National
Council Against Smoking Submission
SUMMARY
Tobacco is a
uniquely dangerous consumer product. It is the only legal product that kills
the user when used exactly as the manufacturer intends. In South Africa tobacco kills one person every 20 minutes or about 30 000 people a year.
Tobacco use is bad for business too - it makes workers sick, so reducing
productivity in al sectors of the economy. Tobacco also keeps poor people poor.
South Africa's tobacco control policies have been successful in reducing tobacco
consumption. Fewer adults and youth are smoking cigarettes. However, the
Tobacco Products Control Act, 1993 (as amended) needs strengthening in several
crucial areas.
The purpose of the Bill is to ensure that young "people don't start
smoking, to protect non-smokers from pollution by tobacco smoke, to help
smokers quit and to reduce the risks for those who continue to smoke.
The NCAS is especially supportive of the Bill's increased requirements
regarding smoking in public places. The Bill seeks to better protect children
from passive smoking and seeks to guarantee workers their constitutional right
to an environment that is not harmful to their health.
The changes proposed to Section 2 of the Act include:
1. Restricting smoking near air inlets and entrances to public places. Many
people now smoke near entrances and exits to buildings as an unintended
consequence of the current law. As a result, high concentrations of tobacco
smoke can be found near doorways through which the public must pass, and smoke
enters buildings via general airflow. This can be particularly problematic for
those with asthma or heart conditions, for whom even short exposures to smoke
can trigger an attack.
2. The Bill seeks to protect children in two ways. It proposes not allowing
smoking in private homes used commercially for childcare or educational
purposes. It also proposes not allowing minors into the areas set aside for
smoking. Young children are especially vulnerable to second-hand smoke because
they breathe more air relative to body weight than adults and so absorb more
tobacco smoke toxins. They are also less able to complain or remove themselves
from smoke-filled rooms.
3. Most people do not want to be exposed to tobacco smoke. However, many are
afraid to assert their right to smoke-free air in the workplace because of the
fear of upsetting their employers. The Bill proposes making it possible for
people to safely voice their concerns without fear of repercussions. The Bill
also requires employers to respect an employee's right not to be forced to work
in a smoking section. People should not be required to endanger their health
for the opportunity to work.
4. Section 2(3) allows the Minister to prohibit smoking in certain outdoor
areas, where smoking may constitute a fire or other risk. In crowded sports
stadia exposure to tobacco smoke is likely to be sustained (from a few hours to
the whole day for cricket lovers) and significant. Vulnerable people, who are
very sensitive to smoke, can have their health put at risk.
There are two issues on which the Bill is silent but which merit special
attention from the Portfolio Committee.
Firstly, the Act prohibits smoking in workplaces, but allow it in private
homes. Private homes are often a workplace for domestic workers. These workers
are therefore not protected from tobacco smoke in smoker's homes. The Act has
created the discriminatory situation where domestic workers are given less
protection than other workers. This is not fair. All workers including domestic
workers must. be protected from tobacco smoke pollution.
Secondly, there is strong public support for a ban .on smoking in cars while
children are passengers. Smoking in cars can produce high concentrations of
smoke which can harm young children.
'
The amendments to Section 3A of the Act address regulation of the tobacco
product itself. Manufactured tobacco products are more toxic, carcinogenic, and
hazardous to health than they need to be to deliver nicotine.
Cigarettes are the deadliest form of nicotine delivery available on the market.
Yet, cigarette-manufacturing is barely regulated. By contrast, pharmaceutical
smoking cessation products (such as nicotine gum and inhalers) are subject to a
lengthy and expensive government approval process before they can be marketed.
A cigarette manufacturer can add anything it wishes to cigarettes without any
regulatory oversight. On the other hand, if a pharmaceutical company wants to
add mint flavouring to nicotine gum to improve the taste, it must endure years
of regulatory
hurdles.
The Bill allows for the regulation of the substances that the manufacturer can
put into tobacco products (its constituents) and the chemicals that may be
produced when tobacco products are used (its emissions).
The purpose of Section 3A is to reduce the harmfulness of tobacco products. It
requires tobacco manufacturers to produce the least dangerous product
technically possible.
The WHO has recommended that countries establish manufacturing standards for
tobacco products so as to reduce their appeal to children, decrease their
addictive qualities, and decrease potential harm to users.
