Tobacco Harm Reduction (THR) presents a promising approach to mitigating the health risks associated with smoking. However, effective regulation by governments is essential to ensure the safety, efficacy, and responsible marketing of reduced-risk tobacco products. In this discussion, we dive into the intersection of THR and government regulation, highlighting the importance of a balanced approach to tobacco control.
Understanding THR encompasses a range of strategies aimed at reducing the harm caused by tobacco use, including the promotion of alternative products such as e-cigarettes, heated tobacco products, and nicotine replacement therapies. These products offer smokers potentially less harmful alternatives to traditional cigarettes, thereby aiding in smoking cessation efforts and improving public health outcomes.
In a recent interview, Bahman Safakish, Managing Director of the Pan African Region for Philip Morris International, said: "Our advocacy for harm reduction stems from our commitment to the smoke-free future. We believe in providing legal age smokers with scientifically substantiated alternative products that offer a reduced risk profile compared to traditional smoking, therefore we believe it is important to raise awareness and understanding about Tobacco Harm Reduction among African legal age smokers, (...) the African legal age smokers should have the choice and access to scientifically substantiated novel Smoke Free Products and shouldn't be deprived or left behind."
Government regulation plays a central role in shaping the landscape of tobacco harm reduction. Regulatory frameworks must strike a delicate balance between protecting public health and fostering innovation and consumer choice. Key areas of regulation include product standards, health warning requirements, marketing restrictions, taxation, etc.
"There is a crucial need for pragmatic recognition of the potential merits of these products as a tool for reducing harm and meeting public health benefits and the need for a differentiated treatment of Smoke Free Products from combustible tobacco products. While they are not risk free and contain nicotine which is addictive, providing access to, and information about scientifically substantiated Smoke Free Products to adult smokers who would otherwise continue to smoke allows them to make an informed decision to move away from the most harmful form of nicotine consumption, combustible tobacco products", Safakish added.
Governments must also establish robust regulatory frameworks to ensure the safety and efficacy of reduced-risk tobacco products. This includes stringent product testing, ingredient disclosure, manufacturing standards, and post-market surveillance to monitor potential health effects and emerging risks. By setting clear guidelines and standards, governments can safeguard consumer health and confidence in reduced-risk products.
Regulation of reduced-risk products must prioritize measures to prevent youth initiation and nicotine addiction. This includes strict age verification measures, marketing restrictions targeting youth audiences, and limitations on flavourings and packaging designed to appeal to minors. Governments play a critical role in enforcing these regulations and addressing emerging trends in youth tobacco use.
Government regulation should aim to strike a balance between promoting access to reduced-risk products for adult smokers seeking alternatives and preventing unintended consequences such as renormalization of tobacco use or dual use among non-smokers. Flexible regulatory approaches, informed by scientific evidence and public health principles, can adapt to evolving trends and technologies in the tobacco market.
Effective regulation of reduced-risk products requires collaboration among governments, public health organizations, industry stakeholders, and consumer groups. Transparency, dialogue, and stakeholder engagement are essential to developing evidence-based policies that prioritize public health while respecting individual rights and choices.
The Kenyan example of inclusion in a regulatory process
In Kenya, the Ministry of Health in April 2024 announced that it was inviting submissions from the public on proposals to apply graphic health warning labels on tobacco products - which, according to the draft graphic warnings shared by the Ministry, include nicotine products like vapes and pouches. Graphic Health warnings currently appear on cigarettes in Kenya, but there is concern by public health and smoking-cessation campaigners that warnings on tobacco-free nicotine products could prevent smokers from switching to safer alternatives.
"Interested members of the public, stakeholders, and organizations are invited to submit any comments, views, or representations regarding the draft graphic health warnings through public hearings," Health Cabinet Secretary, Susan Nakhumicha, said.
This followed the publication of the draft health warnings for tobacco products by the Ministry of Health, which the ministry proposes to be applied indiscriminately across traditional tobacco products such as cigarettes and across tobacco-free oral nicotine products such as vapes and nicotine pouches.
Public health advocates in Kenya were allowed to challenge the Ministry of Health proposals and presented at public hearings highlighting their concerns that the proposed graphic health warnings for nicotine alternatives are misleading and will deter smokers from switching to potentially life-saving products.
While acknowledging the importance of the new graphic health warnings, public health experts asked the Ministry of Health to consider coming up with harm reduction alternatives when developing proposed graphic health warnings for tobacco products.
The industry stakeholders have also urged the ministry to consider factual, descent-based, and science-based regulation in the formation of the new graphic health warnings on these products and also asked the ministry to come up with a differentiation of product categories when developing proposed graphic warnings.
Scientific evidence indicates that vapes and nicotine pouches are lower risk than tobacco products as they do not burn tobacco , which causes the majority of harm from smoking. Independent research shows that vaping is one of the best tools for helping smokers quit.
"Rather than being a source of harm like other tobacco and oral products, tobacco-free smokeless nicotine alternatives have the opportunity to reduce smoking-related disease. It's important that any future regulatory system recognizes that these products are comparatively low risk", said Dr. Michael Kariuki, lead researcher of the report titled, "Review of the risks and toxicants of smokeless tobacco, areca nut and khat products available in Kenya", by researchers at the University of Nairobi.
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This is a concrete example of inclusive dialogue where all the voices are heard and people affected by the statutory instruments have adequate opportunity to give views.
Governments play a crucial role in educating the public about the potential benefits and risks of reduced-risk tobacco products. This includes disseminating accurate information, promoting smoking cessation services, and debunking myths and misconceptions surrounding THR. By empowering consumers with knowledge, governments can support informed decision-making and promote healthier lifestyles.
"Replacing cigarettes with Smoke Free Products will take time and does not depend only on our efforts. The support of regulators, the scientific community as well as of the society is needed to enable informed decision making of adult smokers who don't quit as well as pragmatic regulation of Smoke Free Products which can not only accelerate the decline of smoking but can further encourage innovation in this space", Safakish went on saying.
Regulation is paramount in ensuring the responsible promotion, distribution, and use of reduced-risk tobacco products within the framework of tobacco harm reduction. By adopting evidence-based policies, fostering collaboration among stakeholders, and prioritizing public health, governments can harness the potential of THR to reduce the harm caused by tobacco use and improve the well-being of populations worldwide.
