Sunday, 10 June 2012

Finally Some Evidence For Plain Packaging?

You may have noticed, during their campaigning for plain packaging of tobacco, that the tobacco control industry has desperately avoided referring to any real evidence for their claims. Hardly surprising really, since even Australia's prime proponent admits that it doesn't exist.

Sure, they've cobbled together a list of studies written by their mates to create an illusion of certainty, but the general thrust of their campaign so far has been to repeat "children", "cancer", "protect", and "tobacco industry" and hope that no-one calls their emotional bluff.

Via a FOI request, though, it seems they might finally be forced to come up with some concrete figures.

With apologies to those who know about such processes, each piece of legislation must undergo a cost and benefit analysis before becoming law. One such way of doing so is to conduct an impact assessment (IA) which investigates these things. To make absolutely sure that the government isn't just making stuff up, the Regulatory Policy Committee (RPC) is tasked with scrutinising impact assessments and making recommendations.

The documents placed on public display for plain packaging included the initial impact assessment, which the RPC weren't perfectly happy with.

They gave it a traffic light style rating of 'amber' which is explained on their website thus:
AMBER – If an IA receives an Amber flag, this means we have areas of concern with the quality of analysis and evidence presented. These issues should be addressed prior to the IA being finalised so as to improve its contribution to the final decision made.
As you can imagine, I was rather intrigued as to what "areas of concern" they had, so I asked. The 'opinion' is reproduced below.


Firstly, you'll note that the government have blithely dismissed the negative impact on business as 'neutral'. The RPC rightly ask - considering that one of the main reasons tobacco controllers give as justification for plain packaging is that industry profits will be hit hard - for the evidence for this.

That'll be a work of twisted logic when the final impact assessment is released, methinks.

More significantly, though, the RPC wants to know what evidence there is that banning colours and logos will have an effect on smoking rates which will outweigh the burden they are placing on packaging companies, retailers, the public and other businesses including, yes, the tobacco industry (think GDP in a recession here).

Not just any effect either, they want evidence of a "marginal" effect. That being, one which is over and above that 'achieved' by hiding tobacco behind shutters since April 6th.

Now, even absent of other tobacco control industry measures, proving any benefit of plain packaging would be difficult seeing as there is no reference point anywhere in the world. But to offer any 'marginal' benefit when tobacco displays were only hidden by law on April 6th is something only the most disingenuous economist or epidemiologist could offer up with a straight face (and a newly-enriched bank account).

Especially since the Department of Health itself, in its zeal to convince parliament, came up with some heroic financial claims (coupled with distortions of the truth) to bludgeon through banning displays back in 2008/9.


Having already dubiously claimed a 'conservative' saving of 2,786 youth smokers, and a whopping half billion pounds of benefits to the country, they now have to top that for plain packaging in the face of a complete lack of any tangible evidence whatsoever. But with business costs very much quantifiable.

We could be about to see one of the most egregious state abuses of statistics ever seen - that is, by 'proving' a non-existent financial benefit to the country which exceeds the extraordinary hammer blow to businesses and their employees who will be forced to suffer as a result - just to stop you from seeing a colour or bevelled edge on a cigarette packet.

Can't wait to see how they do it. It will be a work of art which could put Dynamo to shame.