Thursday, 26 May 2022

The European Commission wants to hear from you

The European Commission is asking for feedback on its Tobacco Products Directive (TPD). The call for evidence closes on 17 June 2022 and is intended to "assess to what extent the framework has fulfilled its goals and whether it is able to support a ‘Tobacco-Free Generation’ by 2040". A new TPD is likely to be proposed and brought into law in the next few years.

Anti-vaping lobbyists will be pushing for a ban on e-cigarette flavours, many of them with the help of Mike Bloomberg's $160 million slush fund. These backdoor prohibitionists see it as the best way to wreck the market because politicians don't understand how important flavours are ('tobacco' flavour, which apparently doesn't count as a flavour, is horrible in my opinion and isn't used by most vapers). The TPD exempts e-cigarettes and heated tobacco products (HTPs) from the ban on 'characterising flavours' unless the Commission can demonstrate that there has been "a substantial change of circumstances".

You can interpret that as you like - and the Commission probably will - but a Commission review published last year concluded that there has not been a substantial change of circumstances with regards to e-cigarettes, although the race is closer when it comes to heated tobacco.

The TPD sets out criteria for a ‘substantial change of circumstances’ and calls for the Commission to withdraw certain regulatory exemptions once those conditions are met (a flavour ban for product categories other than cigarettes and RYO tobacco, labelling exemptions). The Commission followed the market shares closely and no product category reached the threshold that would mandate the Commission to trigger this clause in the reporting period. The closest to the threshold are HTPs. Therefore, assessing the current criteria should be considered.

All the feedback is online to read. It's good to see that most of it is calling on the EU to leave vapers alone. For example:
 

Emerging products are key to decrease smoking prevalence in the EU. E-cigarettes are a significant harm reduction tool within the mix of emerging products. I used to smoke a pack of cigarettes a day and thanks to the e-cigarette, I have been tobacco free for the past 3 years. I do not think that my freedom of choice should be further restricted if the e-cigarette prevents me from smoking. I also think that flavours play a very important role to switch. I am mostly using fruit flavours and try to avoid tobacco or menthol flavours which reminds me of the time when I smoked combustible cigarettes. 

To me it is quite simple - I don't smoke cigarettes when I have access to my vape. A lot of people are already addicted to nicotine, vaping is a safer alternative and legislations against it hurt millions of people who already vape. Legislations against vape juice also open up the already huge black market for potential risky vape juice.

Well I will put it plain simple. After 25 years of heavy smoking's and hundred's of attempt's to quit. I discovered electronic cigarettes and I never touched a cigarette again and that was 6 years ago. That's all I have to say, it works, worked for me and for many around me. If you want to solve the tobacco problem you will have to listen to the smokers and ex smokers, is that simple, listen to us instead of those "doctors" radicals, proibitionists etc In case you come up with more regulations and proibition, well I will find my stuff on the black market, inside or outside my country. My body my rules.

 
Feel free to add your two cents. The call for evidence is here. You have to register but it's easy enough. Only an email address is required. You're limited to 4,000 characters (about 700 words) and can add one attachment. Be polite.


Wednesday, 25 May 2022

Vaping is an "environmental disaster", say anti-vaping nuts

The Lancet has published a letter from three French academics arguing for a clampdown on e-cigarettes on environmental grounds. The authors give the game away early on by saying the quiet part out loud...

With the vape market mainly owned by the tobacco industry, it is legitimate to question whether vaping is more eco-friendly than smoking... [my emphasis]
 
Leaving aside the question of whether the vape market is mainly owned by the tobacco industry in reality (it isn't in the UK), the implication is that it would be illegitimate to "question whether vaping is more eco-friendly than smoking" if it was owned by someone else. Why? An environmental issue is an environmental issue, regardless of who makes the product.

Or could it be that the authors are not particularly interested in whether e-cigarettes are eco-friendly, they are just opposed to everything the tobacco industry does?

Fortunately, vape waste is a preventable environmental disaster, but for this disaster to be averted, disposable e-cigarettes must be better regulated. 
 
'Disaster' is a bit of a strong word for vape pens going into landfill, isn't it? Still, what's the solution?
 
In 2020, the US Food and Drug Administration (FDA) banned flavours other than tobacco and menthol for pod or cartridge-based e-cigarettes. Unfortunately, the FDA's policy does not include disposable e-cigarettes.
 
Flavour bans! Of course! The very policy anti-vaping fanatics have been calling for ever since Mike Bloomberg handed out $160 million to NGOs to "fight flavoured cigarettes". What a happy coincidence that this policy will somehow make e-cigarettes more eco-friendly!
 
For the environmental consequences alone, this position should be re-examined.

