PHB 23
Bil Iechyd y Cyhoedd (Cymru)
Public Health (Wales) Bill
Ymateb gan: Company Chemists’ Association Limited
Response from: Company Chemists’ Association Limited
The Company Chemists’ Association response to The Health, Social Care and Sport Committee inquiry into
The general principles of the Public Health (Wales) Bill to improve and protect the health and well-being of the population of Wales and the Health, Social Care and Sport Committeeterms of reference.
Date: December 2016
Contact details:
Paul Harris
Chair of Welsh Management Group
The Company Chemists’ Association
Garden Studios
71 – 75 Shelton Street
Covent Garden
London
WC2H 9JQ
Email: XXXXXXXXXXXXXXX
Introduction
The Company Chemists' Association (CCA) provides a forum for the large businesses engaged in community pharmacy to work together to help create an environment where pharmacy can flourish and providers compete in a fair and equitable way. The CCA aims to represent our members, empower our members to understand the changing policy environment, and influence that policy environment. Our eight member companies – Boots, Well, Lloyds pharmacy, Tesco, Wm Morrison Supermarkets, Asda, Rowlands Pharmacy and Superdrug – own over 6,400 pharmacies between them which represents almost 50% of the pharmacies in the United Kingdom. Our members own just over 50% of pharmacies in Wales.
We are pleased to be able to respond again to the Welsh Governments call for evidence on the Public Health (Wales) Bill as we did in 2015. Please find our amended response below incorporating our previous comments but also extending our concerns and observations to cover the amended principles within the new Bill.
The CCA is extremely supportive of the revised Bill and its aims. However, the Bill covers many areas that we do not feel the CCA would be best placed to make comment on. Therefore, we have offered our views on the most pertinent areas that the Bill seeks to amend that we feel will have a direct impact on community pharmacy in Wales.
Principles impacting on community pharmacy within the Public Health (Wales) Bill
1.Register of retailers of tobacco and nicotine products
Part 2 observations
The CCA would like to highlight its concerns with the introduction of such a register and the use of the words for all “nicotine products” we draw your attention to The Bills explanatory memorandum that states
While many smokers quit without recourse to smoking cessation services and products, it is recognised that nicotine products can play an important role in helping smokers to quit altogether, or to reduce their consumption of tobacco products. Nicotine products include traditional forms of licensed nicotine replacement therapy (NRT), such as nicotine patches, gums and lozenges. There is strong evidence available for the long-term safety of NRT with concurrent smoking, suggesting that long term use of NRT is not associated with an increased incidence of harm, including cardiovascular events or cancer, with the latest analysis of outcome at 12.5 years from study outset.
Nicotine Products
Whilst supportive of the intention of the provision, the CCA requests the exemption of all pharmacies providing medically licensed Nicotine products as part of their service delivery for smoking cessation be it over the counter, via prescription or as part of a smoking cessation enhanced service. The Bill could inadvertently affect already very productive community pharmacy stop smoking services and could cause these services to be bound and inhibited by the legislative changes the Bill looks to impose.
Registered Premises
The CCA requests that as detailed above all pharmacies be exempted from the arrangements this bill seeks to address.
Distribution to under 18’s
Smoking cessation enhanced services and pharmacy provision within Wales does include people under 18 where believed to be competent to participate in such enhanced services, additionally many over the counter NRT products are licensed for sale to 12-18 year olds and some of these products can also be prescribed by their doctor and dispensed by their local pharmacy. Under the new regulations an under 18-year-old patient or customer would not be able to purchase, collect a dispensed prescription or take part in an NHS commissioned smoking cessation service without being accompanied by someone over the age of 18.
An exclusion by legality at this point of entry for young smokers seeking professional help for their addiction would be an inadvertent own goal for Welsh Government if registered pharmacies are not exempted from this provision.
2.Health Impact assessments
Part 5 Observations
The CCA would welcome clarification as to whether Health impact assessments will have a bearing on services delivered by Community Pharmacy and the future impact this may have on community pharmacy in Wales.
The CCA are supportive of this amendment which evaluates how the health of the population of Wales or sector of population will be affected by any proposed decision or action. The CCA feels this is a positive step towards The Well-being of Future Generations (Wales) Act 2015 which aims to ensure that sustainability and well-being, including achieving a healthier Wales, is at the heart of decisions taken by public bodies.
Comments on the principles of the Public Health (Wales) Bill
The RCPCH supports the principles of the Public Health (Wales) Bill, in particular:
3.1 We support the Bill’s intention to re-state restrictions on smoking in enclosed and substantially enclosed public and work places, giving Welsh Ministers a regulation-making power to extend the restrictions on smoking to additional premises or vehicles.
3.2 We support the proposal to place restrictions on smoking in school grounds, hospital grounds and public playgrounds. This, coupled with sustained public health campaigns about the dangers of second hand smoke, will not only send a strong message that Welsh Government values the health of its children, but will also protect children from the harmful effects of second hand smoke.
3.3 We also welcome the requirement for Welsh Ministers to require public bodies to carry out health impact assessments in specified circumstances. We believe that this part of the legislation could help to prevent children and young people from becoming unwell if, for example, local authority planning decisions included a public health impact assessment to consider the health impact of planning decisions on physical activity and obesity. However, we would welcome greater detail as to which circumstances are specified and what the requirements will be of the health impact assessments themselves.
