturers and producers do this, FPH would support a legal requirement on them to designate a person in the UK as having individual responsibility in this area. Q. 21: FPH broadly supports the following principles:
Regulation of un-licenced electronic cigarettes and other nicotine containing products , unlicensed products should be subject to the same comprehensive and binding marketing controls as tobacco products so that they cannot be marketed or advertised 1
Electronic cigarettes and other nicotine containing products should not be advertised or promoted in ways that could reasonably be expected to promote smoking of tobacco products. Electronic cigarettes and other nicotine containing products should not be advertised in ways or through channels that could reasonably be expected to make them appealing to nontobacco users Electronic cigarettes and other nicotine containing products should not be advertised in ways or through channels that could reasonably be expected to make them appealing to children and young people marketing controls should extend to bans on the sponsorship of sports clubs or sporting events, any events targeting young people, product placement, use of flavours designed to appeal to youth and celebrity spokespersons – no advertising or use should ‘re-normalise‘ or ‘re-glamourise‘ smoking and undermine smoking prevention policies all products, whether licenced as medicines or consumer products, should be required to carry a health warning clearly indicating the addictive nature of nicotine and detailing ingredients and their safety, and also encourage smoking cessation, with links to the NHS Smokefree website outlets selling electronic cigarettes should provide information on the dangers of smoking, the addictive nature of nicotine and encourage cessation until further information is available on effectiveness as a quit product, smokers should be informed that the most effective means of quitting is via the NHS stop smoking service celebrity endorsement or free samples, both of which are prohibited under rules for over the counter medicinal products such as licenced nicotine products, should be prohibited
FPH draws the Department of Health’s attention to our existing policy statement on electronic cigarettes, which you can read at the following link: http://bit.ly/1lz8M0i
For further information, please contact Mark Weiss, Senior Policy Officer UK Faculty of Public Health at:
[email protected] or on 0203 696 1479.
4 St Andrews Place
London NW1 4LB Tel: 020 3696 1479 Email:
[email protected] www.fph.org.uk Registered Charity No: 263894
Website:
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