Yeah, the environmental consequences. Sure. That's what you're bothered about.

The same people wrote a letter to the Lancet in 2018 warning about people using e-cigarettes to consume cannabis. Guys, stop going round the houses and just admit that you don't like vaping.


Tuesday, 24 May 2022

E-cigarette use costs $15 billion a year?!?

Anti-vaping quackademics from California's Bay Area are at it again...
 
E-Cigarette use costs US $15 billion per year, reports UCSF in first study of its kind 

Use of electronic cigarettes costs the United States $15 billion annually in health care expenditures — more than $2,000 per person a year — according to a study by researchers at the UC San Francisco School of Nursing

The study, published on May 23, 2022 in Tobacco Control, is the first to look at the health care costs of e-cigarette use among adults 18 and older.


UCSF plus Tobacco Control is the perfect recipe for crank activism and this study is everything you might expect.
 

“We weren’t able to look at e-cigarette use among youth under 18 in this study,” Max said. “However, if more young people continue to take up vaping and keep on using this product when they become adults, the negative impacts on health care costs are likely to increase over time.” 

The authors called for continuing efforts to control tobacco use among youth in order to reduce illness and health care costs associated with e-cigarette use. 


Of course they did. That was the whole purpose of writing the study. That is the whole purpose of any study about vaping that is produced by Californian 'public health' researchers.

The study itself leaves a lot to the imagination. The authors seem to have compared the healthcare use of e-cigarette users to that of lifelong non-smokers, although their methodology is far from clear. The glaring problem with this comparison is that the obvious confounding factor is prior smoking. The overwhelming majority of vapers who are old enough to consume a non-trivial amount of healthcare will be ex-smokers or dual users who have a long history of smoking. 
 
Only 0.2 per cent of their study sample were exclusive e-cigarette users. The proportion that would have been exclusive e-cigarette users and lifelong nonsmokers would have been virtually zero. (It also means, if these researchers' calculations were correct, that if every adult in America used e-cigarettes, the associated healthcare costs would be $7.5 trillion, which is a third of the country's GDP.)

Failing to control for past smoking is a common flaw in studies which try to make vaping look like a major health threat. The authors of this study don't even mention it. They just assume that e-cigarettes are unhealthy.
 
...our model assumed that e-cigarette use has impacts on healthcare utilisation through health effects, that is, e-cigarette use causes poorer health, which in turn causes more healthcare utilisation
 
If that's what you assume, that's what you're going to find.


UPDATE

The Science Media Centre have found a couple of experts to comment on this trash. Worth a read. 

Prof Peter Hajek, Director of the Tobacco Dependence Research Unit, Queen Mary University of London (QMUL), said:

“This is a baffling piece of work. The authors report that people who use e-cigarettes have poorer health and incur higher health costs than non-smokers, but it is not clear why they assume that the excess health expenditure incurred by smokers who are trying to limit their smoking by using e-cigarettes (often because of acute health problems) is caused by their recent vaping rather than by their lifetime smoking. This is like claiming that the extra health expenditure incurred by people with broken legs is caused by using crutches.”




Monday, 23 May 2022

A swift half with Johnny Kitson

There's an episode of The Swift Half that I forgot to mention on here at the time. It's with Johnny Kitson who is a superforecaster and an interesting man! Check it out.



Friday, 20 May 2022

Jamie Oliver addresses a small gathering in London

Contemptible multi-millionaire Jamie Oliver turned up to speak to the staff of his front group Biteback and a handful of journalists in Westminster today in a protest against affordable food. Waving a high-sugar, high-fat, high-calorie luxury dessert, the failed restaurateur demanded the government ban multibuy deals such as '3 for 2' and '50% extra free' on food that contains modest quantities of fat, sugar and salt. The government is doing this anyway, just a year later than over-the-hill chef would like.
 
 
I wrote about this issue for Spiked in the week, so I will leave Tom Harwood to summarise the day's events. I particularly enjoyed the last 15 seconds of this.



Wednesday, 18 May 2022

Do nanny state policies work at all?

Carl Phillips and Marewa Glover have produced a very interesting study assessing the efficacy of anti-smoking policies in the USA. With the exception of tax rises, they find very little evidence that any of them have made any measurable difference to smoking rates and that most, if not all, in the fall in smoking rates would have happened without any legislation. 
 
Why, then, have smoking rates been declining for decades? Their theory is that it began with the "information shock" of public health authorities, such as the Surgeon General, declaring smoking to be a major health risk in the 1960s. This led to an immediate decline in smoking rates which has echoed down the years through inter-generational effects. As they note, the most robust predictor of individual smoking initiation is parental smoking. When parents quit or never start smoking, their offspring are less likely to smoke.  

