NZORD's submission to Ministry of Health on tobacco displays

NZORD's submission to the Ministry of Health on Tobacco Displays - February 2008

This topic may seem a bit unusual for NZORD to be commenting on. The impact of smoking on the health of the population is certainly not a rare thing. It is one of the most common avoidable causes of health problems in society. But further analysis shows it is a matter of great interest to us because of its effect in blocking our access to health service through the sheer volume of health problems that smoking causes. Here’s the core of our submission to the Ministry of Health:

Submission summary:

Though there may be little discernable direct health impact on rare disease patients from tobacco use in society as a whole (unless of course the patient is also a smoker or is exposed to smoke), there is significant indirect impact in terms of lack of priority for our health needs, and severely restricted access to the health services we need.

Smoking is one of the most significant risk factors for a range of diseases which are high on the health priority lists and which do capture a significant slice of health budgets. The indirect consequence of tobacco use therefore place a severe constraint on access to resources for research, treatments and clinical care for rare disorders.

Any action to effectively restrict smoking uptake will reduce the burden of many common diseases over time. This presents a significant opportunity to improve our access to health care and services. For this reason we support the second part of option 3 in the consultation document - a complete ban on display of tobacco products.


A 1997 report by Brian Easton estimated that smoking cost the New Zealand health sector $205 million in direct costs in 1990. Without tobacco’s direct and indirect costs, Easton estimated there would have been an extra $785 million dollars that could have been used for other purposes. Easton, B. (1997) “The Social Costs of Tobacco Use and Alcohol Misuse” Public Health Monograph Series no. 2.

In 2005 an update of this report estimated the total cost of tobacco use to NZ society as $1.7 billion. “Report on Tobacco Taxation in New Zealand”, vol 2, Appendices, pps 21-29. Clearly, Tobacco diverts funding from other important health care areas – such as rare disorders and improved genetics services.

The recently released Public Health Bill seeks strategies for reducing non-communicable diseases, such as cardiovascular disease and diabetes. We support this objective and note that cigarette smoking is the number one contributor to onset of cardiovascular disease, and is a significant contributor to many other diseases that have high impact on numbers of patients affected and on total cost to the health sector and society.

We note the Health Research Council has funds to support only 20-25% of its applications. Of the nine research portfolios, the non-communicable disorders portfolio includes cancer, cardiovascular disease, diabetes, respiratory disease, and others, of which smoking is a significant risk factor for nearly all of these conditions. Other categories of non-communicable disease such as genetic disease (the majority of which are rare) are given a low priority by the Health Research Council.

In 2003 the National Health Committee produced a report on Molecular Genetic Testing in New Zealand, reporting that the services are seen as “not well-resourced” and “well short of international standards.” The recommendation from the NHC included an urgent need to upgrade these services to provide a viable and essential part of a modern health service. Genetic services are a crucial basic necessity for diagnosis and treatment of rare diseases, yet the Ministry of Health and District Health Boards have declined to implement this important report because genetic services are “not a priority” activity. This clearly demonstrates direct disadvantage to our interests resulting from the presence of significant preventable disease driven by smoking, that is given a higher priority.

Health benefits for rare disease patients and their families could come from added investments in screening programmes such as newborn metabolic screening. New Zealand was initially a pioneer in this area, but over the years has lagged behind, largely because of lack of priority for this sort of investment compared to common diseases with significant total costs. Opportunities to prevent or treat some rare diseases have therefore been lost to us.

A significant number of rare diseases now have therapies available that have high unit costs because of small patient numbers. This often leads to poor cost effectiveness analysis in a tightly budgeted health system and a reluctance by health administrators to fund these medicines. Reduction in the substantial direct and indirect cost of tobacco use would improve the chances of rare disease patients getting their essential medicines funded.

Reduction in tobacco driven disease has the potential to free up significant resources and provide a realistic opportunity for rare diseases to get a more equitable share of health services and research.

We reiterate NZORD’s support of a complete ban on tobacco displays (Option 3). We dismiss the potential disadvantage of smokers’ difficulty in knowing where to purchase cigarettes, as having no credibility or significance in the wider context we offer on this discussion. We note the NZ Herald’s recent report on an Australian study which found that “40 per cent of smokers who were trying to stop or reduce smoking were tempted to buy a pack when they saw a retail display. Nearly a third of smokers in the study agreed that removing the displays would help them to quit.” Johnston, M “Cigarette shop displays too tempting, says study”, New Zealand Herald, February 7, 2008.

John Forman
Executive Director