In March QNADA submitted a response to the call for feedback on the draft National Tobacco Strategy 2022-2030 (the Strategy). The QNADA submission wholly supports the priority areas for the Strategy and commends it for seeking to directly address tobacco industry interference in public health and tobacco control policy. QNADA argues this approach sets an example for other drug policy areas, such as alcohol, where industry influence and involvement continues to stifle good public health policy. QNADA agrees with the Strategy position that government action alone cannot reduce the prevalence of tobacco use, and that a strength of Australia’s tobacco control measures to date has been partnerships between governments, NGOs, health professionals, research groups and community groups. To this end, QNADA identified four areas we believe the strategy should further address. We’ve provided an abridged version of what we included in our submission below.
- Future proof the strategy by clarifying how all priority areas and actions could be applied to new and emerging nicotine products.
While QNADA recognises the emphasis on preventing and reducing harms from new and emerging products (including e-cigarettes) in priority area 9 of the draft strategy, we believe these issues are relevant across the entire strategy and need to be outlined more widely. As novel nicotine products become more widely used and available, and the evidence around potential harm and therapeutic use continues to evolve, all priority areas and actions of the strategy will become increasingly relevant to novel products. QNADA supports strengthened regulations for new and emerging products, however we do not support legislative approaches that focus on individuals who are using these products as opposed to organisations selling and promoting them.
- Closely monitor trends related to excise.
Excise increases have been resoundingly successful in reducing smoking prevalence at a population level. However, we note the relatively small gains excise measures have furnished in disadvantaged populations. We suggest that while price increases have been – and may continue to be – an effective mechanism to reduce tobacco use, we may be approaching a threshold, where prohibitive pricing begins pushing vulnerable populations to illicit tobacco in the absence of other nicotine replacements and support. While we acknowledge the ATO’s Tax Gap Analysis findings of a reduced net illicit tobacco market in spite of rising licit tobacco prices, we suggest targeted research be undertaken to quantify the extent of illicit tobacco use amongst disadvantaged groups and to better inform countermeasures to illicit tobacco use.
- Prioritise support and resourcing for community controlled organisations and ensure meaningful partnerships.
We are pleased to see the strategy acknowledges the social and cultural determinants of health as influencing tobacco use and the broader importance of tobacco cessation efforts to closing the gap. We support the intent to bring culturally safe tobacco cessation interventions to mainstream health services, however resourcing and support for community controlled organisations should be a priority, and the upskilling of mainstream organisations should not be at the expense of community controlled organisations.
- Appropriately resource organisations to deliver interventions and increase access to NRT
QNADA strongly agrees that evidence-based tobacco prevention and cessation programs should be part of routine care across all health (including AOD treatment and harm reduction services), social care and custodial settings. However, we do not support mandating tobacco interventions as a condition of government funding. In our view this makes little sense in the context of existing governance mechanisms that facilitate good clinical practice. We suggest instead working across systems to ensure that relevant frameworks, strategies, and guidelines address tobacco and other nicotine products where relevant, achievable, and necessary. Further, such an approach risks adding an unnecessary layer of reporting to already underfunded and overburdened services.