INNCO Expresses Concerns about WHO and FCTC Direction on COP 9 and Harm Reduction for Tobacco

On 1 February 2021, INNCO submitted comments to the U.K. All Party Parliamentary Group for Vaping Inquiry. INNCO has grave concerns regarding the World Health Organization (WHO) and the Framework Convention on Tobacco Control (FCTC) treatment of low-risk nicotine products and the refusal to recognize harm reduction principles to lower the disease and premature death caused by use of high-risk forms of tobacco such as combustible cigarettes and certain forms of toxic oral tobacco products.

The United Kingdom has taken a pragmatic, humane, and ultimately very effective position on the use of tobacco harm reduction, embracing electronic cigarettes as a complement to traditional tobacco control strategies. As a consequence, England has one of the lowest smoking rates among European countries. As a leader in tobacco harm reduction with a proven track record of success, INNCO believes that the United Kingdom is in a unique position to raise these issues with the WHO and FCTC.

The Inquiry (which can be viewed here) is designed to collect evidence and issue a report on the FCTC’s Conference of the Parties 9, and invites comments on five key areas. INNCO applauds this effort to seriously and honestly explore the following issues identified by the Inquiry:

 

1) WHAT PROBLEM ARE THESE POLICIES AND POSITIONS SUPPOSED TO ADDRESS?

Public Health England has said that alternative nicotine delivery devices which are less harmful than smoking could play a crucial role in reducing the huge burden of smoking. Given this, what is the policy rationale for intervention, and how does it compare or differ from current UK Government policy?

 

2) JUSTIFICATION OF PROPOSALS

 To what extent will COP9 justify any measures it proposes?

 

3) TRANSPARENCY AND CONSULTATION

 What advice and evidence does the WHO receive and how this leads them to their policy positions?

 

4) EXPLORE THE THREAT OF UNINTENDED CONSEQUENCES OF PROPOSALS WITHIN COP9.

To what extent will these proposed measures impact upon health policy in the UK?

 

5) FIT FOR PURPOSE.

(a) To  what extent has the WHO moved away from the FCTC protocol, given its original commitment to Harm Reduction?

 (b) Is it still fit for purpose in its current form given that the Reduced Risk Products available on the market are now so prevalent and have moved in significantly since 2003  when the FCTC came into being?

(c) In crafting the regulatory regime under the FCTC, the objective of the Convention in Art. 3 of the FCTC is instructive as its stated goal is to ‘protect present and future generations from the devastating health, social, environmental and economic consequences of tobacco consumption and exposure to tobacco smoke …. to reduce continually and substantially the prevalence of tobacco use and exposure to tobacco smoke.’