Comments on Healthy People 2030 draft objectives related to tobacco use
We are pleased to provide comments on the draft tobacco-use indicators for the Healthy People 2030 public health measurement framework.
This comment reflects views of the National Tobacco Reform Initiative, which is an alliance of experienced public health professionals dedicated to reducing adult smoking, and the related burden of disease and premature death, as far and as rapidly as possible in the United States. The members are as listed below. In this comment, we provide overall comments on the set of objectives and comments on each of the twenty specific objectives.
We propose changes to the objectives that would would rationalize and future-proof the framework. Our aim is to ensure that the objectives are closely aligned with meaningful health outcomes – ultimately reducing disease and premature death by changing tobacco-use behaviors. We suggest restoring quantified ‘leading indicators’ as with the Healthy People 2020 objectives.
We also suggest ways to avoid perverse incentives and unintended consequences that might arise from incomplete recognition of the very substantial differences in risk between combustible and non-combustible tobacco products. To characterize the overall burden of tobacco and nicotine use, we propose that a harm-weighted index of tobacco use would be a useful way to capture both changes in overall in tobacco use and changes in the structure of tobacco consumption over the coming decade. We suggest a focus on any form of combustible tobacco use rather than on just cigarettes, as we anticipate changes in patterns of consumption, and these could be driven in part by regulation such as reducing nicotine content.
We question whether policy implementation objectives should be included in Healthy People 2030 and make several suggestions for refinements to the indicator definitions.
We hope these views are helpful as we pursue our shared goal of radically reducing tobacco-related disease and premature death. We would welcome the opportunity to discuss these views with relevant staff.
Yours faithfully
Allan C. Erickson (NTRI Coordinator) Former Vice President for Public Education and Tobacco Control, American Cancer Society; staff director, Latin American Coordinating Committee for Tobacco Control
David Abrams, Ph.D. Professor, College of Global Public Health, New York University
Scott Ballin, JD Health Policy Consultant, Former Vice President and Legislative Counsel to the American Health Association
Aaron Biebert Former President and CEO, Clear Medical Solutions; Director, Attention Era Media Film Production Company – produced “A Billion Lives” documentary seen by millions worldwide
K. Michael Cummings, MPH, Ph.D. Professor, Department of Psychiatry and Behavioral Sciences, Medical University of South Carolina; Co-leader, Tobacco Research Program, Hollings Cancer Center
Tom Miller Attorney General of Iowa, Des Moines.
Ray Niaura, Ph.D. Professor, College of Global Public Health, New York University
John R. Seffrin, Ph.D. Professor of Practice, School of Public Health, Indiana University at Bloomington
Daniel Wikler, Ph.D. Mary B. Saltonstall Professor of Ethics & Population Health, Department of Global Health and Populations, Harvard T.H. Chan School of Public Health
Clive Bates (NTRI advisory team) Counterfactual Consulting, former Director Action on Smoking and Health, London
Attached: Comments on draft Healthy People 2030 Tobacco Use Objectives
