Consultation Responses

North South Alcohol Policy Advisory Group Newsletter June 2022

louise.bradley@publichealth.ie — Wed, 17 Apr 2024 14:19:33 +0000

North South Alcohol Policy Advisory Group Newsletter June 2022 louise.bradley… Wed, 17/04/2024 - 15:19

North South Alcohol Policy Advisory Group Newsletter June 2022

1 Jun, 2022

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This newsletter provides updates on recent alcohol research and policy relevant to Ireland and Northern Ireland. The June edition features an evaluation of MUP in Scotland, the annual report from the UK Alcohol Health Alliance and the WHO Draft Action Plan on Alcohol. You can access reports and recordings of past events as well as information on upcoming webinars.

Consultation Response: Further Regulation of Tobacco and Nicotine Inhaling Products in Ireland

maresa.fagan@publichealth.ie — Fri, 19 Jan 2024 12:28:44 +0000

Consultation Response: Further Regulation of Tobacco and Nicotine Inhaling Products in Ireland maresa.fagan@p… Fri, 19/01/2024 - 12:28

Consultation Response: Further Regulation of Tobacco and Nicotine Inhaling Products in Ireland

Tobacco

19 Jan, 2024

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Consultation Response: Further Regulation of Tobacco and Nicotine Inhaling Products in Ireland

Earlier this month the Institute responded to a public consultation by the Department of Health in Ireland to inform the future regulation of tobacco and nicotine inhaling products, such as e-cigarettes.

The public consultation was launched in November 2023 and asked questions across seven areas for which new legislation would be needed: point of sale display, appearance of nicotine inhaling products, flavours, vaping restrictions, proxy sales, smoking in outdoor dining areas and raising the legal age of sale for tobacco.

In its response, the Institute said the proposed regulatory measures were necessary, proportionate, feasible, equitable and supported by both evidence and public opinion.

Key Points on Tobacco Regulation
IPH strongly supports the introduction of legislation to create a smoke-free generation on the island of Ireland and recommends:

Introducing a package of short-term and medium-term tobacco endgame measures including further regulation of nicotine concentrations and product packaging
Increasing the minimum legal age of sale for tobacco products to 21, with a firm commitment to ultimately prohibit tobacco sales to anyone born after 2009
Adoption of a comprehensive pricing strategy including taxation and minimum unit pricing of tobacco and e-cigarette products
Application of place-based approaches to reduce the accessibility of tobacco utilising the recently approved licensing system
Investment in workforce capacity and resources for enforcement within the Health Service Executive, local councils and an Garda Síochána
Introducing a legal requirement for all government departments and elected officials in Ireland to report on compliance with Article 5.3 of the World Health Organization Framework Convention on Tobacco Control
Introducing regulations to create smoke-free outdoor dining areas.

Key Points on E-cigarette Regulation
IPH recommends an approach to e-cigarette regulation that focusses on reducing the appeal and accessibility of e-cigarettes to children and young people, and recommends:

Keeping e-cigarette products behind the counter and prohibiting in-store marketing and promotional materials
Introducing further regulation on the marketing and sale of e-cigarettes online
Prohibiting the use of all imagery including animations/cartoons, colouring and branding for both e-cigarette packaging and device
Restricting e-cigarette flavours including flavour descriptors
Adopting a comprehensive strategy on reducing retail outlet density for tobacco prior to any consideration of exemptions for specialist vape shops
Introducing progressive e-cigarette taxation targeted to products preferred by young people, but maintaining a price differential through consistent increases in tobacco taxation
Resourcing change management, communications, evaluation, and monitoring systems to assess policy impacts on children, tobacco users, dual users, and e-cigarette only users.

IPH response to the consultation on fortification of flour with folic acid in Northern Ireland

maresa.fagan@publichealth.ie — Fri, 12 Jan 2024 15:02:51 +0000

IPH response to the consultation on fortification of flour with folic acid in Northern Ireland maresa.fagan@p… Fri, 12/01/2024 - 15:02

IPH response to the consultation on fortification of flour with folic acid in Northern Ireland

Food

Prevention

Womens Health

15 Jan, 2024

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IPH response to Amending the Bread and Flour Regulations

In August 2023 the Institute responded to the Department for Environment Food and Rural Affairs (DEFRA) consultation on Northern Ireland’s ‘Bread and Flour’ regulations.

