Response 792911664

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Introduction

1. What is your name?

Name (Required)
Freddy Sitas

3. What is your organisation?

Organisation (if applicable)
Centre for Primary Health Care and Equity, School or Population Health University of New South Wales

4. What is your position in the organisation?

Position (if applicable)
Director and Conjoint Associate Professor

Conflicts of interest (actual or perceived)

5. Have you or your organisation ever received services, assistance or support (whether monetary or non-monetary in nature) from the tobacco industry and/or e-cigarette industry? If this scenario applies to you or your organisation, please provide relevant details in the textbox.

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Radio button: Unticked Yes
Radio button: Ticked No
Support from tobacco and/or e-cigarette industry (Required)
My organisation does not receive any funds from the tobacco industry

6. Have you or your organisation ever provided services, assistance or support (whether monetary or non-monetary in nature) to the tobacco industry and/or the e-cigarette industry? If this scenario applies to you or your organisation, please provide further information in the textbox.

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Radio button: Unticked Yes
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Support to the tobacco and/or e-cigarette industry (Required)
The Centre for Primary Health Care and Equity does not provide services to the tobacco industry.

7. Is your organisation a:

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Checkbox: Unticked Tobacco retailer/manufacturer/importer/wholesaler
Checkbox: Unticked E-cigarette retailer/manufacturer/importer/wholesaler
Checkbox: Unticked Public health organisation
Checkbox: Unticked Academic/policy institution
Checkbox: Unticked Non-government organisation
Checkbox: Unticked State or territory government agency
Checkbox: Unticked Commonwealth government agency
Checkbox: Unticked Manufacturer/retailer/importer/wholesaler of pharmaceutical goods
Checkbox: Ticked Other
Checkbox: Unticked Not applicable
If other, please specify:
University

Framework of the draft NTS 2022-2030

8. Do you agree with the goals and smoking prevalence targets for the draft NTS 2022-2030? Please provide an explanation for your selection.

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9. Do you agree with the objectives for the draft NTS 2022-2030? Please provide an explanation for your selection.

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Objectives
Australia has led the world in anti-smoking campaigns involving legislation, taxation and significant public health measures for over half a century, informed by data. This has halved the smoking rates from 35% in the 1960s to 15% today. However, 2.9 million Australians still smoke and around 20,000 Australians die every year from smoking. While previous initiatives have been successful in lowering Australia’s smoking rate, to lower it again by half (i.e. from 15% to 5%) requires even more effort and far more sophisticated, focused campaigns with access to detailed, local data.
Current data sources include prevalence surveys to monitor change over time and estimates of the burden of smoking on deaths using attributable fractions derived from research. For deaths attributed to smoking (arguably a key statistic influencing policy), Australia relies on indirect estimates of tobacco-attributed mortality – using relative risks from the USA – most recently updated in 2011.

10. Do you agree with the guiding principles for the draft NTS 2022-2030? Please provide an explanation for your selection.

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Guiding principles
The guiding principles of working in partnership are essential to achieve these ambitious gains. Current "Business as usual" anti tobacco / smoking programs will not achieve these. Extending partnerships to significant sub populations which have high smoking rates is essential. Having direct (local) Australian data to improve the accuracy of tobacco attributed deaths overall and especially in important population subgroups where tobacco smoking prevalence is high, is of critical importance. Subgroups include ‘priority populations’ e.g. people living in rural areas, of Aboriginal and Torres Strait Islander origin, who are unemployed, less educated, of low socioeconomic status, with a mental disability, and certain migrant communities. Getting local detailed data will facilitate more precise strategies for tobacco control, especially in marginalised populations. A new partnership between 'Health' and the State and Territory Attorney Generals is required to amend the death notification forms to include simple question on smoking (that incorporates when the deceased stopped).

Priority areas of the draft NTS 2022-2030

11. Do you agree with the priority areas for the draft NTS 2022-2030? Please provide an explanation for your selection.

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Priority Areas
A priority area should be to collect timely local accurate data to monitor the rise and fall of deaths attributed to smoking in Australia and within its important subgroups, rather than relying on risk estimates gathered from overseas, e.g. from global burden of disease.

12. Do you agree with the actions listed under each priority area for the draft NTS 2022-2030? Please provide an explanation for your section.

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Actions
An additional action must be to include in State and Territory death notification forms a voluntary question directed to the next-of-kin on the tobacco smoking status of the deceased to identify “never”, “former” and “current” smokers. This question will allow Australian agencies (e.g. the Australian Bureau of Statistics and the Australian Institute of Health and Welfare) to directly and accurately estimate the annual number of people whose death, by cause, was attributed to smoking.

Having direct (local) Australian data to improve the accuracy of tobacco attributed deaths overall and especially in important population subgroups where tobacco smoking prevalence is high, is of critical importance. Subgroups include ‘priority populations’ e.g. people living in rural areas, of Aboriginal and Torres Strait Islander origin, who are unemployed, less educated, of low socioeconomic status, with a mental disability, and certain migrant communities. Getting local detailed data will facilitate more precise strategies for tobacco control, especially in marginalised populations.
The advantages of this approach include: All deaths legally require completion of a death notification form, so they capture almost all the population. Once adopted, such a question will generate data that are perpetual and increasingly statistically valid.
The cost of implementation is low. The forms differ slightly between jurisdictions, so amendments will be required to relevant State and Territory regulations, and to Death Registry IT systems and paper forms to include the question – a small cost. Answering the question will mostly be done by the next-of-kin in the presence of a funeral director or medical professional. This means the reliability of the answer is likely to be high as it is provided by a person familiar with the deceased. The additional time/cost to the funeral director or medical professional in completing the death notification form will be minimal.

Other Feedback

13. Please provide any additional comments you have on the draft NTS 2022-2030.

Additional comments
I am happy to provide further information. This proposal is based on experience from South Africa (pop 54m) implemented since 1997 and Tianjin Municipality, China (pop 15m), implemented since 2011. Each has now collected information on the smoking habits on over a million deceased individuals. In each case, the tobacco burden measured directly differed significantly to what had been estimated using indirect global burden of disease) estimates and led to better focusing of tobacco programs.

Publication of submissions

15. To proceed, please select the button below if you acknowledge the conditions above and agree to have your submission published in full.

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Radio button: Ticked Yes, I acknowledge the above conditions and agree to have my submission published.