Wednesday 31 August 2016

Japan Tobacco's Unfair Representations

This week Japan Tobacco launched a web-page (bothsidesoftheargument.ca) against plain packaging in Canada, timed to coincide with the end of the first wave of public consultations on this important initiative.


The primary framing of its message on the web-site and the full-page newspaper ads to drive journalists to it was that the policy was being "rushed through after a short public consultation"

Appealing to Canadians' sense of fairness is likely to yield the company better results than to remind them of the toxicity of the product that they currently peddle. The public opinion survey they commissioned from Forum Research is focused at teasing out public concerns about fairplay, and the twin bogey men of contraband and the slippery slope of plain packaging being used on other harmful producxts.

Their concerns about fairplay did not seem to extend to the survey methods or their own communications.

Participants in the survey, for example, were shown two images a cigarette package on which they could assess the impact of the reform. The images of a "plain" and current package they were shown were stripped of many of the elements that are under consideration in the government's proposals. (The image below is taken from the survey report). The difference is relegated to 25% of what the participants saw.

They were not given the opportunity to note the many ways in which the package was used to promote their brands before being asked whether removing these details might make a difference, or the many ways the government intends to standardize the cigarette product and its packaging. 

By contrast, JTI encourages retailers to see the package as key promotional tool - as shown in the picture below, taken from their retailer web-site. Why was this image not shown to those surveyed? 



Nor was there much fair play when it came to the numbers they use. Australia is the only country to date has field experience with plain packaging, and JTI claims on its new web page that following plain packaging "in four out of five states, smoking prevalence has actually increased4." 

Two funny things about this claim.
The first is that although the statement is referenced (number "4"), there is no corresponding footnote. The notes jump mysteriously from "3" to "5".  In the past the company has used commercial (read pay-for-use) estimates of smoking prevalence in Australia -- a practice which has already been the subject of detailed criticism.
Moreover, the Australian government commissioned their own analysis of the data that the tobacco industry cited (but hid) in their claims of no-effect. This analysis concluded that "over the 34 month post-implementation period from December 2012 to September 2015 ...the 2012 packaging changes resulted in 108,228 fewer smokers."

The second oddity about this yet-unsubstantiated claim is that it is contradicted by the Australian government surveys. which show that smoking rates in Australia continue to fall: "14.7% (age-standardised) of adults aged 18 years and over smoked daily (approximately 2.6 million smokers), decreasing from 16.1% in 2011-2012."

Another glaring unfairness in the company's presentation to survey respondents and viewers of its website is the suggestion that the initial consultation period of three months is the final opportunity for public input. Forum Research conclusion that "an overwhelming majority... think the public should be given more than 3 months" is part of the suggestion that they won't.


As Health Canada's consultation document pointed out, there will be an additional 75 day consultation period when the regulation is pre-published in the Canada Gazette. (The House of Commons is mandated under the Tobacco Act to conduct a further review, and can be expected to conduct further hearings).

In fact the consultation will be in the range of 4 to 6 months, which as shown in the graph from their report above, was supported by 63% of respondents. (JTI would have said "two-thirds"!).

JTI's concern for fairness was also missing in its appeal for web-readers to consider the views of Sinclair Davidson, an Australian researcher. This gentleman has already been exposed as a paid participant in a disinformation campaign by the Australian press (at least twice!) - as they were only last week by Canadian researchers in the peer-reviewed Canadian Medical Association Journal.