May 26, 2014

An Open Letter to Cancer Council Victoria

Four years ago, in April 2011, Professor David Hill, Director of Cancer Council Victoria made bold predictions about the impact of plain packaging.  Writing in the Sydney Morning Herald, he claimed that “plain packaging will slash smoking rates … make significant inroads into reducing rates of smoking initiation and consumption … [and] has enormous potential to cut smoking rates.”[i]  In February 2013, barely two months after trademarks had been removed from the Australian tobacco market, you quoted Fiona Sharkie of Quit Victoria who claimed that “plain packaging is already having an effect.”[ii]  

Yet, in your critique of a recent analysis of adolescent smoking prevalence conducted by researchers from the University of Saarland and the University of Zurich,[iii] you appear to have changed your view.  You now claim that plain packaging could not “be expected to immediately lead to a detectable reduction in adolescent smoking prevalence” and that this was not the “expectation of governments or any credible researcher.”[iv]  Similarly, in your critique of an analysis of adult smoking prevalence conducted by London Economics,[v] your position was, “it is likely to be many years before an impact on the decline in prevalence can be accurately assessed.”[vi]

We are confused.  Will plain packaging “slash smoking rates” or will it have no measurable effect for years to come?  Was there an effect already in February of 2013 but no effect a year later?

Do you indeed say now that one cannot expect plain packaging to have any impact on smoking rates one year after its full implementation?  If that is the case, after how many years should governments expect to see the measurable effect you promise, and with what magnitude and probability?  How many years is “many:” three, five, ten or more years?

We are also struck by your statement that no “credible researcher” would expect an impact within the first year (particularly as this is what Professor Hill enthusiastically proclaimed in 2011).  This is at odds with the findings of the expert elicitation exercise conducted by Pechey et al. in 2012, in which renowned tobacco control experts provided best guess estimates of the impact of plain packaging on adolescent smoking.[vii]  Ultimately, the experts guessed that the number of youth trying smoking would decrease by 3% within two years.

Our question to you:  If the “best guess estimate” is a reduction of 3% within two years, would you not expect some effect within the first 13 months of implementation?  Or, in the alternative, is it your view that neither these experts nor this study are credible? 

Finally, is it not a double standard that you would be happy to portray studies that count whether people display their packs in cafes and bars as evidence that plain packaging is working,[viii] but dismiss out of hand a thorough statistical analysis of more than 41,000 data points on actual smoking behavior?

We look forward to your answers.  As the World Health Organization International Agency for Research on Cancer wrote,

As tobacco control policies are formulated and implemented, it is important that they undergo rigorous evaluation  … [W]e need to not only consider the size and nature of effects, we also need to consider the possibility that there is no meaningful effect. (…) We recognize that science cannot prove the null hypothesis, but it can and should make statements about interventions where there is a consistent failure to find evidence of any meaningful effect.[ix]

 

With our warmest regards,

Julie Soderlund, Vice President Communications, Philip Morris International


[i] Available at http://www.smh.com.au/federal-politics/political-opinion/tobacco-industry-has-much-to-fear-20110407-1d63x.html.

[ii] http://www.cancervic.org.au/about/media-releases/2013-media-releases/february-2013/nz-plain-packaging.html.

[iii] Available at http://www.econ.uzh.ch/static/workingpapers.php?id=828.

[iv] Available at http://www.cancervic.org.au/downloads/tobacco_control/2013/Cancer_Council_Victoria_comments_on_Kaul_Wolf.pdf.

[v] Available at http://londoneconomics.co.uk/wp-content/uploads/2013/11/London-Economics-Report-Australian-Prevalence-Final-Report-25-11-2013.pdf.

[vi] Available at http://www.cancervic.org.au/downloads/tobacco_control/2013/Critique_by_Cancer_Council_Victoria_on_report_by_PMI_26.11.13.pdf.

[vii] Available at http://www.biomedcentral.com/1471-2458/13/18.

[viii] Available at http://www.ncbi.nlm.nih.gov/pubmed/24428427.

[ix] World Health Organization, International Agency for Research on Cancer, Volume 12, Methods for Evaluating Tobacco Control Policies (2008) available at http://www.iarc.fr/en/publications/pdfs-online/prev/handbook12/Tobacco_vol12.pdf.

 

[i] Available at http://www.smh.com.au/federal-politics/political-opinion/tobacco-industry-has-much-to-fear-20110407-1d63x.html.

[ii] http://www.cancervic.org.au/about/media-releases/2013-media-releases/february-2013/nz-plain-packaging.html.

[iii] Available at http://www.econ.uzh.ch/static/workingpapers.php?id=828.

[iv] Available at http://www.cancervic.org.au/downloads/tobacco_control/2013/Cancer_Council_Victoria_comments_on_Kaul_Wolf.pdf.

[v] Available at http://londoneconomics.co.uk/wp-content/uploads/2013/11/London-Economics-Report-Australian-Prevalence-Final-Report-25-11-2013.pdf.

[vi] Available at http://www.cancervic.org.au/downloads/tobacco_control/2013/Critique_by_Cancer_Council_Victoria_on_report_by_PMI_26.11.13.pdf.

[vii] Available at http://www.biomedcentral.com/1471-2458/13/18.

[vii] Available at http://www.ncbi.nlm.nih.gov/pubmed/24428427.

[ix] World Health Organization, International Agency for Research on Cancer, Volume 12, Methods for Evaluating Tobacco Control Policies (2008) available at http://www.iarc.fr/en/publications/pdfs-online/prev/handbook12/Tobacco_vol12.pdf.

 
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