The consultation followed an announcement in 2021 by the the UK government to fortify flour with folic acid.

The consultation report for ‘Amending the Bread and Flour Regulations 1998 and the Bread and Flour Regulations (Northern Ireland) 1998’ is awaited and will be published on the Food Standards Agency website: Consultation on Amending the Bread and Flour Regulations 1998 and the Bread and Flour Regulations (Northern Ireland 1998) | Food Standards Agency.

Blog: What next for fortifying flour in Northern Ireland to help prevent birth defects?

maresa.fagan@publichealth.ie — Fri, 12 Jan 2024 14:38:11 +0000

Blog: What next for fortifying flour in Northern Ireland to help prevent birth defects? maresa.fagan@p… Fri, 12/01/2024 - 14:38

Blog: What next for fortifying flour in Northern Ireland to help prevent birth defects?

Food

Prevention

Womens Health

15 Jan, 2024

The UK is in line to be the first country in Europe to fortify flour in a bid to reduce the occurrence of certain birth defects.

In this blog, Dr Jenny Mack, Consultant in Public Health Medicine, shares some insights on why this measure is being introduced in the UK and what this may mean for Northern Ireland.

Why has this measure been agreed by the UK government?

Folic acid plays a very important role in the development of the brain, skull, and spinal cord of the foetus. Despite decades of efforts to enhance the use of folic acid supplements, there are still many women in the UK who do not have enough folic acid in early pregnancy. Being deficient in folic acid means the woman’s developing baby is at risk of a neural tube defect (NTD). This is important, as NTDs can lead to serious health problems, including long-term damage to the nervous system, disability and unfortunately, death.

Evidence reviews conclude that more NTDS could be prevented if broader population health measures were introduced, specifically if flour was fortified with folic acid. This measure will help ensure that women with unplanned pregnancy, and those that have not taken supplements before they discover they are pregnant, can also be offered some protection for their baby. Adding folic acid to food products, a process known as ‘fortification’, has been implemented in around 80 countries across the world. In countries where folate fortification has been rolled out, NTDs have fallen.

In the USA, folic acid fortification of cereal grains was mandated in 1998. This was associated with a decline in NTDs which was maintained for more than a decade. At the same time, fortification led to an increase in folate levels amongst women of a childbearing age in the general population. This video produced by the CDC tells the story of how evidence influenced the policy decision in the USA.

A study in the British Medical Journal estimated that 2,000 pregnancies associated with NTDs would have been prevented by 2012 if the UK has adopted the same fortification regimen as the USA in 1998.

What is the potential benefit to health in Northern Ireland?

The UK government and devolved administrations have proposed the addition of 250µg of folic acid per 100g of non-wholemeal wheat flour. If these regulations are enacted fully, this would be a major step towards the prevention of a substantial proportion of NTDs. This is particularly important for Northern Ireland, where the population is at higher risk of NTDs due to higher levels of social deprivation, evidence of a less nutritious diet among women of childbearing age and some evidence of lower levels of folate in women who may become pregnant, when compared to other regions in the UK and in comparison to Ireland. Estimates of the incidence of neural tube defects are not routinely published in Northern Ireland, in part due to the absence of a standardised congenital anomaly register in the region. Estimates from Hospital Information Branch suggest that there were around 48 admissions, and tragically 6 stillbirths, attributable to NTDs in the region in 2018. However, due to small population size in Northern Ireland and no bespoke register, developing appropriate incidence estimates and assessment of trend needs further careful epidemiological analysis.

So why hasn’t this been implemented in Northern Ireland?

The UK government agreed to fortify flour with folic acid in an announcement in September 2021. Devolved governments in Northern Ireland need to amend their regional Bread and Flour Regulations to see the measure implemented in the region. It is now over a year since interested parties, including IPH, submitted a response to the Department for Environment Food and Rural Affairs (DEFRA) consultation on Northern Ireland’s ‘Bread and Flour’ regulations. A consultation report detailing the responses received and the government response was released on 17 January 2024. There were 23 responses from Northern Ireland to this consultation.
The report states that the UK government and devolved administrations have carefully considered the responses received and intend to proceed with the proposals as set out in the consultation, with the exception of the proposal to exempt flour used as a minor ingredient (less than 10% of the final product). A UK-wide monitoring group has been set up to develop an evaluation of the proposed implementation of amendments to the Bread and Flour Regulations, relating to micronutrient levels. The monitoring group is chaired by Food Standards Scotland and comprises colleagues from the Department of Health and Social Care; the Department of Health Northern Ireland; Welsh Government; Scottish Government; the Department for Environment, Food and Rural Affairs; and the Food Standards Agency in Northern Ireland. The group is considering monitoring at a UK level as standard and at the devolved administrations level where feasible, for both positive and postulated negative impacts of the policy. Political support for this measure exists, with Lord Dodds of Duncairn particularly active on the issue in the House of Lords and in the All-party Parliamentary Group on Folic Acid Fortification at Westminster.

