National Assembly for
Wales / Cynulliad Cenedlaethol Cymru
Health
and Social Care Committee/
Y Pwyllgor Iechyd a Gofal Cymdeithasol
Public Health (Wales) Bill / Bil Iechyd y Cyhoedd (Cymru)
Evidence from Bevan Foundation – PHB 69 / Tystiolaeth gan Sefydliad Bevan – PHB 69
145a High Street
Merthyr Tydfil
CF47 8DP
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4th September 2015
Dear Chair,
Evidence on the general principles of the Public Health (Wales) Bill
Introduction
1.
The Bevan Foundation
develops ideas to make Wales fair, prosperous and sustainable. It
is a registered charity and is independent of government, any
political party or line of thought. We welcome the
opportunity to submit a response to the Committee’s inquiry.
We have also submitted evidence as part of a group led by Tenovus
Cancer Care.
2. Our submission addresses your specific questions on smoking and e-cigarettes and on toilets, and your general questions on the approach taken in the Bill.
Smoking and e-cigarettes
3. Our research on smoking cessation in Wales[1] argued that the end to the downward trend in smoking amongst the population as a whole and the high prevalence and upward trends in smoking amongst the least well-off require a new approach to smoking cessation. This would involve:
a. Regarding smoking as an addiction not a lifestyle choice.
b. Active intervention by a wide range of health professionals to support quitting.[2]
c. Active use of a range of quit aids to reflect smokers’ circumstances.[3]
d.
Creating a
no-smoking culture and environment particularly amongst groups at
greatest risk of smoking.
4.
The use of
e-cigarettes in enclosed public places is a minor issue compared
with the scale of the smoking problem, and we are not convinced
that a ban is the right focus for public health in Wales.
5.
The rationale for
the 2007 ban on smoking in enclosed public places was to reduce the
harm from second-hand smoke, and for this reason it has had high
levels of compliance. The Bill’s proposals change the
rationale of a ban: we are not aware of evidence that second-hand
e-cigarette vapour causes harm, and it is hard to see how smoking
conventional or e-cigarettes in open public spaces e.g. a hospital
car park harms others.
6.
Indeed, the evidence
suggests that e-cigarettes are less harmful to the user than
smoking, and the evidence that their use ‘normalises’
smoking is weak. As an NRT product (albeit unregulated at present)
e-cigarettes can help with quitting especially for those who do
want to engage with smoking cessation services.
7.
We understand the
wish to be cautious about the use of a new nicotine device, but
believe that the resources involved in implementing and enforcing a
ban would be better used on promoting more effective stop smoking
support.
Provision of
Toilets
8.
We welcome the
inclusion of public toilets in the Bill. Access to toilets is a
much neglected issue of importance to everyone but especially
children, older people and people with certain health
conditions.
9.
We are concerned
that the proposed requirement for each authority to prepare and
publish a toilet strategy adds to local authorities’ paper
mountain without resulting in the provision of more toilets.
Instead, we suggest that the Bill is less cautious and places a
direct requirement on public and private bodies alike to provide
and maintain public toilets in places open to the public, such as
shopping centres, bus stations, sports venues and town centres. The
requirement could be proportionate to footfall, e.g. one toilet per
X visitors.
10.There should be an explicit requirement that toilets are accessible to disabled people and are open for specified hours.
Priorities for public
health
11.Wales has one of the least
healthy populations in the UK, with high levels of smoking, obesity
and alcohol misuse. A Public Health (Wales) Bill is a unique
opportunity to tackle the underlying environmental and behavioural
causes of poor health in an innovative way which meets Wales’
needs.
12.We would like to see the Bill
take a coherent and broad approach to promoting public health,
bringing together action to address all the key
challenges.
13.The Bill should include the
general principles that underpin the Welsh approach to public
health, and should:
a.
Recognise that poor
public health is much more than ‘lifestyle choice’
– it is caused by structural problems in the
economy and society, including low income, low levels of education,
poor housing, and unregulated promotion of unhealthy products and
services.
b.
Recognise the deep
inequalities in health associated with socio-economic group,
gender, age, ethnicity and disability.[4]
c.
Ensure the
infrastructure for healthy living is available e.g. adequate
housing, access to affordable and nutritious food, access to sport
facilities.
d. Combine positive incentives for good health behaviours with restrictions on others.
e. Be willing to innovate and test new interventions.
Other areas of public health
14. There are many
other areas of public health that are critically important,
including:
a. Nutrition (including obesity)
b. Alcohol and substance misuse
c. Damp, cold and over-crowded housing
d. Physical inactivity
e.
Sexual
health
15. These issues
are arguably more important than where people use e-cigarettes and
we would welcome their inclusion in a comprehensive Public Health
(Wales) Bill.
Yours sincerely
Victoria Winckler
Director
CC:
Minister for Health and Social Services
Deputy Minister for Health
Chief Medical Officer