There are many things I like about my job. Writing submissions for 'public' consultations isn't one of them.
I've lost count of how many times we have responded to local, national or international 'consultations':
Consultation on Smoking in Public Places (Greater London Authority Smoking in Public Places Investigative Committee), Consultation on the Future of Tobacco Control (Department of Health), Tobacco and Primary Medical Services (Scotland) Bill (SP Bill 22), Green Paper Consultation (Towards a Europe free from tobacco smoke: policy options at EU level) and many, many more.
Most recently we submitted a response to the Consultation on the Draft Tobacco Control Action Plan for Wales, despite the fact that Forest wasn't on the 'List of Consultees'. Nor was any other consumer organisation. Clearly, the consumer is not expected to have an opinion when it comes to tobacco control. You'll do as you're told, that seems to be the message.
Undeterred, we submitted our response anyway because it's important that we take every opportunity to get our message across. If we didn't we may as well pack up and go home. (And as someone else once said, this is a marathon not a sprint.)
Anyway, I was interested to read another submission to the same consultation.
The Good, the Bad and the Ugly (great title) is Imperial Tobacco's response to the Draft Tobacco Control Plan for Wales and I've singled it out because, unusually for such documents, it's written in plain English and it makes a point of standing up for the sorely neglected consumer.
Here's a taste:
The Government's tobacco control policies have never been subjected to proper evaluation. There is therefore no basis on which to claim that the decline in smoking rates is a direct result of [previous] policies ...
The Plan contains multiple references to unelected anti-smoker groups, indicating an alarming level of undue influence on policy formulation and implementation. For example, ASH Wales are featured no less than 39 times in the 45-page Plan. Such levels of influence from vested interest groups invariably lead to unrealistic, unachievable and ineffective policies ...
Rather than talking up what it sees as the benefits of the smoking ban, we would ask the Government to be more forthcoming in its Plan about the significant unintended consequences, in particular the devastating impact that it has on local community pubs. It is now beyond all reasonable doubt that the smoking ban has had the biggest single impact on accelerating pub closures in the UK since 2007. This provides a stark warning to those considering increasing smoking restrictions in and around pubs ...
Government has no mandate to regulate the private lives of adults who have chosen to use a legitimate product. Furthermore, the evidential base for the introduction of invasive legislation is often absent or highly flawed. For example, one report that was extensively recycled in the media claimed that second-hand smoke was "23 times more toxic in a vehicle than in a home". Such claims are without any substance and have been roundly refuted by the evidence.
The use of the term 'smoke-free' is a deliberate attempt to play down the real intention of the introduction of more restrictions and bans. More bans amount to more restrictions on personal freedoms ... Denormalisation is not a strategy that is pursued in other public areas as it has been shown to be ineffective and counter-productive, alienating those whom policy-makers are trying to influence.
You can download The Good, the Bad and the Ugly here. Definitely worth a read.