The long over-due Post-Implementation Review into Plain Packaging has been very quietly released today.
Many thanks to the Pubic Health Association of Australia for notifying us of the release – the Department of Health itself has no mention of this at its website. I was particularly interested to see this:
PHAA Tobacco spokesperson Professor Mike Daube, who chaired the Australian Government’s Expert Committee that recommended plain packaging said, “This is great news for everyone except Big Tobacco. It shows clearly that the legislation is more than meeting its objectives. We know that smoking in adults and children and cigarette sales are declining, but it is especially rewarding that this meticulous independent analysis attributes part of that decline to plain packaging alone, even within its first three years”.
That is a very important consideration. The reforms in 2012 consisted of two changes:
- Standardised packaging (so-called plain packaging); and,
- Increased size of warnings on packages.
This is how the Department of Health currently describe the PIR (emphasis added):
The Department of Health has engaged Siggins Miller Consultants Pty Ltd to undertake consultation with stakeholders that have been impacted by the tobacco plain packaging measure and to conduct a cost benefit analysis of the measure to inform the development of a Post Implementation Review (PIR). The consultation period runs from 16 February 2015 to 27 March 2015.
Okay – so the PIR is looking only at the plain packaging component of the policy introduced in 2012, and the Public Health Association of Australia tells us that very careful analysis has untangled the two effects and part of the decline in tobacco consumption is due to plain packaging.
Seems very strange thing to say when the PIR itself reports (emphasis added):
Both of the 2012 packaging changes are designed to reduce smoking levels and to work in concert with each other. Indeed, one of the aims of plain packaging is to make graphic health warnings more effective. As noted by Dr Chipty, due to the timing of the 2012 packaging changes it is not possible to identify separately the effects of tobacco plain packaging and enlarged and updated graphic health warnings on smoking prevalence without making restrictive assumptions. The analysis undertaken was, however, able to estimate the impact of both measures working in concert from other aspects of Australia’s comprehensive approach to tobacco control, such as excise increases.
I wonder if the Public Health Association of Australia actually read the report? Maybe they didn’t expect anyone else to read it.
So now we have a small methodological problem: The PIR is meant to report on the efficacy of plain packaging per se. That is what the Health Department promises. That is what Siggins Miller Consultants Pty Ltd tell us is happening in their consultation. That is what the Public Health Association of Australia tells us has been done. The only problem being that the PIR itself tells us that it cannot be done, and has not been done.
As they say in the classics: More to come.