Submission on the Future of Tobacco Displays in New Zealand

This submission is on behalf of the College of Nurses, Aotearoa (NZ) Inc.  The College is a professional organisation for registered nurses that aims to support excellence in clinical practice, research and education and to work with consumers to influence health policy.
Opening comments:

• The College thanks the Minister and the Ministry of Health for the opportunity to provide feedback on the review of tobacco displays in New Zealand.
• The College supports a complete ban on the retail display of tobacco products.
• Nurses comprise the largest health and health promotion workforce in New Zealand.  Nurses work with the patients and clients who suffer from the effects of tobacco.  The College acknowledges and remembers the thousands of Maori and non-Maori smokers and non-smokers who have died from tobacco related disease [1].  Helping people quit smoking, preventing young people from starting, and advocating for policy changes and healthcare services that promote a smokefree society are an integral part of the health promoting role of nurses.
• Nurse work is evidence based.  The College accepts the evidence provided in the Ministry of Health consultation document about tobacco displays, and the work of researchers from Otago University, Massey University and Whakauae Research Services [2-3].  The evidence shows that tobacco displays increase initiation into smoking by children, and do not support former smokers who want to stay quit.  A ban will help ensure that retail tobacco displays do not undermine the smokefree work of nurses and others.
• In addition, the College views retail tobacco displays as inconsistent with the Smoke-free Environments Act 1990.  A ban would be congruent with the objectives of the Act.
• Finally, the College appreciates the addictive nature of tobacco and its legal status.  The College notes that a ban on tobacco displays would not affect the supply of cigarettes to smokers.

Responses to proposed options:

• The College does not support this option.  Retaining current restrictions relating to tobacco displays in retail outlets is counter productive in terms of the health of New Zealanders.  It ignores the evidence about the effects of retail displays on youth and former smokers [2-3].
• The College supports enhanced education and enforcement for retailers – but only to assist with adapting to a complete ban and to ensure such a ban is adhered to.  A complete ban will be easier to understand and enforce than complex regulations related to size, positioning and content of tobacco displays.

Further limit the maximum size of tobacco displays

• The College does not support further restriction to the size of displays since this ignores the evidence about the effects of retail displays on youth and former smokers [2-3].

Require graphic health-warning posters with a complete display ban

• The College is aware of the evidence of the effectiveness of graphic warnings in prompting quit attempts and decreasing smoking [4].  Because of this it supports their use as the only identification of the availability of tobacco products in retail outlets.
• The College suggests these signs be government approved only.

Limit the number of tobacco displays to one display per retail outlet.

• The College supports a complete ban on tobacco displays, and restricting tobacco sales to one check-out per retail outlet to reduce exposure to tobacco products.

Ban tobacco displays in areas accessible to under-18-s

• The College supports a complete ban on tobacco retail displays, not a partial ban that restricts displays to over-18 environments.
• The partial ban option :
• Ignores the evidence showing that young adults smoke at a higher rate than any other age group [1].
• Fails to address tobacco industry marketing directed at young adults [5]
• Glamourises smoking as an adult only activity.
• May trigger relapse in adults who have quit since many 18+ environments sell alcohol, and smoking and drinking are associated.

Completely ban all tobacco displays

• The College supports a complete ban on tobacco displays.

• Option 3, a complete ban, is the College’s preferred option.  Reasons for this follow:
• A complete ban is supported by evidence that young people and former smokers are adversely affected by tobacco retail displays [2-3]
• It will not disadvantage smokers.
• It will support the smokefree work of nurses and is congruent with the Smokefree Environments Act, 1990.
• It has been implemented in other countries [2].
• It is easier to understand, enforce and monitor than a partial ban.

Information on tobacco products to smokers

• Information on the availability of tobacco products should consist of graphic warning signs.

Tobacco product storage in retail outlets

• Tobacco products should be stored so that they are not visible to customers when they are being retrieved for customers.
• Tobacco products should not be stored in stand alone containers since these would act as displays.

Tobacco product outlets

• There should be one tobacco check-out per retail outlet only.

Vending machine

• Vending machines should be banned as they act as a retail displays.

Enforcement of a complete ban

• Education should be provided to retailers about complying with a complete ban.
• A complete ban on tobacco displays should be enforced, and funding for enforcement should be made available.

References

1. Ministry of Health. 2006. Tobacco Trends 2006: Monitoring tobacco use in New Zealand. Wellington: Ministry of Health.
2. Ministry of Health. 2007. Review of tobacco displays in New Zealand: Consultation Document. Wellington: Ministry of Health.
3. Hoek, J., Gifford, H., Pirikahu, G. et al. (2008). Effects of tobacco retail displays on ex-smokers and lapsed quitters. Report for the Cancer Society and ASH New Zealand.
4. Hammond, D., Fong, G.T., McDonald, PW et al. (2004). Graphic Canadian cigarette warning labels and adverse outcomes: Evidence from Canadian smokers. American Journal of Public Health. 94(8): 1442-1445.
5. Ling, P. & Galntz, S. (2002). Why and how the tobacco industry sells cigarettes to young adults: Evidence from industry documents. American Journal of Public Health. 92(6):908-916.