What about Ireland?

In Ireland the topic of NTDs recently came into the spotlight with concerns over outcomes for children with spina bifida undergoing surgery. There has been some, but limited, discussion on issues of prevention, data monitoring and surveillance. The Minister for Health recently responded to a parliamentary question on the fortification and the prevention of NTDs. The Minister’s response indicated that before any policy position is reached on folic acid fortification, stakeholder consultation would be required, and that in the short-term other measures would need to be optimised, such as folic acid supplementation and dietary folate intake.

What measures are needed to further reduce NTDS on the island of Ireland?

Alongside fortification, IPH suggested the development of a Northern Ireland strategy to reduce NTDs at a population level. A strategy could help to co-ordinate a suite of preventative actions, including fortification, but also optimise the use of supplements, monitor incidence and enhance preventive approaches for higher risk pregnancies. IPH recommended investment in a monitoring system to assess levels of fortification, adequacy of folate levels in women who may become pregnant and incidence of NTDs. Baseline estimates have recently been established in other regions of the UK which will enable the impact of fortification to be evaluated.

There is much to learn from the New Zealand experience. Despite some failed attempts to progress the measure in 2007, Manatu Hauora (New Zealand Ministry of Health fully introduced mandatory fortification in August 2023, within two years of announcing government support in 2021. The government championed the legislation as a health inequity investment – capturing learning from fortification in Australia to show the additional benefit to indigenous women and protecting women, babies and families in underserved communities.

Links

Read: IPH response to the consultation on fortification of flour with folic acid in Northern Ireland

Additional Resources

Advice on planning your pregnancy https://www.nhs.uk/pregnancy/trying-for-a-baby/planning-your-pregnancy/

Information for women of child-bearing age on how to ensure you get enough folic acid when planning a pregnancy  Folic_Acid_2022.indd (hscni.net) https://www.safefood.net/healthy-eating/supplements

Consultation Response: IPH response to Northern Ireland’s 2030 & 2040 Emissions Reduction Targets, Carbon Budgets, and Climate Change Committee Advice Report

maresa.fagan@publichealth.ie — Tue, 19 Dec 2023 15:28:58 +0000

Consultation Response: IPH response to Northern Ireland’s 2030 & 2040 Emissions Reduction Targets, Carbon Budgets, and Climate Change Committee Advice Report maresa.fagan@p… Tue, 19/12/2023 - 15:28

Consultation Response: IPH response to Northern Ireland’s 2030 & 2040 Emissions Reduction Targets, Carbon Budgets, and Climate Change Committee Advice Report

Climate Change

Public Health

18 Dec, 2023

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NI Carbon Budget Consultation Response

The Institute recently responded to a public consultation on Northern Ireland’s 2030 & 2040 Emissions Reduction Targets, Carbon Budgets, and the Climate Change Committee Advice Report: 'The path to a Net Zero Northern Ireland’, published by the Department of Agriculture, Environment and Rural Affairs (DAERA) on behalf of the Northern Ireland Executive.

Key Observations

The Institute made a series of recommendations, including the following:

•The Department of Agriculture, Environment and Rural Affairs (DAERA) follows the advice provided by the UK Climate Change Committee on 2030 and 2040 emissions reduction targets to ensure that Northern Ireland reaches net zero by no later than 2050

•There is an increase in ambition of targets and budgets, to at least those set by Ireland, in order to support transboundary collaboration

•There is no further delay to the publication and implementation of the new Environment Strategy / Environmental Improvement Plan for Northern Ireland

•Health Impact Assessment (HIA) of climate change in Northern Ireland is conducted to inform the development of Climate Action Plans

•The ‘Speculative Agriculture’ option (halving livestock numbers by 2050, significant technology and efficiency improvements in the sector, and reduction in meat and dairy consumption) is prioritised due to the co-benefits for population health and wellbeing associated with a population-wide shift towards a sustainable, healthy diet.