The Bill also proposes that manufactured cigarettes be manufactured in a way
that reduces the likelihood of a cigarette causing fires. In 2004, cigarettes
caused 1400 (or 4% of the total) fires in SA. Over R45 million worth of
property was destroyed. The devastating fire in 2005 at Table Mountain was a result of a single carelessly discarded cigarette.
Finally the Bill increases the penalties so that they are a real deterrent to
contraventions of the Act. A fine of R200 for allowing smoking in a restaurant
is miniscule and has no impact on restaurant owners.
The National Council Against Smoking (NCAS) welcomes the draft Tobacco
Products Control Amendment Bill (824-2006). We thank the Portfolio
Committee for the opportunity to comment on the Bill.
INTRODUCTION
1: The National Council Against Smoking (NCAS) welcomes the draft Tobacco
Products Control Amendment Bill (B24-2006). We thank the Portfolio
Committee for the opportunity to comment on the Bill.
2. The NCAS is a non-profit organization established in 1976 with the mandate
of promoting public health through encouraging non smoking as a social norm.
3. Tobacco harms both public health and the economy. The World Health
Organisation and the World Bank have both urged governments to control tobacco
because it is a threat to health and sustainable economic development.
4. The NCAS has consistently supported the country's tobacco laws and is in
favour of the proposed amendments. The Bill will build on the important gains
that have already been achieved in lowering tobacco consumption since 1994.
5. This submission will briefly review the policy objectives that will be
served and evaluate the likely effectiveness of tobacco control measures
proposed in the Bill.
Unique treatment for a unique product
6. Tobacco is the only legal consumer product that kills the user when used
exactly as the manufacturer intended. There is also no safe level of use.
7. All forms of tobacco are harmful but cigarettes are more dangerous than
cigars, snuff and snus.
8. Tobacco use causes, or worsens, over 40 diseases including cancer, heart
attacks, lung disease, complications of pregnancy and TB.
9. Tobacco use kills about 30000 South Africans each year or about 80 people a
day. This is more than double the number of deaths on our roads every year.
10. A smoker is more likely to die from tuberculosis (T8) than a non-smoker.
Every day about 16 avoidable deaths from TB occur amongst smokers.
11. Globally, only two major causes of death are increasing rapidly - HIV and
tobacco. The WHO predicts that, unless urgent action is taken worldwide deaths
from tobacco will double from the current 5 million to 10 million annually by
the year 2025.
12. Approximately 70% of these future deaths will occur in the poor nations of
the world, where already overburdened health services are unprepared for this
coming epidemic.
Tobacco use in South Africa
13. Fewer adults and children are smoking in South Africa as a result of
the tobacco laws. In 2002, about 62% of 14 to 16 year-olds had not taken even a
single puff on a cigarette; this was up from 53% in 1999.
14. Since 1994, the number of adults who smoke has gone down by over a third.
About 5 million or 23% of adults smoke. Snuff is used by about 10% of African
women.
SECTION 2: CONTROLLING TOBACCO USE.
Policy goals
15. The reasons for enacting legislation to control smoking in public places
are to:
(a)-ensure that a clean and healthy environment is maintained;
(b) ensure that the smoking of others does not impair the health of non-smokers;
( c) prevent the nuisance that smoking may cause to non smokers.
Background
16. In 2004, smokers burned 25 million kilograms of tobacco in our air making
tobacco smoke one of our largest sources of indoor air pollution.
17.Cigarette smoke contains over 4500 chemicals, including over 200 known
poisons (arsenic. cadmium, cyanide, nicotine, etc) and 60 chemicals that cause
cancer.
18. Over 600 scientific studies have now linked passive smoking and ill health.
It is a cause of lung cancer and heart disease in adult non-smokers. In children
it increases the risk of sudden infant death syndrome (SIDS), acute respiratory
infections (croup and pneumonia), ear problems and asthma attacks.
19. There is no safe level of exposure to tobacco smoke and both short-term and
long-term exposure can cause harm. As little as 30 minutes of exposure to
secondhand smoke can significantly increase the risk of a heart attack in those
with heart problems.
20. A number of countries have now banned smoking completely in indoor public
areas, including Ireland, Norway, Bhutan, New Zealand and Scotland.
21. A total ban on smoking in indoor public places has several advantages. It
would:
be more effective than a partial ban in decreasing tobacco smoke
pollution and in
improving health;
be fairer as it would protect all workers. Currently, those who
work in areas set
aside for smoking are still exposed to harm;
generate considerable cost savings to society; and
be simpler, more consistent and easier to enforce.
