April 28, 2011
Send via email (firstname.lastname@example.org)
Office of Regulations and Compliance
Controlled Substances and Tobacco Directorate
Healthy Environments and Consumer Safety Branch
MacDonald Building, Address Locator: 3507C1
123 Slater Street
Ottawa, ON K1A 0K9
Re: Canada Gazette, Part I, Notices and Proposed Regulations, February 19, 2011
Tobacco Products Labelling Regulations (Cigarettes and Little Cigars)
On behalf of the North American Quitline Consortium (NAQC), I would like to thank Health Canada for the opportunity to provide comments on the proposed regulations on required label warnings for cigarettes and little cigars. NAQC strongly supports Health Canada’s regulatory efforts in this area. It is our hope that the final regulations will include 16 health warnings, 8 health information messages and 4 toxic emissions statements along with a pan-Canadian toll free number for provincial quitlines and a cessation Web portal for display on all tobacco packaging. Such a final regulation will have a significant, positive impact on the health of millions of Canadians for years to come.
In its proposed regulation, Health Canada requests comments on its analysis, the proposed regulation, consultations, implementation activities, enforcement and service standards. As an organization with an expertise in cessation services, NAQC’s comments will focus exclusively on the areas related to cessation resources.
NAQC Comments on the Proposed Regulations
1. NAQC enthusiastically supports Health Canada’s development of a new regulation
. A key feature of this would require the display of a pan-Canadian toll-free number for the provincial quitlines and a cessation Web portal on all health warnings and on some of the health information messages. By including these cessation resources on labels, users not only would be reminded of the existence of cessation services and how to access the services every time they look at the pack, they also would be directed to proven methods for quitting. This will help smokers avoid unproven methods that are less likely to help them succeed in quitting.
2. NAQC’s independent research on the impact of the regulations supports the cost benefit analysis that was carried out by Industrial Economics
. We believe that displaying cessation resources on the warning labels would result in a 40-50 percent increase in call volumes to the quitlines and that several thousand additional individuals would quit smoking as a result of the help they receive from quitlines. This would result in significant reductions in the risk of tobacco related illnesses and premature death due to smoking to Canadians. As noted by Industrial Economics, the present value of benefits ranges from $4 billion to $12 billion over 10 years.
3. NAQC strongly supports the government’s commitment to providing financial resources to the provinces and territories that will provide the cessation services linked to the toll-free pan-Canadian quitline number
. In a memorandum of agreement, the government has stepped up to cover the costs of increased call volume as well as the administrative and management costs, and infrastructure costs. The estimated costs of $3.5 million in years one and two, when call volumes are expected to peak, and $2.5 million in years three and four, when the surge in call volume is likely to begin to subside seem reasonable.
4. NAQC strongly supports the government’s memorandum of agreement with the provinces and territories defining the service standard as “providing the same quitline services and service standards to callers who call the pan-Canadian quitline number as those provided to callers who call the provincial or territorial quitline number directly.”
Through this action, the government acknowledges the authority and responsibility of provinces and territories for maintaining their own service standard.
Recommendations for Consideration by Health Canada and the Provinces
The new regulation offer an unprecedented opportunity to decrease the prevalence of tobacco use in Canada. As Health Canada, the provinces and territories plan for and move toward implementation of the regulations, NAQC recommends the following activities for consideration:
1. NAQC recommends that now is the time for provincial quitlines to begin providing medications as part of their services. Such action would increase the benefits that are yielded by the new regulations, increasing the number of successful quits and thereby reducing the risk of premature death due to smoking. One or two of the provinces have experimented with such action. Lessons can be learned from their efforts. Lessons also can be shared from the state quitlines. In the U.S. about 75 percent of quitlines provide medications to their clients. Additional quitlines facilitate provision of medications with vouchers or coupons. The estimated quit rate for quitline counseling is 16.2 percent whereas the estimated quit rate for quitline counseling with medications is 22.1 percent.
Experience has shown that offering medications along with counseling has a positive impact on reach of the quitline. A national pilot project to examine the barriers and potential solutions for providing medications may help move this recommendation forward.
2. NAQC also recommends that the provinces and territories consider further integrating the quitline into the healthcare system by building and strengthening fax and electronic referral programs that link healthcare providers with quitline resources. Such action will help make cessation a regular part of health care services. It also will increase the reach of the quitlines to more tobacco users.
The new regulation on tobacco warning labels herald an exciting new era for tobacco control and cessation. NAQC is confident that the comments and recommendations included in this letter are consistent with the government’s authority and if implemented would curb the significant adverse consequences of tobacco use. NAQC and its network of members across the U.S. and Canada stand ready to help Health Canada in its efforts.
Thank you, again, for the opportunity to provide input and share views on the proposed regulation. Should you have any questions about NAQC’s comments, please contact me via email at LBailey@NAQuitline.org
or via telephone at 602-279-2719.
Linda A. Bailey, JD, MHS
President and CEO
North American Quitline Consortium. (2009). Tobacco Cessation Quitlines: A Good Investment to Save Lives, Decrease Direct Medical Costs and Increase Productivity. Phoenix, AZ: North American Quitline Consortium.