Dear VSML friends,
We have received communication from the South African Department of Health (DOH) inviting stakeholders to participate in virtual consultation on the Draft Bill on the Control of Tobacco Products and Electronic Delivery Systems on the 30th March 2021 (letter attached),
Some of the concerns that were raised with the Department were on plain packaging, public vaping, point of sale bans, indoor vaping, online sales and courier deliveries.
Based on the length of time taken in this process, the 21000 submissions received and the socio-economic impact assessment, we seek to understand what changes have been made to the original bill. If there have been amendments made to the proposed bill, we too would like to understand why this has not been distributed and sufficient time provided to prepare submissions.
As a consumer advocacy group, we urge Electronic Nicotine Delivery Systems (ENDS) consumers to register to attend this meeting and use it as an opportunity to register their unhappiness with the proposals contained in the Bill.
After all, as vapers, we chose a safer alternative and the current proposed bill will have a significant impact on our rights to continue with our choices. The same impact will be shared by smokers who wish to switch, but the proposed bill will limit their opportunity to access vital information and make appropriate choices. Therefore we certainly fall into the category of "Whom it may concern"
Details of where submissions need to be forwarded can be found in the letter attached.
Key points to consider when drafting a response.
Though it is understandable and supported that ENDS be regulated, what scientific evidence is the DoH relying on to lump vaping and smoking together?
South Africa should develop a separate law to regulate vaping, underpinned by the scientific fact that smoking and vaping are not the same and have a completely different health profile.
Government should make the starting point of its regulatory proposals the health of smokers who have been provided with a less harmful alternative to smoking. Efforts to regulate smoking and vaping, in the same way, will be counter-productive in reducing the number of smokers and the diseases resulting from smoking.
Government should take account of extensive evidence from the UK, US, New Zealand and Japan which clearly shows that smoking has come down significantly since the advent of electronic nicotine delivery systems. Efforts to regulate ENDS must bear this in mind and recognise that it is a technological invention that holds the potential to significantly reduce smoking, and thereby reduce smoking-related diseases that burden individuals, families, society and public health as a whole.
In the 960 days since the close of public comments on the Control of Tobacco Products and Electronic Delivery Systems Bill of 2018, Government has taken every effort to keep abreast of the ever-growing body of evidence. This would include evidence updates published by:
Public Health England
Cancer Research UK's
British Medical Association
Cochrane Review
Royal College of Physicians
National Academies of Sciences Engineering Medicines
Government should focus its regulations on ensuring that products are safe for consumption by ADULT users.
EVP category is constantly evolving with new technologies regularly introduced, how are consumers supposed to be made aware of new better and safer products if marketing and advertising are prohibited? This would include online platforms and shops, which will be prohibited under the proposed bill.
The evidence to date shows that tobacco-free vapour product emissions do not pose any significant health risks to bystanders and therefore there is no health-related reason to prohibit their use indoors.
We have received communication from the South African Department of Health (DOH) inviting stakeholders to participate in virtual consultation on the Draft Bill on the Control of Tobacco Products and Electronic Delivery Systems on the 30th March 2021 (letter attached),
Some of the concerns that were raised with the Department were on plain packaging, public vaping, point of sale bans, indoor vaping, online sales and courier deliveries.
Based on the length of time taken in this process, the 21000 submissions received and the socio-economic impact assessment, we seek to understand what changes have been made to the original bill. If there have been amendments made to the proposed bill, we too would like to understand why this has not been distributed and sufficient time provided to prepare submissions.
As a consumer advocacy group, we urge Electronic Nicotine Delivery Systems (ENDS) consumers to register to attend this meeting and use it as an opportunity to register their unhappiness with the proposals contained in the Bill.
After all, as vapers, we chose a safer alternative and the current proposed bill will have a significant impact on our rights to continue with our choices. The same impact will be shared by smokers who wish to switch, but the proposed bill will limit their opportunity to access vital information and make appropriate choices. Therefore we certainly fall into the category of "Whom it may concern"
Details of where submissions need to be forwarded can be found in the letter attached.
Key points to consider when drafting a response.
Though it is understandable and supported that ENDS be regulated, what scientific evidence is the DoH relying on to lump vaping and smoking together?
South Africa should develop a separate law to regulate vaping, underpinned by the scientific fact that smoking and vaping are not the same and have a completely different health profile.
Government should make the starting point of its regulatory proposals the health of smokers who have been provided with a less harmful alternative to smoking. Efforts to regulate smoking and vaping, in the same way, will be counter-productive in reducing the number of smokers and the diseases resulting from smoking.
Government should take account of extensive evidence from the UK, US, New Zealand and Japan which clearly shows that smoking has come down significantly since the advent of electronic nicotine delivery systems. Efforts to regulate ENDS must bear this in mind and recognise that it is a technological invention that holds the potential to significantly reduce smoking, and thereby reduce smoking-related diseases that burden individuals, families, society and public health as a whole.
In the 960 days since the close of public comments on the Control of Tobacco Products and Electronic Delivery Systems Bill of 2018, Government has taken every effort to keep abreast of the ever-growing body of evidence. This would include evidence updates published by:
Public Health England
Cancer Research UK's
British Medical Association
Cochrane Review
Royal College of Physicians
National Academies of Sciences Engineering Medicines
Government should focus its regulations on ensuring that products are safe for consumption by ADULT users.
EVP category is constantly evolving with new technologies regularly introduced, how are consumers supposed to be made aware of new better and safer products if marketing and advertising are prohibited? This would include online platforms and shops, which will be prohibited under the proposed bill.
The evidence to date shows that tobacco-free vapour product emissions do not pose any significant health risks to bystanders and therefore there is no health-related reason to prohibit their use indoors.