And so, by their calculations...
 

Results: About one-third of the observed prevalence decline through 2010 can be attributed solely to fewer parents smoking after the initial education shock. Combining peer-group cessation contagion explains well over one-half of the total historical prevalence reduction. Plausible additional echo effects could explain the entire historical reduction in smoking prevalence. 

Conclusions: Ongoing anti-smoking interventions are credited with ongoing reductions in smoking, but most, or perhaps all that credit really belongs to the initial education and its continuing echoes. Ensuring that people understand the health risks of smoking causes large and ongoing reductions. The effect of all other interventions (other than introducing appealing substitutes) is clearly modest, and quite possibly, approximately zero, after accounting for the echo effects.

 
I recommend reading the whole study, but the following section should give you the gist of what they mean by echo effects:
 

We know that choosing to smoke is socially contagious – the more people around someone who smokes, particularly their parents, the more likely they are to start smoking.1 Parental smoking is the most consistent strong predictor of whether a teenager (of a particular age, in a particular population) will start smoking. Smoking prevalence among siblings, peer groups, and the wider community affects uptake via overt and subconscious social signaling. All of these are taken as fact in the scientific literature and in Phillips et al tobacco control politics, where they are cited as motivation or points of leverage for interventions. But one important implication – that a downward shock or trend in smoking prevalence will, by itself, cause further downward trending for more than a generation – is generally ignored. 

Similarly, smoking cessation is a contagious behavior. This is particularly clear for switching to a lower-risk alternative, wherein the person quitting smoking demonstrates to their social contacts that the choice is appealing and educates them about the alternative. However, even if the choice of cessation method is not affected by social-contact education, the demonstration effect of quitting itself is still powerful. Seeing a friend quit smoking takes it from being an abstract possibility to a concrete example of success. In addition, simply having fewer people who smoke in one’s social circles encourages quitting. Each of these, and all of them together, creates a positive feed-forward effect from any smoking reduction. 

Thus, a one-time permanent downward shock in the popularity of smoking – like that caused by initial education about the harms from smoking – causes a long tail of transition to a new lower equilibrium, echoes of the initial shock. If many people quit smoking, then many more who would have started smoking had they come of age earlier will not do so and others will be motivated to quit over time. The subsequent cohorts coming of age not only will experience the effect of the downward shock, but also be subject to less social contagion. There will be a new equilibrium, but it will only be reached slowly, with a substantial portion of the effect taking more than a generation. This will happen with or without any further efforts to discourage smoking. Subsequent interventions could still have effects beyond the secular trend toward a new equilibrium, of course, but it makes no sense to try to quantify those effects without trying to estimate the background effects of the echoes alone.

 
Phillips and Glover stress that it cannot be proved either way whether the bulk of anti-smoking regulation has made a difference to smoking rates. They present a hypothesis and a series of models. But it is an intriguing hypothesis and I have often wondered to what extent the tobacco control lobby has been dining out on a decline in smoking rates that would have happened without them (and for many years did happen without them). 

That would certainly help explain why tobacco-style regulation fails to work when applied to other activities. These policies tend to focus on the Three As - affordability, advertising and availability - but whilst it is Econ 101 to note that higher prices tend to lead to lower consumption, albeit at the expense of consumers, the evidence for the other two As is remarkably thin on the ground. 

Take alcohol. A 2019 systematic review titled 'Do alcohol control policies work?' and written by two members of the South African Medical Research Council concluded that ‘[r]obust and well-reported research synthesis is deficient in the alcohol control field despite the availability of clear methodological guidance.’ The policies examined included restricting alcohol advertising and restricting on- and off-premise outlet density.

With regards to advertising, a Cochrane Review, which is usually considered definitive, found 'a lack of robust evidence for or against recommending the implementation of alcohol advertising restrictions'. 

Even the authors of Alcohol: No Ordinary Commodity, the bible of the secular temperance movement, were only able to make a limp case for advertising bans.

‘Imposing total or partial bans on advertising produce, at best, small effects in the short term on overall consumption in a population, in part because producers and sellers can simply transfer their promotional spending into allowed marketing approaches. The more comprehensive restrictions on exposure (e.g. in France) have not been evaluated… The extent to which effective restrictions would reduce consumption and related harm in younger age groups remains an open question.’


A systematic review published in 2012 tried very hard to find evidence to support orthodox, supply-side anti-alcohol policies. It was written by dyed-in-the-wool 'public health' activists, including Mark Petticrew and Martin McKee, but they really struggled to find what they wanted. 

On advertising, they found seven studies which 'provided inconclusive results for the influence of advertising on alcohol use'. 

There wasn't much evidence and a lot of it was of poor quality, but...