Building on this proposed legislation, we call upon the Committee to:
3.4 Ensure that the legislation will include provisions that all public bodies would be required to ensure that environments encourage physical activity, safe cycling and walking routes and are not obesogenic (for example by minimising the exposure to marketing of food and drink high in sugar, fat or salt).
3.5 Consider, in light of recent reports by the Chief Medical Officer[1]and Public Health Wales[2]highlighting the issue of health inequalities, how these assessments can include the strongest possible provisions to ensure that the most disadvantaged children in Wales are not further disadvantaged.
4. Further recommendations
4.1 The Bill cannot address every issue affecting public health in Wales. However, there are a number of key areas that we urge the Committee to consider when ascertaining whether or not the Bill reflects priorities for improving public health.
4.2 Whilst some of these proposed measures are not within the legislative powers of the Assembly, we would support the extension of the Assembly’s competency to legislate on key public health issues, such a minimum unit pricing for alcohol.
4.3 Some of the recommendations would require legislation from the Welsh Government, some would be delivered through Public Health Wales and others would need action at local authority level.
4.3. We believe it would be a missed opportunity if the Bill did not include the following measures:
5. Maximising women’s health before, during and after pregnancy
5.1 Maternal health and wellbeing has a profound impact on the health of children. Being a healthy weight, breast feeding and stopping smoking all improve health outcomes for both mothers and infant.
We therefore recommend that:
5.2 The Welsh Governmentshould develop a national strategy on infant feeding.
5.3 The Welsh Government should require NHS Wales to ensure all maternity services achieve and maintain UNICEF UK Baby Friendly Initiative Accreditation
5.4 The Welsh Governmentshould set and monitor targets for increasing breastfeeding and reducing smoking in pregnancy and early childhood.
5.5 Public Health Walesshould undertake a targeted awareness campaign promoting smoking cessation, breastfeeding, heathy weight in women of childbearing age and safe sleeping practices for babies.
5.6 Public Health Wales and Health Boards should provide local breastfeeding support that is planned and delivered to mothers in the form of evaluated, structured programmes.
6. Strengthen alcohol and tobacco control
6.1 In Wales, 7% of fifteen year old boys and 9% of fifteen year old girls are regular smokers. Numbers have dropped since 1998, but not to the levels of other European countries. In addition to the proposed tobacco control legislation in the Public Health (Wales) Bill , we believe a public health campaign is required to further highlight the dangers of second hand smoke. Although rates of teenage drinking have dropped, they are still only average within Europe. 13% of fifteen year olds in Wales admit to drinking alcohol once a week and the negative health consequences of drinking alcohol are well established.
We therefore recommend that:
6.2 The Welsh Governmentshould pursue responsibility to implement Minimum Unit Pricing on alcohol.
6.3 Public Health Walesshould undertake sustained public health campaigns about the dangers of second hand smoke.
6.4 Public Health Walesshould protect services that help pregnant women stop smoking and ensure they are accessible to all
7. Tackle childhood obesity
7.1 The Child Measurement Programme for Wales reports that “26.2% of children in Wales are overweight or obese, compared to 21.9% in England in this age group”[3]. This is a crisis not just for the individuals involved but for the NHS and social care in Wales because obese or overweight children are very likely to become overweight or obese adults with the associated rises in rates of Type 2 Diabetes, heart disease and certain cancers.
7.2 There must be a comprehensive package of measures from the Welsh Government to tackle obesity. The Child Measurement Programme includes four- five year olds but it does not measure 10.5 -11.5 year olds, creating a barrier to reducing childhoodobesity. As well as preventative measures, children and young people who already have overweight or obesity must be able to access the support and treatment they need to reduce their weight.
7.3 Many of the key policy initiatives which will go furthest to reverse current trends (advertising bans and fiscal measures, for example) are the responsibility of Westminster Government, but we believe that there are some key areas where the Welsh Government can take action.
We therefore recommend that:
7.1 The Welsh Governmentshould develop and implement an evidenced-based childhood obesity strategy for tackling the current crisis and preventing further escalation.
7.2 The Welsh Governmentshould implement a package of measures to reduce the factors that collectively create an obesogenic environment. This should include an audit of local authority licensing and catering arrangements with the intention of developing formal recommendations on reducing the proximity of fast food outlets to schools, colleges, leisure centres and other places where children gather, as well as urging local authorities to include a public health impact assessment in all planning decisions and to introduce 20 mph speed limits in built up areas, to create safe places for children to walk, cycle and play.
7.3 Public Health Walesshould expand the Child Measurement Plan for Wales to measure children after birth, before school and in adolescence.
8. Accident prevention
8.1 A large proportion of preventable deaths during childhood and adolescence occur in the context of children and young people’s interaction with their external environments. A number of these are preventable by changes in policy and the need to better equip children and families with the knowledge, resources and appropriate public spaces in order to facilitate safety in the home and in the community and reduce the incidence of unintentional injury.
We therefore recommend that:
8.2 Public Health Wales should deliver health visiting services and home safety equipment schemes which educate and equip parents and carers to keep their children safe, with a focus on water safety, pet safety, blind cord injury prevention and safe sleeping.
8.3 The Welsh Government should call on the UK Government to implement Graduated Driving Licences to address the issue that young drivers make up 2% of licence holders but are involved in 12% of accidents in Great Britain.
9. Further information
For further information on any of the content of this paper, please contact Gethin Jones, External Affairs Manager for Wales: XXXXXXXXXXXXXXXXXX or XXXXXXXXXXXXXXX