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I have looked at all the references they quote
to show how biased and baseless their 'convincing' evidence is.
Remember - ASH have the single hate of Smoking. This is absolute
bias and must have diverted attention from many other probable
causes of cancer. This is to the cost of many who have suffered
from their blinkered science.
ASH are far from an independent organisation and
when looking at any evidence we should remember who their
'Bed-fellows' are.
(From the Strategic plan of ASH - http://www.ash.org.uk/html/about/Strategic%20Plan%202005-08.doc
ASH is an organisation which provides information on
all aspects of tobacco and works to advance policies and measures
that will help to prevent the addiction, disease and unnecessary
premature death caused by smoking. ASH was established in 1971 by
the Royal College of Physicians. ASH receives funds
for projects undertaken to further the objectives of the
organisation. Currently, funds are provided by
the British Heart Foundation (BHF), Cancer
Research UK and the
Department of
Health.)
This should be read alongside a copy of their document published in the Health Committee Report. The Report can be found from Page 109 of 128 at http://www.publications.parliament.uk/pa/cm200506/cmselect/cmhealth/485/485iii.pdf
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15The paragraph before this one accuses without reference “…that there is concern in some parts of Government --- carefully fostered by the tobacco industry and its front groups – about the………” This is the deliberate unsupported demeaning of elected members by a group whose declared aim is to declare war on smoking. It is typical of their cry of ‘foul’ when anyone else puts alternative evidence forward. This should be remembered when looking at the sources and cherry-picking cited throughout their submission.
16 ASH & Cancer Research UK commissioned poll
17 ASH Press Release- Again they pick out what they want and ignore what others want- 54% strongly agreed when asked about ‘the workplace’ do the 35% & 32% mentioned below have any rights? 49% support ending smoking in pubs and bars (35% opposed) 47% support ending smoking in nightclubs (32% opposed) ----- Read the Latest ONS Report to show the true figure of 33% against smoking in pubs - summary at http://www.forestonline.org/files/pdf/ONSsmoking0706.pdf
18 Without reading the many, many pages it also showed how historically non-total ban measures had successfully reduced smoking prevalence.
19 Concentrates mainly on the hospitality industry. No mention of ETS exposure in the home or other possible drawbacks. Purely ‘back-slapping’- no mention of adverse(?) comment in Fong report re smaller decline in ETS exposure in the home and car than UK that used education not a ban -http://tc.bmjjournals.com/preprint/tc13649.pdf
20 Narrow view looks at specific £ cost –ignores outside provision, ignores partial removal of ETS, ignores social costs etc
21 Medical case for going Smoke-free –no quibble –BUT ignores opportunity to go reduced exposure route
22 Again simplistic and optimistic – this assumes no downsides to a total ban such as in Ireland raised smoking levels, no effect on ETS exposure in the home, no economic effects on business, no social effect on communities & individuals and more as yet unknowns.
23 – Maybe out of context- many bars had seen that level of drop
24 –Not false many bars have suffered very badly
25–current figures continue to show a serious drop in sales –ASH claim “The decline in volume at drinking places in Ireland is a function of changing social habits—not smoking laws.” Do smoking laws change social habits??? Many licensees say the law has made things worse. AND if rural pubs are closing might there be more rural/social isolation/deprivation
26 Chosen statistics to prove the extreme view
27 many bar workers are smokers and choose the job,
-maybe no infant, child or adult should be exposed to
secondhand smoke but
a/ will that be achieved by a Total ban
b/ they should also not be exposed to many other avoidable
hazards – Decreased exposure is all that can be expected and
all the ban will do is to displace smokers to unregulated places
such as the home
28 -49 out of 700 Workplace
deaths in Hospitality industry. This may be true BUT Royal
College of Physicians claim c. 12,000 die each year from exposure
to ETS. Most, 11300, are from exposure in the home. Hospitality
deaths are 0.41% of that total.
By driving smokers from the pub smoking will reappear somewhere
so alternate venues mainly the home will be found.
UCL report ‘Smoking bans kill kids’ http://www.ucl.ac.uk/media/library/smokingban full report at http://www.ucl.ac.uk/media/library/smokingban
Leaving Hospitality alone would remove a major cause of a
possible rise in ETS exposure at home.
A slight change in smoking prevalence of only 0.11% would
cause/prevent the same number of deaths as are claimed to occur
in the hospitality trade.
Smoking is on the increase in Ireland + ETS exposure in the home
fell less in Ireland than in the UK +ETS exposure in cars fell
less than in UK yet the UK does not have a total ban. The Irish
ban is causing unnecessary -deaths especially in the home
–closure & damage to rural businesses –hardship to
socially excluded smokers and non-smokers. A choice to exclude
the hospitality industry would not risk the success of current
progress (approx –0.6% pa).
A 0.6% fall is the equivalent of c.200 lives saved each year and
if the other 651 workplace lives are added we should expect over
850 lives to be saved without a total ban.
More could be added by existing trade agreed policies to increase
smoke-free environments.
Hospitality workers, frequently smokers, can choose not to work
in ‘smoke-laden’ atmospheres.
29 An accurate figure but why not complete the statement “there were 28,426 major injuries (415 more than 2001/02) and 126,004 injuries causing 3 days or more absence from work, (3,651 fewer than in 2001/02). However, the rate of major injuries rose by 1.9% while the rate of over 3-day injuries fell by 2.4%.”
