Letter to delegates to FCTC COP-6 « The counterfactual
The letter strikes hard by beginning with 5 clear and concise main points:
The letter strikes hard by beginning with 5 clear and concise main points:
- The best available scientific evidence on ENDS, cited with links to original research in the attached report, suggests they are very low risk, and are having the effect of reducing smoking – they are a welcome innovation that will reduce cancer, cardiovascular and lung disease and contribute to success in meeting targets for reducing NCDs by 25% by 2025.
- There is no evidence to suggest ENDS cause material harm, create gateways, renormalise smoking or are attracting youth who would otherwise be non-smokers. The use is concentrated in smokers, and this should be expected.
- WHO acknowledges that these products offer both ‘promise and threats’ but provides a one-sided negative analysis focussed only on threats based on flawed scientific advice. WHO emphasises minor or implausible risks while underplaying potentially large benefits of ENDS.
- WHO has not developed a coherent framework for discussing relative risk of products like ENDS (around 95-100% less risky than smoking). The most important function of ENDS is to substitute for smoking and to dramatically reduce risks to people who cannot or choose not to give up nicotine.
- WHO’s policy recommendations are not based on sound policy-making practice (evidence synthesis, options appraisal, impact assessment and consultation), and ignore many potential unintended negative consequences. These would have the effect of protecting cigarette sales, favouring the tobacco industry and causing more harm to health if implemented uncritically.
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