They say: “We recognise there is uncertainty as to the benefits and risks associated with the evolving marketplace of non-combustible tobacco products over the longer term, and we recognise there is a continuum of risk in these products. We are also duly cautious about the involvement of the tobacco industry. However, we must also consider the substantial body of evidence we do have and not allow excessive caution or residual uncertainties to deny smokers promising options to switch away from the combustible products that we know with certainty are lethal.”
The independent experts continue by expressing their regret: “Regrettably, WHO has been dismissive of the potential to transform the tobacco market from high-risk to low-risk products. WHO is rejecting a public health strategy that could avoid millions of smoking-related deaths.”
The letter makes seven key points applicable to the FCTC parties and compliments this by delivering six recommendations.
Seven Key Points:
- Tobacco harm reduction presents significant public health opportunities
- E-cigarettes are a driver of smoking cessation
- Tobacco harm reduction can contribute to the Sustainable Development Goals
- Major regulatory assessments and experience support heated tobacco products
- Policymakers must recognise unintended consequences of policy proposal
- Place adolescent ENDS use in proper context
- There is public health support for harm reduction in tobacco control
We recommend that Parties to the FCTC take a more questioning and assertive approach to WHO’s advocacy on smoke-free alternative to smoking and undertake the following:
- Make tobacco harm reduction a component of the global strategy to meet the Sustainable Development Goals for health, notably SDG 3.4 on non-communicable diseases.
- Insist that any WHO policy analysis makes a proper assessment of benefits to smokers or would-be smokers, including adolescents, as well as risks to users and non-users of these products.
- Require any policy proposals, particularly prohibitions, to reflect the risks of unintended consequences, including potential increases in smoking and other adverse responses.
- Properly apply Article 5.3 of the FCTC to address genuine tobacco industry malpractice, but not to create a counterproductive barrier to reduced-risk products that have public health benefits or to prevent critical assessment of industry data strictly on its scientific merits.
- Make the FCTC negotiations more open to stakeholders with harm-reduction perspectives, including consumers, public health experts, and some businesses with significant specialised knowledge not held within the traditional tobacco control community.
- Initiate an independent review of WHO and the FCTC approach to tobacco policy in the context of the SDGs. Such a review could address the interpretation and use of science, the quality of policy advice, stakeholder engagement, and accountability and governance. The Independent Panel for Pandemic Preparedness and Response (IPPPR), initiated to evaluate the response to the COVID-19 pandemic, offers such a model.
- Letter from one hundred specialists in nicotine science, policy, and practice - https://clivebates.com/documents/WHOCOP9LetterOct2021-EN.pdf