22. Surveys show that 80% of smokers and non-smokers support a ban on smoking
in public places in South Africa.
23. The Tobacco Products Control Amendment Act of 1999 took significant steps
toward protecting the public by prohibiting smoking in all enclosed public
places and workplaces, except for designated areas set aside for smokers.
24. Almost overnight, the social norms regarding secondhand smoking changed.
Whereas previously people smoked anywhere and everywhere including in
hospitals, now the ashtray and smoky haze has almost disappeared.
25. Clear rules defining where smoking is, or is not, permitted has averted
needless conflict between smokers and non-smokers. Both smokers and non-smokers
can then be sure of their rights. The public have embraced the law and shopping
malls, public transport and workplaces rapidly became smoke-free. With the
exception of some in the hospitality industry, the law is working well.
27. The law is self-enforcing. The police did not have to sit in every cinema,
cafe, and office waiting to arrest offenders. Instead, ordinary citizens stood
up for their right to clean-air.
The Proposed Amendments.
28. The NCAS is especially supportive of the Bill’s increased requirements regarding
smoking in public places. The Bill seeks to better protect children from
passive smoking and seeks to guarantee workers there constitutional right to an
environment that is not harmful to their health.
Restrictions on smoking near entrances to enclosed public places:
29. The NCAS supports moving smokers away from the entrances and air inlets
to buildings. Tobacco smoke can enter and pollute buildings though open doors,
windows and ventilation inlets. People entering and exiting the building are
also exposed to this pollution. This can be particularly problematic for those
with asthma or heart conditions, for whom even short exposures to smoke can
trigger an attack.
30. Significant numbers of people now smoke near entrances and exits to
buildings as an unintended consequence of the current law. As a result, high
concentrations of tobacco smoke can be found near entrances and exits through
which the public must go, and smoke enters buildings via general airflow.
31. The NCAS has received numerous complaints from the public on this issue.
For example, many indoor diners complain that in coffee shops and restaurants
they are exposed to smoke from those smoking outside in the alfresco area.
32. The problem can be fairly easily resolved by prohibiting smoking within 3
metres of any non-domestic building. Experience in other countries shows that
the policy can be enforced through signage at entrances and moving ashtrays
away from doorways.
33. Since 1997, Tasmania has prohibited smoking within 3 metres of an entrance
to or exit from any non-domestic or multiple-use building and within 10 metres
of any air intake for ventilation systems for buildings.
Smoking in day care centres and the entry of minors into smoking sections.
34. The Bill seeks to protect children in two ways. It proposes not
allowing smoking in private homes used commercially for childcare or
educational purposes. It also proposes not allowing minors into the areas set
aside for smoking.
35. Young children are especially vulnerable to second-hand smoke because they
breathe more air relative to body weight than adults and so absorb more tobacco
smoke toxins. They are also less able to complain or remove themselves from
smoke-filled rooms.
36. It is vital that facilities for children be smoke-free. Children of
non-smoking parents should not be exposed to harm while in day care. For
children of parents who smoke exposure in the home plus in the day care will be
additive and increase the harm.
37. In day care facilities, even if smoking is restricted to a single room in
the house, smoke will still drift throughout the home. It is not possible to
confine smoke to one area. The NCAS have received reports of caregivers walking
from other parts of the house into the room where the children were with a
lighted cigarette because he or she was not consciously mindful of his/her smoking.
38. Prohibiting smoking in day care and tutoring facilities only during times
when children are actually on the premises will not work. This disregards the
fact that many of the volatile chemicals in smoke remain in the air for a long
time following the smoking of a cigarette (from four hours to days). Some of
the solid particles in smoke will settle on furniture, carpets and other
surfaces in the room. These then slowly re-enter the atmosphere creating a
hazard long after smoking has ceased. A simple test of how long smoking
persists is that one can still smell cigarette smoke in a home, or on clothes,
long after someone has smoked.
39. In relatively confined spaces, such as smoking areas, where many people
smoke, high levels of tobacco smoke toxins can build up, To take children into
these places is recklessly exposing them to harm.
40. Prohibitions on taking children into public smoking areas can have an
educational effect for parents, who may be less inclined to smoke at home.
Smoking in sports stadia and other crowded facilities.