A study rated as ‘strong’ in the quality assessment found no significant association between exterior advertising in areas near schools and adolescent drinking.

 
The authors nevertheless concluded that...
 

In general, the findings of this review are consistent with reviews on wider alcohol availability (Popova et al., 2009), which have found that availability has a strong influence on alcohol use.


But this is mere editorialising. The evidence they discuss in the paper doesn't show that at all.

In general, the results of this review are similar to those found in previous reviews (Babor et al., 2003)—studies show mixed results but strongly indicate that greater exposure to advertising is associated with higher levels of alcohol use.


How can mixed results strongly show anything?

They also looked at availability - including licensing hours and outlet density - and again struggled to find evidence to support their priors. They found '21 studies on the influence of availability of alcohol from commercial sources on alcohol use', but, alas...

Overall the findings provided inconclusive results for the influence of availability on alcohol use, although some studies indicated that higher outlet density in a community may be associated with an increase in alcohol use.

With regards outlet density specifically:

For off-premise outlets (such as shops), eight studies found no significant association but there is some indication that a higher density of off-premise outlets may be associated with an increased likelihood of heavy drinking. For on-premise outlets (such as bars and restaurants), results were also mixed but there is some indication that a higher density of on-premise outlets may be associated with an increase in the likelihood of drinking and heavy drinking. 

 
'Some indication' and 'may be associated' are not phrases to fill policy-makers with confidence and are a far cry from the bald assertions of efficacy you hear from the likes of Alcohol Focus Scotland when they appear on television.

As for local changes to licensing regulations...

Four studies (with four effect estimates) looked at the influence of local licensing changes on alcohol use, which included banning alcohol sales and making changes to the hours, days and volumes of alcohol sales that were licensed. They indicate that licensing restrictions may reduce alcohol use, but the evidence is not very robust.


This, remember, is from a group of people who are absolutely committed to clamping down on the advertising and availability of alcohol, and who are putting the best possible spin on the evidence.

The story is much the same when you look at food/obesity. You don't see many randomised controlled trials in the nanny state wing of public health but we have one for the policy of food reformulation. And guess what? It doesn't work. 
 
Consumption of sugar-reduced products, as part of a blinded dietary exchange for an 8-week period, resulted in a significant reduction in sugar intake. Body weight did not change significantly, which we propose was due to energy compensation.

We also have a RCT for intensive anti-obesity interventions with children over a period of years and they don't seem to work either.

It is often claimed that limiting the number of fast food outlets will reduce obesity, but dozens of studies have looked at the association between proximity to fast food outlets and obesity. The vast majority suggest that there isn't one.

This week saw the publication of a systematic review of food advertising. Again, it was written by fervent interventionists and its lead author is the activist-academic Emma Boyland who is responsible for a fair chunk of the literature herself. She is now not only a professor but also an advisor to thee World Health Organisation.

 

 
You won't be surprised that she concludes that governments should restrict food advertising, but it is difficult much of a justification for this in her study.

Evidence on diet and product change was very limited. The certainty of evidence was very low for four outcomes (exposure, power, dietary intake, and product change) and low for two (purchasing and unintended consequences).

Shown in a graphic, the evidence can most charitably be described as 'mixed'.
 
 
Even the press release had to come clean:
 

Their research, published in JAMA Pediatrics, found that food marketing was associated with significant increases in food intake, choice, preference, and purchase requests. However, there was no clear evidence of relationships with purchasing, and little evidence on dental health or body weight outcomes.


If food marketing doesn't have an effect on 'body weight outcomes', there is, of course, no point in restricting it. Obesity and dental health are the only outcomes we're interested in.

None of the studies mentioned above are libertarian hit jobs or industry debunkings. On the contrary, they are written by teammates marking each others homework. The ideological bias and statistical chicanery of many 'public health' researchers will be well known to readers of this blog. If they can't produce persuasive evidence that their policies work, even when reviewed by like-minded friends, we must seriously consider the possibility that none of this stuff does what it is supposed to.


Trying to find common ground on food policy

Sky News have a show presented by Trevor Phillips which tries to find common ground between people who disagree. It is called, reasonably enough, Common Ground and I like the format. It's half an hour long so there is time to get deeper into issues than you get in a standard TV interview. 

Yesterday I was on the show with Thomasina Miers, a restaurateur and food campaigner, to discuss the BOGOF ban and obesity policy in general. She is not a fanatic like Graham 'Mad Dog' MacGregor nor is she a grifter like Aseem Malhotra. She's mostly interested in improving the nutritional quality of school meals, but she also supports things like the BOGOF ban, so we naturally disagreed.

I'm not sure how much common ground we found. Watch it and decide for yourself.