SUBMISSION TO PORTFOLIO COMMITTEE ON HEALTH TOBACCO PRODUCTS CONTROL ACT OCTOBER 1998
The Cancer Association of South Africa is a non-government organisation, representing 366 staff, 500 members and over two thousand volunteers. It is a non-profit organisation which is wholly funded by public donation. It has 48 offices and is represented in all 9 provinces of the country.
The mission of the Cancer Association is to prevent and fight cancer and its consequences in partnership with all South African communities.
Tobacco smoke contains 43 known carcinogens. It is thought to cause about one third of all cancers. Smoking is a major cause of cancer of the lung, bladder, mouth, esophagus and larynx. It is also a contributing factor in cancer of the kidney, pancreas, stomach, cervix and blood.
In being true to our mission, the Cancer Association has lobbied government over the past few years to introduce further tobacco control measures. We fully support the proposed amendments to the Tobacco Products Control Act as we believe these measures will prevent many people from developing cancer in the future.
We have collected a total of 55 688 signatures from members of the public in support of the ban on tobacco advertising. These signatures have been collected from diverse communities in all provinces. We have also received a total of 678 phone calls from people wishing to state their support for a ban on tobacco advertising.
We believe that if a ban on tobacco advertising is introduced in South Africa there will be a number of positive outcomes. These are described below.
A ban on tobacco advertising will:
1. REDUCE TOBACCO CONSUMPTION
The experiences of other countries show that bans on tobacco advertising, when implemented in the context of a broader tobacco control programmes, achieve their desired public health purpose: they result in declines in tobacco consumption with significant benefit to the health of the population.
The former Norwegian Minister of Health has said:
"there is no doubt that the Norwegian advertising ban has had a clear and substantial influence on total consumption in general and smoking rates among school children in particular. In my view, the reduction brought about by the advertising ban will have a positive and marked impact on the future incidence of smoking related diseases and consequent mortality."
The experiences of Norway, Finland, France and New Zealand where effective advertising bans have been in place for several years have provided good indications that tobacco advertising bans do work - cigarette sales in these countries decline by between 14% and 37% from the year advertising was totally banned to 1996. In each case, the banning of tobacco advertising was followed by a fall in smoking on a scale that could not be reasonably attributed to other factors.
Country Date of Advertising ban Drop in consumption to 1996
Norway 1975 26%
Finland 1977 37%
New Zealand 1990 21%
France 1993 14%
Total bans on tobacco advertising are in force in 27 countries. Partial bans or restrictions exist in many others. Partial bans have shown to be far less effective in reducing consumption than total bans as they do not succeed in radically altering the social environment so that it is less conducive to smoking. The tobacco industry has proven to be extremely creative in promoting cigarettes in the face of partial regulations and has simply shifted resources to those forms of marketing still allowed. A rigorous regression analysis of tobacco pricing and advertising controls in 22 countries revealed that the higher the prices and more stringent the advertising controls, the greater the decline in tobacco consumption. (Laugesen and Meads C 1990) Do tobacco advertising bans lower consumption? Tobacco advertising restrictions price, income and tobacco consumption in OECD countries, 11960-86. In: Dursto, Jamrozik K, eds., Tobacco and health 1990, The global war:
Proceedings of the Seventh World Conference on Tobacco and Health, Perth, Health Department of Western Australia, pp.126-129 pg. 173 WHO).
The experience of other countries has also shown us that there is no reason to believe that government will use a ban on cigarette advertising as a precedent to ban the advertising of a wide range of other products. The 'slippery slope' argument, often offered as a warning against a ban on tobacco advertising by the industry, has failed to materialise anywhere in the world.
A ban on advertising will:
2. PROTECT CHILDREN
Since the release of secret, internal industry documents in the United States, we now know that tobacco companies deliberately target children as young as 14 in their marketing campaigns. The reasons for this are twofold:
a. Because the vast majority of smokers start before the age of 18 and develop brand loyalty early on, it is critical for tobacco campaigns to secure as large a share as possible of the teenage market.
A memo written for Reynolds states: "The Camel brand must increase its share of penetration among the 14-24 age group.. .which represents tomorrow's cigarette business" and that "If our company is to survive and prosper over the long term we must get our share of the youth market." (RJR memo, 1970)
Another company states: "The base of our business is the high school student."
b. Children are a strategically important market for another reason: they are the chief source of new consumers for the industry, which each year must replace the many thousands of smokers who quit or die from smoking related diseases.