41. Section 2(3) allows the Minister to prohibit smoking in certain outdoor
areas, where smoking may constitute a fire or other risk. In crowded sports
stadia exposure to tobacco smoke is likely to be sustained (from a few hours to
the whole day for cricket lovers) and significant. Vulnerable people, who are
very sensitive to smoke, can have their health put at risk.
42. In addition, many communities ban nuisances like loud noise at night,
public drunkenness, dogs defecating on pavements, etc. So even when tobacco
smoke may not harm health it is still a major nuisance which should be
controlled in areas in which exposure cannot be easily avoided such as at
railway platforms and entrances to buildings.
Protecting the constitutional rights of workers.
43. The Constitution guarantees everyone the right 'to an environment that
is not harmful to their health or well-being". Sections 2(3) and (4)
require employers to respect employees' rights and protect them from the harms
caused by tobacco smoke pollution.
44. Surveys find that most people do not want to be exposed to tobacco smoke.
However, many are afraid to assert their right to smoke-free air in the
workplace because of the fear of upsetting their employers. They instead phone
local authorities, the health department and non-governmental organizations
seeking help while wishing to remain anonymous. The Bill proposes making it
possible for people to safely articulate their concerns without fear of
repercussions.
45. The Bill also places an obligation on employers to respect an employee’s
right not to be forced to work in a smoking section against their wishes.
People should not be required to pay with their health for the opportunity to
work. The Bill proposes prohibiting employers from coercing people desperate
for employment to work in the smoking section (section 2(5)(c)) and from
seeking legal guarantees that employees will not to hold them responsible for
harm caused by working in a smoking section.
46. Business owners cannot contract with their workers to relax workplace
safety standards and the same rule should apply to tobacco smoke.
The Special Case of Domestic Workers
47. The Act in general prohibits smoking in workplaces, but continues to allow
it in private homes. Private homes can be a workplace for domestic workers.
These workers are therefore not protected from tobacco smoke in smoker's homes.
The Act has created the discriminatory situation where domestic workers are
given less protection than other workers. The NCAS urges that this anomaly be
ended and that all workers, including domestic workers, be protected from
pollution by tobacco smoke.
Smoking in cars
48. There is strong public support for a ban on smoking in cars while
children are passengers. The Bill is silent on this issue. Smoking in cars can
produce high concentrations of smoke. Even with all the windows open the
particulate matter levels can be higher than what is considered 'safe' for
sensitive groups like children and the elderly. When the windows are closed the
smoke concentrations can reach levels considered ':-hazardous for the general
population.
49. The NCAS believes that a strong case can be made for banning smoking in any
vehicle while driving. We have received reports of people throwing stompies out
of the window, only for the wind to blow the cigarette back into the driver's
lap. Frantic efforts to find the lit cigarette then follow to stop it burning
clothes or the car upholstery. The lapse in concentration poses a road threat.
50. The NCAS urges the Portfolio Committee to prohibit smoking in cars while
children are present. We believe that public support for the ban is sufficient
to ensure that enforcement will not be a problem.
SECTON 3A: STANDARDS FOR MANUFACTURING AND EXPORT OF TOBACCO PRODUCTS
Policy goals
51. The purpose of Section 3A is to reduce the harmfulness of tobacco
products. It requires tobacco manufacturers to produce the least dangerous
product technically possible.
52. The way tobacco products are designed and manufactured affects their
safety, appeal, and addictiveness. Manufactured tobacco products are more
toxic, carcinogenic, and hazardous to health and the environment than they need
to be to deliver nicotine.
53. The Bill allows for the regulation of the substances that the
manufacturer's can put into tobacco products (its constituents) and the
chemicals that may be produced when tobacco products are used (its emissions).
54. The WHO has recommended that countries establish manufacturing standards
for tobacco products so as to reduce their appeal to children, decrease their
addictive qualities, and decrease potential harm to users.
Background
55. Despite their toxicity tobacco products are currently subject to little
regulation regarding their content, design and manufacture. New tobacco
products can be introduced and the design of currently available products can
bed changed o the whim f the manufacturers, and with almost no regulatory
oversight.
56. Paradoxically, medications to help people quit smoking are strictly
regulated by the Medicine's Control Council. These have to meet the same safety
and product standards as any other scheduled medicine and can only be sold
through pharmacies.
57. A policy that barely regulates nicotine in its deadliest form (cigarettes),
while strictly regulating it in its safest form (medications) is not rational.
