tag:blogger.com,1999:blog-3141759542968821728.post8774770180197137880..comments2024-01-01T16:01:35.711+00:00Comments on Dick Puddlecote: Heads The Public Sector Wins, Tails The Public LosesDick Puddlecotehttp://www.blogger.com/profile/01481866882188932892noreply@blogger.comBlogger8125tag:blogger.com,1999:blog-3141759542968821728.post-45025992782621827402014-07-02T14:28:44.359+01:002014-07-02T14:28:44.359+01:00It did stave off an immediate ban, but it did not ...It did stave off an immediate ban, but it did not alter course or cause any serious reflection. After the MLX 364 consultation, the DH assigned MHRA to examine the issue (presumably on the principle that to a hammer every problem look like a nail). Instead of going out for a wider consultation on a full range of real world options, it convened a group of like-minded health and medical grandees to make recommendations as an ad hoc formation of the Committee on Human Medicines (clue in title) - unsurprisingly they came back with the ideas they favoured. Although it took until June 2013 for DH/MHRA to reaffirm its position in favour of medicines regulation, the intervening ~3 years did not allow time to formulate alternative proposals or conduct any sort of consultation. <br /><br />The other troubling aspect of the MHRA consultation was ridiculous framing bias. The three options consulted on were:<br /><br />i. Regulate e-cigarettes as medicines - withdraw products without authorisation in 21 days<br /><br />ii. Regulate as e-cigarettes as medicines - withdraw products without authorisation in 1 year<br /><br />iii. “Do nothing and allow these unregulated products containing nicotine that have not been assessed for safety, quality and efficacy to remain on the market.”<br /><br />Framing of the option iii made it sound irresponsible even though there is a significant body of applicable consumer protection regulation. There are also several other options<br />(eg, making specific safety regulations or product standards) that were not included.Clive Batesnoreply@blogger.comtag:blogger.com,1999:blog-3141759542968821728.post-19903854389623933322014-07-02T14:06:14.231+01:002014-07-02T14:06:14.231+01:00Haha! I misread (spinning too many plates at the m...Haha! I misread (spinning too many plates at the moment).Dick_Puddlecotenoreply@blogger.comtag:blogger.com,1999:blog-3141759542968821728.post-20035071480133722172014-07-02T12:43:40.676+01:002014-07-02T12:43:40.676+01:00As long as they consult and engage,they can then t...As long as they consult and engage,they can then totally ignore<br />Stakeholder engagement<br /><br /><br />During the course of 18 months, the MHRA met with a range of <br />stakeholders. This included importers of electronic cigarettes and the <br />Electronic Cigarette Industry Trade Association (ECITA). Meetings were <br />also held with interests across government to establish a common <br />position. This included those with an interest as regulators, like the <br />Health and Safety Executive and local authority Trading Standards, as <br />well as the Department of Health, the Behavioural Insights Team at <br />Number 10 and the Department for Business, Innovation and Skills. The <br />MHRA has worked closely with NICE on the development of its draft <br />guideline on smoking harm reduction, published in June 2013. The Agency <br />has also met with key players in the public health community, such as <br />leading researchers in the smoking field, Action on Smoking and Health <br />(ASH) and the British Medical Association (BMA), and sought views of <br />medical royal colleges and the NHS.dodderer1noreply@blogger.comtag:blogger.com,1999:blog-3141759542968821728.post-13856890497589637342014-07-02T11:45:43.266+01:002014-07-02T11:45:43.266+01:00Something similar is apparent with consultations o...Something similar is apparent with consultations on e-cigarettes and snus. The 2010 MHRA consultation (MLX364) showed overwhelming opposition (at least as measured in number of responses) visible in support for 'Option 3' here:<br />http://www.mhra.gov.uk/Publications/Consultations/Medicinesconsultations/MLXs/CON065617<br /><br />But the report of the consultation laughably does not even provide totals that would show this, but manages to conclude that the 'right people' are onside: <br /><br />"The response to consultation suggests there is clear support for MHRA regulation, including from medical professional bodies, royal colleges, NHS bodies, public health bodies and trading standards." <br />http://www.mhra.gov.uk/home/groups/es-policy/documents/publication/con111573.pdf<br /><br />Turning to the 2010 EU consultation on the TPD: <br />http://ec.europa.eu/health/tobacco/consultations/tobacco_cons_01_en.htm<br /><br />They asked if the scope of the directive should be extended to included nicotine containing products (e-cigs etc) and whether the ban on snus should be lifted. They work hard to conceal the fact that the overwhelming response was 'no' and 'yes' respectively. See 6.1 and 6.2 in the write up and bear in mind that 96% of responses came from citizens rather than NGOs, industry, government etc.<br />http://ec.europa.eu/health/tobacco/docs/consultation_report_en.pdf<br /><br />In fact you need to go to a more detailed document to find out the actual numbers buried in tables:<br />http://ec.europa.eu/health/tobacco/docs/statistics_compendium_en.pdf<br /><br /><br /><br />91.9% of those responding to the question (75.6% of all responses) favoured no change in the scope of the directive (i.e. not including NCPs),which they duly ignored and brought them into the proposed text to be regulated as a medicines (something extremely damaging that they didn't even ask about). <br /><br /><br />With snus, a mere 84.34% of those responding to the question (69.96% total responses) disagreed with the problem definition. And 83.15% of those responding (68.96% total) supported lifting the ban on snus, which they duly ignored without even blinking.Clive Batesnoreply@blogger.comtag:blogger.com,1999:blog-3141759542968821728.post-45181736362817511092014-07-01T21:03:36.982+01:002014-07-01T21:03:36.982+01:00Well they're hardly likely to promote 'Nat...Well they're hardly likely to promote 'National Smoking Day', are they, DP? Although to be honest, I've never heard of it, either. Every day is 'National Smoking Day' for me, anyway.<br /><br />It would be rather nice to have a day to celebrate the tobacco plant, though, and all the benefits that it can bestow. It might serve to slow down the juggernaut of TC if they have to actually look for some real science to refute the upsides of tobacco. Not that they'd find any...nisakimannoreply@blogger.comtag:blogger.com,1999:blog-3141759542968821728.post-74266172630867526802014-07-01T17:32:15.227+01:002014-07-01T17:32:15.227+01:00Is it? I've not heard so much as a whisper abo...Is it? I've not heard so much as a whisper about it! Perhaps even the antis are getting bored. ;)Dick_Puddlecotenoreply@blogger.comtag:blogger.com,1999:blog-3141759542968821728.post-49485745522769092202014-07-01T17:05:52.449+01:002014-07-01T17:05:52.449+01:00Dear Mr Puddlecote
Today is National Smoking Day ...Dear Mr Puddlecote<br /><br />Today is National Smoking Day - Ist July.<br /><br />Just had the second cigarette of my three a year habit.<br /><br /><br />The sooner our beloved government gives up persecuting smokers the sooner I can give up smoking ...<br /><br /><br />DPDPnoreply@blogger.comtag:blogger.com,1999:blog-3141759542968821728.post-46099007191725586262014-07-01T11:30:24.665+01:002014-07-01T11:30:24.665+01:00It should be blatantly obvious by now,consultation...It should be blatantly obvious by now,consultations,petitions and web based campaigns are as much use as a chocolate kettle. Freedom,liberty and justice<br />are low profile for the funded cliques with their Neo Marxist attitude to Representaive Democracy,their way or no way.<br />If Liberty seeks attention it has to kick not talk,it has to shout not whisper,it has to be vehement in it's confrontation with no place for appeasement.<br />Lets eject the whimpering poodles and let loose the RotweilersJuly 1st Movementnoreply@blogger.com