The UK Vaping Industry Association (UKVIA) has raised major concerns over possible bias in a report commissioned by the Scottish government as part of a review on the environmental impact of single-use e-cigarettes.
The report was jointly prepared by Zero Waste Scotland and Dr Dominic Hogg of environmental consultancy Equanimator Ltd, and shortlists nine policy options for further consideration. These include a proposed ban on single-use vapes, which UKVIA claims could see vapers deprived of their chosen alternative to cigarettes and smoking rates driven up.
In a letter to Lorna Slater MSP, Scotland’s Minister for Green Skills, Circular Economy and Biodiversity, UKVIA director general John Dunne detailed two major concerns with the report; the process of the review and the ‘lack of impartiality’.
He questioned why the public and the wider vape sector were not invited to contribute to the review, saying this contradicts government guidance which states ‘consultations are open for all citizens to reply to’.
Dunne also said that the approach to this report differs from a previous Scottish consultation on the advertising and promotion of vaping products, which allowed consumers to ‘have their say’ and saw more ‘diverse’ responses.
Further, while the UKVIA and the Independent British Vape Trade Association were permitted to provide submissions to the review, their individual members were not.
Dunne wrote: “This gives the impression that the consultations were merely a box-ticking exercise rather than a genuine attempt to engage with the views of both the vaping sector and those who have successfully transitioned from smoking to vaping.
“This is reinforced by the fact that the report does not reference any comments from the UKVIA, the UK’s largest vaping association with an extensive membership in Scotland.
“Unfortunately, it seems that this review could be used as a tool to push through anti-vaping policies without proper public consultation and scrutiny.”
He also raised concerns with potential biases of lead reviewer Dr Dominic Hogg who, just days after the review was published, posted to LinkedIn saying, “if we weren’t going to keep single use ecigs off the market, then what product would we keep off the market”.
Ahead of Scotland’s consultation, climate activist Laura Young – who contributed to the report and runs her own Ban Disposable Vapes campaign – said she had “full trust” in a “robust” and “objective” review.
However, Dunne said the public comments made by Dr Hogg raise questions on whether personal prejudices may have influenced his consideration of the facts.
He warned politicians must “seriously consider” the dangers of prohibitive policy put forward in the review, especially considering Scotland has the highest smoking prevalence of any UK country at 14.8% (Office for National Statistics) and there are no plans to ban cigarettes – which are a major pollutant and cause 200 deaths a day in the UK.
Dunne also highlighted that “prohibition has been proven ineffective”, saying a ban on disposable vapes would “create a thriving black market beyond government control” and would see rigorously tested and regulated products replaced with illicit and potentially dangerous alternatives.
He pointed to the failings of Australia’s ‘prescription only’ vaping policy, citing a letter addressed to Australian parliament members from 45 leading Australian and New Zealand tobacco control, public health and addiction experts with no links to tobacco or e-cigarette companies, which called for reform. The experts claimed that “the ban has created a dangerous black market” where nicotine “is now more available and potent than that in the regulated one”.
Dunne wrote: “Over the past decade, it has been widely accepted in the public health domain that e-cigarettes are the most effective way to help smokers transition to a less harmful alternative.
“Outlawing one of the most popular, convenient and accessible alternatives to combustible tobacco would likely increase smoking rates, especially among low-income vapers who rely on affordable disposables as an initial step away from cigarettes.”
He stressed there is a “better way forward” and invited those involved in the consultation to meet to discuss how the Scottish Government can “best support smokers in transitioning to a less harmful alternative” while also ensuring the impact on the environment is minimised.
The letter was also sent to First Minister of Scotland Humza Yousaf MSP; Cabinet Secretary for NHS Recovery, Health and Social Care Michael Matheson MSP; Minister for Public Health and Women’s Health Jenni Minto MSP; Convener of the Health, Social Care and Sport Committee Clare Haughey MSP; chair of Zero Waste Scotland Helen Wollaston; CEO of Zero Waste Scotland Iain Gulland; and Dr Dominic Hogg.
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