The WHO has recognized this is anomaly. The FCTC mandates that governments
require tobacco companies to reveal what ingredients they use in producing
cigarettes and that these are disclosed to the public.
58. The cigarette is more than just dried tobacco wrapped in paper, and snuff
is not simply powdered tobacco leaf. Modem tobacco products are highly
engineered. The manufacturers have spent enormous resources researching the
design and manufacture of cigarettes. The key goal is to deliver nicotine
rapidly and in sufficient quantities to feed a smokers craving.
59. Highly sophisticated technologies are used to fine-tune the addictiveness
of the modem cigarette:
Ventilated filters provide cooler and more dilute smoke. This enables the
smoker to readily inhale larger quantities more deeply into the lungs.
The physical size of smoke particles is carefully controlled - using the
science of particle physics - to allow smoke particles to penetrate deep into
the lungs.
Chemical ingredients are added to the tobacco, filter, and paper during the manufacture
of cigarettes or snuff. These ingredients are called 'additives' and serve many
purposes.
60. Up to 1400 chemicals can be added to tobacco. These additives:
- Mask the irritating and harsh taste of smoke (sugars are added).
- Enhance nicotine delivery, so increasing the addictive "kick" of
nicotine (ammonia).
- Keep the product fresh (anti-fungals);
- Control the rate at which cigarettes bum (nitrates).
- Produce a white ash (chalk).
- Give brands their special flavour (cocoa, chocolate).
61. Recognizing that children often find the taste of cigarettes unpleasant, US tobacco companies planned a "learner cigarette" for teenagers. The aim was to
produce a cigarette "tailored for the beginning smoker to get them through
the largely physically learning to smoke phase."
62. Chocolate, licorice, honey, sugars, menthol, and other flavourings help
hide the unpleasant taste of tobacco and make it easier for children to start
smoking. Menthol, for instance, numbs the throat and reduces coughing.
63. On October 11 2006, a U.S tobacco company agreed to stop marketing candy
and alcohol flavored cigarettes in the U,S, because of its appeal to children,
In a legal settlement with government lawyers the company agreed to stop
selling cigarette brands with names like "Twista Lime" and
"Mocha Mint".
64. Additives, such as ammonia change the pH of smoke so increasing ‘freebase’
nicotine levels. Free nicotine, like crack cocaine, passes more rapidly and
completely through the lungs into the bloodstream and has a faster effect on
the brain.
67. The safety of many of the flavourings and other additives when burned and
inhaled has not been established.
68. By engineering products to enhance addictiveness the industry makes it more
difficult for smokers to quit, and is thus deliberately increasing the overall
harm to the public.
69. The tobacco companies have over the years filed many patents for technology
that would have removed some of the harmful components of tobacco smoke, but
never made these 'less toxic' cigarettes available to the public. The problem,
according to industry documents is that in order to market these changed
cigarettes as 'safer', the industry would have r.ad to admit that its existing
products were dangerous.
70. When a cigarette is lit, the process of burning will produce over 4500
chemicals in the smoke - 200 of these are poisons (arsenic, cyanide, carbon
monoxide, nicotine) while over 60 can cause cancer. The chemistry of smoke is
influenced by many factors including the type of tobacco used, the length of
the cigarette, the burn rate of the paper and how the cigarette is smoked.
71. Currently, the law in South Africa allows limits to be set on the
constituents in tobacco smoke. Maximum limits have been set for nicotine and
tar in cigarette smoke. However, the value of these regulations is eroded by
the inaccuracies in the testing methods.
72. The tar and nicotine numbers that appear on South African cigarette packs
are meaningless. They convey no accurate information to smokers about what they
are inhaling.
73. This is because the International Standards Organization (ISO) testing
methods currently in use for measuring tar and nicotine are flawed. There is
little relationship between the ISO machine-measured yields of cigarettes and
what smokers actually absorb. Further, there are no methods for testing
smokeless tobacco products.
74. Smokers can obtain as much nicotine and tar from smoking 'low-tar'
cigarettes as they can from smoking regular cigarettes. This complicates the
ability to regulate tobacco products. To date, no country has fully met the
challenge of developing comprehensive product regulation standards.
Regulatory Approach
75. A new regulatory framework is needed in which the manufacturer is
obliged to demonstrate that no additional harm arises for tobacco product
design decisions such as the use of additives. While it is impossible to make a
cigarette safe, it is reasonable to prevent manufacturer's doing anything that
increases the harm caused by tobacco smoke.
