COMMENTS BY THE WESTERN CAPE DEPARTMENT OF HEALTH ON THE TOBACCO PRODUCTS CONTROL AMENDMENT BILL

The Health Department of the Western Cape Province supports the Bill and believes that the acceptance thereof will contribute significantly, not only to the saving of lives from tobacco related deaths, but also to the improvement of health of generations to come.

The World Health Assembly stated (1996) that tobacco products are estimated to have caused around 3 million deaths a year in the early 1990's and that, if current smoking trends are not reversed, that figure is expected to rise to 10 million deaths per year by the 2020's or early 2030's, with 70% of those deaths occurring in developing countries.

A leading public health textbook quotes US Surgeon General Reports since 1964 which identify cigarette smoking as the single most significant preventable source of morbidity and premature mortality. Health problems include chronic obstructive airways disease, coronary heart disease, peripheral vascular disease, strokes, lung cancer, laryngeal cancer, oral cancer, oesophageal cancer, bladder cancer, peptic ulcers, intrauterine growth retardation etc. During a study in South Africa by Metcalf and Yach in 1991 already, it was reported that smoking is a major cause of death in developed sectors of the population.

The World Health Assembly has adopted 14 resolutions from 1970 to 1995 which strongly urge Member States to implement comprehensive tobacco control measures.

The World Bank, at the 10th World Conference on Tobacco, held in China in 1997, stated, "Tobacco use causes profound health and economic losses. Controlling it should be efficient and cost effective and governments must lead those controls by aggressively adopting fiscal and regulatory policies"

PUBLIC PLACES AND PASSIVE SMOKING
Over the past years a change has taken place in the status of passive smoking. It is no longer seen as a necessary "inconvenience" of social life but as a public health problem.

Social attitudes with regard to smoking have also changed. It is realised that the smoker is not only endangering his/her o life but also that of others. The consequences of smoking are, therefore, no longer of purely individual nature but also collective and the social acceptability of smoking is being strongly called into question as a result. This is demonstrated by increasing public demand for restrictions on smoking in public places.

Passive smoking has in 1993 been estimated by the United States Environmental Protection Agency (EAP) to cause 3 000 lung cancer deaths every year in the United States. A total of 30 epidemiologic studies conducted worldwide were included in the EPA study.

In a recent study it was reported that passive smoking is a major threat to public health in Europe and that it is responsible for the death of over 22 000 people each year in the European Union. Governments of the European Union were strongly urged to take comprehensive measures to protect non-smokers.

Over 4 000 constituents have been identified in tobacco smoke of which at least 43 are known to cause cancer in humans. Side stream smoke contains ammonia, carbon monoxide and nicotine per milligram burned than does mainstream smoke.

Health consequences of environmental tobacco smoke
The US Surgeon General's Report as early as 1986 on the health consequences of involuntary smoking concluded that "Involuntary smoking is a cause of disease, including lung cancer, in healthy non-smokers.

There is a significant association between the prevalence of childhood respiratory disease and parental smoking habits including pneumonia, bronchitis, asthma and hospitalisation.

Among adults, although lung cancer is one of the most widely studied of all the diseases associated with ETS there are also effects in terms of irritation and discomfort to eyes, nose, upper and lower respiratory tract, particularly in persons with a history of bronchitis or sinusitis. ETS has a negative effect on at least a proportion of asthmatics and persons suffering from angina.

Although it was more difficult in the past to link ETS to cardio-vascular diseases, several epidemiological studies in recent years strongly suggest that the increased risk of death by ischemic heart disease or heart attack is approximately 20% to 30% for the non-smoking partner of a smoker. This risk is often even higher in the workplace due to greater density of smokers.

The workplace is one of the main sources of involuntary exposure to environmental tobacco smoke (ETS). I have personally had many telephone calls over the past 5 years of workers that experience problems with ETS at their places of employment. Many of these were desperate and were looking for assistance from the Act (Tobacco Products Control Act, 1993) to strengthen their hand in bringing about change in an unpleasant work environment. The Tobacco Products Control Amendment Bill provides that 'clout' and will be welcomed by many in this respect (sections 2 and 3). The inclusion of workplace under the definition of public place is supported.

ADVERTISING
There has been worldwide concern in recent years of the impact of tobacco advertising on cigarette consumption, particularly among women, children and minority groups. Yach and Paterson, in a study on tobacco advertising expenditure in South African media, came to the conclusion that tobacco advertising through radio and outdoor advertising reaches children and illiterate communities in peri-urban and rural areas. Tobacco advertising in magazines targets specific consumers, amongst others women.

By 1995 twenty seven countries had already instituted a total ban on cigarette advertising.(6). These include Finland, Norway, Italy, Portugal, Spain, Mozambique, Algeria, Singapore etc.

At the 10th World Conference on Tobacco held in China in 1997 the World Bank presented some key recommendations to client governments. One of these were:
"Implement complete bans on tobacco advertising and promotion of tobacco goods, trade marks, or logos"

Although total banning of tobacco advertising is a highly controversial issue, experience in the United States showed that partial banning of such advertising was less effective than first envisioned. For example, tobacco advertisements were banned from radio and Television in the United States in the early 1970's. Later analysis showed however that total tobacco advertising volume and expenditure continued to increase. It was found that advertising placements were simply transferred to other media.

It needs to be recognized that companies in the tobacco industry has an obligation to their shareholders: to make more profits by selling more tobacco products and advertising is the front line in this regard.

CHILDREN AND ADVERTISING
In a report from the European Bureau for Action on Smoking Prevention it is stated that:
- 44% of all adolescents either experiment with or regularly use tobacco products;
- Children as young as 6 years have been shown to identify cigarette advertisements reliably;
- Children have a higher awareness of tobacco advertising than adults;
- Tobacco advertising shows positive and glamorous images, increasingly directed towards and attractive to young children and women;
- More than 90% of all smokers begin to smoke as teenagers.
The last mentioned is supported by a study undertaken under Cape Peninsula high school students during 1992.

If only 10% of current smokers began as adults it can therefor be argued that adolescents are the group from which most new smokers are recruited.

The report goes further to say that while one of the arguments of the tobacco industry' is that advertising only influences adult smokers to change the brand they smoke, in a given year only about 2 % of smokers switch from one brand to another. Thus brand switching alone does not justify the enormous amounts spent on advertising.

A report titled: "Health or Tobacco: an end to tobacco advertising and promotion" covers data from 18 countries showing that legislation banning tobacco promotion does have the effect of reducing the number of young people who take up smoking.

Yach and Mackay comment about the South African situation that:
"The ban on sales to children has not been enforced in South Africa, the provision of warnings on advertisements has resulted in tobacco industry marketers shifting their investments into other promotional activities. Globally it has been shown that simple measures against advertising only lead to an increase in indirect advertising and sponsorship. There is therefor a need for total, comprehensive bans on all tobacco promotion."

Tobacco advertising is essentially incompatible with any policy that seriously seeks to reduce tobacco use in any community. Any effort by any government to reduce smoking and the diseases caused by it is directly counteracted by tobacco advertising. In this regard sections 4 and 7 of the Bill pertaining to advertising are supported.

Other matters
The increased power given to local authorities to make and enforce bylaws (S3) is supported.
The prescription of maximum levels of tar and nicotine (S5) is supported.
The tightening up of not selling cigarettes to under 16s (S6) is supported as is the limitation of places where vending machines may be operated (S8).