SPECTRUM comments on draft tobacco control strategy for Wales and delivery plan

Consultation response recommends closer consideration of Article 5.3 of the WHO Framework Convention on Tobacco Control, and recognition of the role inequalities and disparities play in driving tobacco use.

1 April 2022

Responding to a consultation launched by the Welsh Government, SPECTRUM has provided comments on the draft long term tobacco control strategy and delivery plan, which aims to achieve a smoke-free Wales by 2030.

Addressing smoking-related inequalities

Although smoking rates have declined significantly in Wales over the last 50 years, smoking-related inequalities have increased. The ambition to be smoke free by 2030 can only be realized if there is recognition of the role inequalities and disparities play in driving tobacco use.

The SPECTRUM response welcomes the inclusion of ‘Reducing Inequalities’ as one of three themes in the strategy. However, it recommends formulating clearer actions to drive forward change. It is also vital to consider all types of inequalities – often the focus is placed on low socio-economic status groups, however those with a mental health condition for example should also be a priority.

We know that smoking prevalence is higher among people with mental health problems and that it increases with severity of the mental health problem.

A two-pronged approach

Youth smoking rates are also important to address, in order to facilitate a smoke-free norm for future generations. Those who grow up in communities where smoking is an everyday occurrence are highly likely to become smokers in the future.

However, this must be considered alongside efforts to tackle existing adult smokers – a much larger population.

…it should be acknowledged that preventing uptake among children can only have a limited effect due to the much smaller number of people becoming adults in the next few years compared with the number of existing adults. A two-pronged approach of preventing uptake of smoking in younger people whilst providing cessation support to those already smoking (including adult smokers) will, over time, break this cycle.

Underpinned by Article 5.3

Industry interference to limit effective tobacco control measures is well documented and must be prevented.

The response recommends closer consideration of Article 5.3 of the WHO Framework Convention on Tobacco Control (FCTC), which should underpin the strategy, priority action areas and associated key actions in the Tobacco Control Plan.

In particular, there is currently no method to identify potential conflicts of interest with regards to consultation responses. The SPECTRUM response suggests that this is considered by the Welsh Government when reviewing submissions, and recommends the inclusion of a request to declare potential conflicts in order to comply with the obligation to protect the development of public health policy from the vested interests of the tobacco industry.

Aligning the Welsh Tobacco Control Plan with the approach outlined in the FCTC is appropriate and important particularly as a signatory to the Convention.  It is essential that the tobacco industry has no role in shaping public health measures for tobacco control and that their responses to this consultation are considered in isolation.

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