76. A new framework should:
- Require manufacturers to disclose all additives used in tobacco products, by
brand, to the Government.
- Also require them to disclose the purpose of an additive and its biological effects,
if any, when inhaled.
- Enable government to order the removal of additives which increase harm.
- Only allow new additives if its safety can be demonstrated
- Permit additives necessary for the manufacturing and storage of tobacco
products provided these are safe, but bar all additives that may influence
smoking behavior.
- Not allow any health claim based on the levels of ingredients, or emissions,
or whether the product meets regulatory standards.
77. The FCTC's Conference of the Parties is developing guidelines for product
regulation and testing. Such guidance should be forthcoming in the near future.
78. The Bill proposes providing broad legal authority to the Minister to
develop standards for constituents, emissions, product design, and testing methods,
once there are clear international guidelines for doing so.
79. While there is no such thing as a safe cigarette, it remains the goal of
public health to make cigarettes less harmful. The benefits of reducing the
levels of toxic chemicals are very small compared to the benefits of stopping
smoking. However, because of the large numbers of people involved even a small
reduction in risk is worth pursuing.
Reducing the fire-risks from cigarettes
Policy goal
80. The aim is to reduce deaths, injuries and property damages
resulting from fires
started by manufactured cigarettes.
Background
81. Smokers' materials are a leading cause of residential fires and
fire-related losses in South Africa, resulting in about 5 percent of all fires.
The 1,400 fires caused by cigarettes in South Africa in 2004 destroyed property
to a value of well over R45 million.
82. Cigarette fires typically result from lit cigarettes left unattended,
falling asleep while smoking in bed, smoking while under the influence of
alcohol, or the tossing away of a lit cigarette. When a lit cigarette comes
into contact with flammable products such as mattresses, bedding or upholstered
furniture, it can start a smouldering process that can continue undetected for
some time before bursting into flame.
83. It is possible to reduce cigarette ignition propensity (that is the
likelihood that a lit cigarette will start a fire) by altering certain design
characteristics of manufactured cigarettes.
84. In July 2000, a major American cigarette manufacturer released a
reduced-ignition propensity version of one of its cigarette brands in the United States, In April 2001, it released a reduced ignition propensity version of the same brand in
New Zealand.
This product is made with a patented paper which has concentric bands of
ultra-thin paper applied on top of traditional cigarette paper. The
manufacturer claims that
"These bands or rings act as 'speed bumps to-slow down the rate at which
the burns as the lit end crosses over them”. When tested by the U.S. National Institute
of Standards and Technology, these cigarettes were found to have a significantly
reduced ignition potential.
85. On December 31,2003, New York State became the first jurisdiction in the
world to mandate a standard to reduce the ignition propensity of cigarettes
when it proclaimed its Fire Safety Standards for Cigarettes. The
standard came into effect on June 28, 2004. and all cigarette brands sold in New York State now meet these standards. In May, Canada too proposed new regulations to
reduce the fire risks of cigarettes.
86. Reduced ignition propensity does not mean fire-safe. It is impossible to
make a burning object completely fire-safe. However, the proposed regulations
can save lives by significantly reducing the number of fires started by
cigarettes.
Regulatory approach
87. The Bill allows the Minister to set a 'performance standard' that
all cigarettes sold in South Africa must meet. This wil) require cigarettes to
self extinguish after a few minutes, if not puffed upon. The law will prescribe
the objective but allow manufacturers the freedom to use the manufacturing
process or technical design of their choosing to achieve it.
PENALTIES
88. The Bill increases the penalties for contraventions of the law so that
they are a meaningful deterrent. The fine for the owner of a public place is
increased from R200 to a maximum of R50 000, and for individual from R200 to a
maximum of R500.
89. The proposed fines are reasonable and modest compared to those for other
offences. For instance the maximum fine for selling liquor to a minor is R 1
million, and
for poaching perlemoen it is R 800 000.
CONCLUSION
90. This submission has provided a rationale for the amendments contained
in the Bill. The NCAS believes that the Bill is fair, reasonable and workable.
It will make a significant contribution to reducing the health, economic and
environmental harms caused by tobacco use in South Africa.
91. Freedom from addiction is a child's right and society's responsibility. We
trust that the Portfolio Committee on Health will put the freedom of children
to grow up healthily above the freedom of an industry to sell a deadly drug.