30 This refers to a very threatening letter from ASH to employers that cites two cases but fails to provide any written reference of them. The paragraph states “that employees made ill by such exposure …….WILL have a claim against their employer…………” but fails to mention ‘reasonable’ one of the most important words in HASAW.
The letter also says “Although the law has not yet been fully tested in this area, ASH is aware of several local authorities where environmental health officers are planning to take enforcement notices out against workplaces where smoking is still permitted. It will be for the courts finally to decide whether in a particular case whether the risk to health was significant”. This contradicts the assurance of a valid claim mentioned above.
31 Refers to the 2005 Manifesto that never mentioned a ban only restrictions. They pick out a single phrase and suggests that it over-rides all other considerations – the word protect need not mean ‘total protection’ this could easily be achieved by taking a leaf out of the WHO terms and conditions of employment and reversing it --only smokers need to apply for employment in smoke friendly environments.
32 http://www.philipmorrisusa.com/en/policies_practices/public_place_smoking.asp - ‘file not found’
33 Would it matter if smoke-friendly pubs implemented what ventilation they could and employed smokers – this would avoid driving smoking into unregulated environments. Market forces, the existing smokefree charter and continued education would ensure smoke-free environments flourished to accommodate the increasing numbers of non-tolerant non-smokers.
34 This might be true but not required in designated smoke-free establishments. Smoke-friendly establishments could provide good ventilation.
35 Proposed exemptions assumed that no pub would be exempt and under these circumstances this quote makes sense. It does not suggest that the BBPA wanted it.
36 “If legislation” – the comment is as above
37 Page not found but totally agree but maybe this indicates that many decisions/directions had been formulated before this stage. These are not easy to defend but would not need to be included in a better-drafted document.
Paragraphs 35 to 41are irrelevant since they assume that legislation and enforcement are the answer. Admittedly they respond to specific points in the consultation but who drew up such a specific, unrealistic set of criteria?
Paragraph 42 the start of a section about Public Health Implications makes massive but unsubstantiated statements that ignore broader problems. It states that the Government objective is to reduce smoking prevalence rates and tackle health inequalities – that is ok but so many assumptions are made in the following paragraphs. ----Paragraph 47 ---The large proportion of non-food premises are in lower socio/economic areas and they suggest that anything but a total ban would reduce the impact of the legislation on smoking prevalence rates in these areas and widen health inequalities. ---Where’s the proof?
Now comes evidence from RIA but no specific reference base is mentioned.
There is no recognition of social costs. Predictions of success are made but specific evidence is available and that from Ireland especially illustrates that they were wrong!!! Great that financial costs can be assumed but they provide ‘no assessment to the reduction in prevalence rates that would be achieved if the Government’s proposed exemptions were adopted.’ Why not?
Yet again they use the cheap shot (para 51) of attacking ‘tobacco opinion’. At this stage I suggest that the majority of smokers will not quit, the habit will be driven underground’ and no consideration is given to possible consequences.
The reference in Paragraph 51 http://www.legacy.library.ucsf.edu/cgi/getdoc?tid=qhs55e00&fmt=pdf&ref=results is dated 1992 and omitted the next sentence that might the ASH quote into context --"Only 6.4% - 10.3% of smokers face total workplace prohibition". ASH suggests that quitting rates are greater when restrictions are increased yet the extreme, a total restriction, as in Ireland has thrown up results that directly challenge this. Maybe ASH should not attempt to apply statements from 1992 when smoking prevalence was far higher and workplace restrictions were much lower than in 2005. This does not confirm their assertion. Evidence might more properly suggest that total bans are a step too far and quite logically might cause public outcry and an anticipatable backlash.
Paragraph 52 –Unintended outcomes…. Some pubs may choose to give up food and concentrate on wet sales – so what. The wish for any business person is to survive and offer what the customer wants –This however doesn’t fit into the total ban wanted by ASH!!
Paragraphs 53 to 59 refer to the ASH commissioned legal opinion which they rely on quite heavily as in the letter referenced 40.
Paragraph 57 becomes quite laughable “Apart from bar staff in exempt premises, other classes who might be held to be discriminated against by exemptions for non-food pubs and clubs include pregnant women (and by extension all women of childbearing age, who may be in the early stages of pregnancy and unaware of the fact) since secondhand smoke is a particular risk to the foetus and therefore these women would not be able safely to use the services and facilities provided by such pubs and clubs.” No one has a right to use all facilities – it is still up to the provider to decide who enters their premises. If the premises were smoke friendly these ‘discriminated against people’ are free to choose whether they enter or not.
38 An internal memo from 1992 –a touch outdated as mentioned re Para 51
39 One of ASH’s own publications picking out the bit they want –but so what if pubs choose beer not food
40 This was a (threatening)
letter from ASH asking companies to review their smoking policy
–no reply
41 The ‘unquestioned’ Scoth Report
42 Refers to the Irish Act 2002 and sounds fair enough but maybe we should look at some of the less successful aspects of the Irish ban (those that never seem to make the papers). Apart from social & economic problems it appears smoking prevalence is on the increase and other aspects such as the reduction of smoking in the home and car is less than that in the UK where there is no ban (yet). Maybe the Irish Act is not the best answer???
43 Of course ASH support the stated programs so would anyone but I couldn’t find any recommendations for accommodating long stay patients who, despite all smoking therapy and medical help, were unable to give up smoking.
44 45 46 No need for comment re herbal cigarettes.