In the industry's own words:
"Younger smokers are critical to R J Reynold 's long term performance and profitability. RJR should therefore make a substantial commitment of manpower and money dedicated to younger smoker programmes... if younger adults turn away from smoking, the industry must decline, just as a population which does not give birth, will eventually dwindle. (RJ Reynolds Confidential Marketing report, 1984).
The primary means by which the industry actively recruits new young smokers is by marketing. Tobacco advertising aimed at youth sets out to present smoking as a means of initiation into the adult world and a symbol of social success, sex appeal, independence and peer acceptance.
A marketing document for the Camel brand states, for example, that it's advertising must create: "the perception that Camel smokers are non conformist, self confident and project a cool attitude, which is admired by their peers."
While the aspirational imagery in tobacco advertising encourages adolescents to experiment with cigarettes, addiction ensures that they invariably become regular or life long users, well before they can make a mature and informed adult choice.
One tobacco industry document describes this process in the following way: "A cigarette for the beginner is a symbolic act: I am no longer my mother's child, I'm tough, l am an adventurer I'm not square . . As the force of the psychological effect takes over to sustain the effect. (Report to the Board of Directors of Phillip Morris).
A ban on tobacco advertising will free children from the relentless commercial pressure on them to take up smoking. This freedom is a more important freedom than the freedom of tobacco companies to portray a dangerous and addictive product as glamorous and socially acceptable.
A ban on tobacco advertising will also remove a source of continual reinforcement and false reassurance to smokers that smoking is socially acceptable, normal and even relatively harmless. Furthermore, an environment without tobacco advertising will make it easier for those smokers who want to quit to maintain their resolve.
A ban on tobacco advertising will:
3. ENHANCE FREEDOM OF SPEECH
A secondary benefit of a ban on tobacco advertising is that it would remove the financial incentive for the media to avoid reporting on the health risks of tobacco. Research overseas and in South Africa has found that the dependence of the media on tobacco advertising revenue has a censoring effect on the editorial policy of women's magazines and newspapers. A MRC study in 1994 showed that the extent of coverage of the smoking issue in women's magazines was closely related to the amount of revenue received by the tobacco industry for advertising. (Yach, D and Paterson, G. Tobacco advertising in South Africa with special reference to women's magazines. Safr Med J 1994).
Clear evidence of such undue influence on editorial opinion was seen last year in South Africa when a Rembrandt group company withdrew one million rands worth of advertising from the Star newspaper following an editorial which supported the regulation of tobacco advertising. The Star has, not surprisingly, avoided stating such support since.
The sponsorship of sport by the tobacco industry has a similar effect:
contractual obligations and fear of losing financial support effectively prevent sports personalities and role models from supporting tobacco control measures or becoming logical and willing spokespeople for health education campaigns.
A ban on tobacco advertising will:
4. LEVEL THE PLAYING FIELDS FOR HEALTH EDUCATION
In the current climate, health education on the risks of smoking simply cannot compete with tobacco advertising.
Firstly, the Department of Health cannot ever hope to match the industry's expenditure on tobacco marketing.
Secondly, health education cannot have much impact in a situation where there is pervasive tobacco advertising: a child may learn of the dangers of smoking in a classroom, but when he or she leaves the school, he or she is confronted with a multitude of messages about smoking which contradict exactly what was learnt during the lesson.
Furthermore, educating children about the health risks of smoking which occur during adulthood, has little and real relevance to them.
The promise of immediate, psychological benefits of smoking as portrayed in tobacco advertising has far greater appeal.
Educational programmes and anti smoking campaigns remain very important, but without strong public policies to support them, they can only have very modest results. A ban on tobacco advertising will allow health education to play a more meaningful role.
Unique treatment for a unique product.
The tobacco industry often defends tobacco advertising by arguing that if tobacco products are legal, it should be legal to advertise them.
This arguments plays on a historical accident. Tobacco is only legal today, because it was introduced on wide scale decades before its health dangers were understood. Given current standards of product safety regulation, it would be virtually impossible to bring tobacco products on to the market today. Tobacco is a unique consumer product: it kills up to one in two of its users when used exactly as intended by the manufacturers, and is highly addictive. No other product of comparable danger remains so unregulated and so vigorously promoted through the mass media.
It would make not sense for legislators to now outlaw a product which is used by approximately 7 million South Africans, but every effort should be made to subject tobacco products to strong regulation. Given the substantial harm caused by tobacco, banning its advertising and promotion is a reasonable middle ground.
We sincerely hope the Portfolio Committee will act in the interest of public health and adopt this Bill and we thank you for giving us the opportunity to present our submission to you.