Rapid Responses to:

HEAD TO HEAD:
Stig Pramming
Should we use regulation to demand improved public health outcomes from industry? No
BMJ 2008; 337: a1761 [Full text]
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Rapid Responses published:

[Read Rapid Response] Full Disclosure Needed for Successful Partnerships
Michael P. Eriksen   (4 October 2008)
[Read Rapid Response] Inclusive Stakeholder Consultation Important For Improved Public Health Outcomes
Sudhanshu R Patwardhan, MBBS   (31 October 2008)

Full Disclosure Needed for Successful Partnerships 4 October 2008
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Michael P. Eriksen,
Professor and Director
Institute of Public Health, Georgia State University, Atlanta, Georgia, 30303

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Re: Full Disclosure Needed for Successful Partnerships

The debate by Sugarman and Pramming in the October 2, 2008 issue of BMJ is extremely important in our efforts to better understand how public health and private industry can interact in advancing the common good. Professor Sugarman’s approach of performance-based regulation, which allows the regulated industry the prerogative of “how” it is going to achieve its public health performance measure, is innovative and deserves to be tested.

Similarly, Professor Pramming’s perspective of advancing private- public partnerships has merit, given that some segments of the private sector are at least partly responsible for the very public health problem under consideration. Accordingly, these companies should be given the opportunity to be part of the solution as well. This is precisely the point expressed by Professor Sugarman – make the private sector responsible for reducing the public health toll their products create. The goals are the same, the means are different.

To work successfully with the private sector, however, there must be full and transparent disclosure. This point is properly reflected in the Oxford Health Alliances guidelines for interacting with the private sector http://www.oxha.org/about/supporting- oxha/OxHA%20guidelines%20for%20funding%20and%20interaction%20with%20industry%20version%201%20February%202008.pdf. However, it appears that the Alliance hasn’t followed its own guidelines in terms of disclosing real or perceived conflicts of interest. The Alliance’s guidelines state that it “…is also committed to transparent, ethical behaviour with respect to funding sources and interactions with the private sector.”

In his essay, Professor Pramming does not declare any competing interests. He is, however, the Executive Director of the Oxford Health Alliance, which receives a portion of its funding from the private sector, in fact, some of the very companies that he touts in his essay. It is difficult to determine the proportion of the Alliance’s budget that is provided by private industry because the Alliance appears to be out of compliance http://www.charitycommission.gov.uk/ShowCharity/RegisterOfCharities/CharityWithoutPartB.aspx?RegisteredCharityNumber=1117580&SubsidiaryNumber=0 in submitting its annual reports to The Regulator of Charities for England and Wales, the Commission that is responsible for assuring that “…that they (charities) operate for the public benefit and independently of government or commercial interests.”

To be successful in advancing a constructive and effective approach to solving some of our greatest public health problems, cooperation and involvement of the private sector is critical. However, to be successful, it must be based on full disclosure and transparency.

Competing interests: Serve as a consultant to the Bill and Melinda Gates Foundation and the Robert Wood Johnson Foundation.

Inclusive Stakeholder Consultation Important For Improved Public Health Outcomes 31 October 2008
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Sudhanshu R Patwardhan, MBBS,
International Scientific Affairs Manager- Medical and Public Health
British American Tobacco, Globe House, 4 Temple Place, London WC2R 2PG, United Kingdom

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Re: Inclusive Stakeholder Consultation Important For Improved Public Health Outcomes

It is encouraging to note that both authors acknowledge that there is a role for ‘industry’ to play in positively impacting public health outcomes through partnerships with governments, policymakers and other stakeholders (1,2).

We, at British American Tobacco, believe that truly effective regulation needs co-operation between governments and industry, and we welcome constructive discussion with governments through a fully inclusive stakeholder consultation process. This process should achieve effective, evidence-based regulation which can help measurably to reduce the public health impacts of the use of tobacco products, while respecting the choices and rights of adults who decide to use these products and allowing our business as part of a legal industry to compete for their custom.

One of our core beliefs (3) is that the health impact of tobacco consumption should be reduced, while respecting the right of informed adults to choose the products they prefer. Consumers should have access to a range of tobacco products, including potentially reduced-risk tobacco products. We believe, along with a proportion of the public health community, that regulators could achieve further public health gains through regulatory approaches that include potentially reduced-risk products, as well as continue with the current public health policies of prevention and cessation.

We think that cooperation between regulators and the industry would achieve suitable regulatory frameworks for assessing and bringing to market potentially reduced-risk products, and for facilitating appropriate consumer communications to enable informed choices based on the risks and relative risks of different tobacco products – a so-called “Comparative risk reduction continuum” (4). One such potentially reduced-risk tobacco product is the smokeless Swedish -style snus product. Based on epidemiological data, leading medical experts agree that “health risks associated with snus are lower than those associated with smoking…” specifically for lung cancer and cardiovascular disease, and that “for most of the major health effects of tobacco, smoking is many times more dangerous than smokeless tobacco use” (5).

Understandably, there is considerable debate about what the public health impact of products like this might be and whether they would actually contribute to a reduction in total tobacco-related harm on a population basis. However, it seems invidious that while consumers in Sweden are allowed to buy snus, there is a current legal ban preventing millions of smokers elsewhere in the EU having that same option of choosing a potentially reduced risk product. Similarly, in the vast majority of countries worldwide, no regulatory framework yet exists to encourage innovation of potentially reduced risk tobacco products and allow communication about their relative risks compared to combustible products.

In our view, regulatory frameworks drawn up through a consultative and collaborative process involving all stakeholders can best achieve government and public health objectives, while incentivising industry innovation in developing and bringing to market consumer acceptable reduced-risk products.

References

1. Head to head: Should we use regulation to demand improved public health outcomes from industry? Yes. Stephen D Sugarman, BMJ 2008; 337:a1750

2. Head to head: Should we use regulation to demand improved public health outcomes from industry? No. Stig Pramming, BMJ 2008; 337:a1761

3. www.bat.com

4. “Tobacco and tobacco products: At a crossroads in the 21st century”. Scott D Ballin, August 2006. http://www.tobaccoatacrossroads.com

5. “Harm reduction in nicotine addiction- Helping people who can’t quit”. A report by the Tobacco Advisory Group of the Royal College of Physicians. October 2007.

Competing interests: None declared