IPH response to the UK government and devolved administrations’ consultation ‘Creating a smokefree generation and tackling youth vaping’

maresa.fagan@publichealth.ie — Mon, 18 Dec 2023 10:19:47 +0000

IPH response to the UK government and devolved administrations’ consultation ‘Creating a smokefree generation and tackling youth vaping’ maresa.fagan@p… Mon, 18/12/2023 - 10:19

IPH response to the UK government and devolved administrations’ consultation ‘Creating a smokefree generation and tackling youth vaping’

Tobacco

18 Dec, 2023

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UK smokefree generation consultation response

IPH recently responded to a UK consultation on creating a smokefree generation and tackling youth vaping.

In October the Department of Health and Social Care (DHSC) in England published a command paper ‘Stopping the start: our new plan to create a smokefree generation’, setting out proposed action to protect future generations from the harms of smoking by creating the first smokefree generation, which the UK Government and devolved administrations (including the Northern Ireland Executive) consulted on.

The UK consultation asked questions in the following three areas for which new legislation would be needed: creating a smokefree generation, tackling youth vaping, and enforcement.

IPH has developed a response to this consultation with a focus on Northern Ireland and in the context of all-island tobacco endgame ambitions.

Tobacco causes around 2,200 deaths in Northern Ireland every year. Tobacco-related illness, disability and death requires a robust response with short-term, medium term and long-term strategic actions. Regular use of e-cigarettes is increasing among children in Northern Ireland and measures are required to reduce the appeal and accessibility of e-cigarette products to children.

The regulatory measures proposed in this consultation are necessary, proportionate, feasible, equitable and supported by both evidence and public opinion.

Submission: Response to public consultation on Disposable Vaping Devices in Ireland

maresa.fagan@publichealth.ie — Tue, 07 Nov 2023 10:28:14 +0000

Submission: Response to public consultation on Disposable Vaping Devices in Ireland maresa.fagan@p… Tue, 07/11/2023 - 10:28

Submission: Response to public consultation on Disposable Vaping Devices in Ireland

Tobacco

7 Nov, 2023

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Response to public consultation on Disposable Vaping Devices in Ireland

The Institute of Public Health recently responded to a public consultation on Disposable Vaping Devices launched by the Department of the Environment, Climate and Communications in Ireland.

This consultation proposed a series of policy options to address the environmental impacts of disposable vaping devices, including:

ban on the manufacture, sale, distribution or free offer of disposable vaping devices under the Waste Management Act, 1996, Section 28(4)(i)
establish a deposit and return system for disposable vaping devices
make no legislative change but improve the producer responsibility scheme to ensure all producers placing devices on the market are registered; ensure enforcement of EPR requirements is adequate; improve education and awareness around returning devices into the WEEE and battery collection schemes for responsible recycling

The Institute responded to this consultation in support of a total ban of the sale of disposable vaping devices, from both an environmental and a health perspective.

This position was based on:

Evidence of environmental harms associated with disposable vapes including littering and leaching of toxic compounds into the environment, disposable vapes as a source of single-use plastics contributing to marine and land pollution, greenhouse gas emissions associated with production and explosion/fire risk;
Evidence of poor compliance with existing regulations, with some disposable vaping devices exceeding permitted levels of nicotine content;
E-cigarettes are not recognised as the most effective way of supporting people to stop smoking in Ireland and they have a largely untested safety profile, compared to the HSE approved package of care offered through QUIT.ie comprising medication and behavioural support
Evidence demonstrating an association between e-cigarettes and initiation of cigarette smoking amongst non-smokers, nicotine addiction and certain health harms.

Evidence Review: IPH response to an Inquiry into the Effects of Alcohol on Society by the UK Commission on Alcohol Harm

maresa.fagan@publichealth.ie — Thu, 12 Oct 2023 11:10:41 +0000

Evidence Review: IPH response to an Inquiry into the Effects of Alcohol on Society by the UK Commission on Alcohol Harm maresa.fagan@p… Thu, 12/10/2023 - 12:10

Evidence Review: IPH response to an Inquiry into the Effects of Alcohol on Society by the UK Commission on Alcohol Harm

Alcohol

30 May, 2020

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Evidence Review: IPH response to an Inquiry into the Effects of Alcohol on Society by the UK Commission on Alcohol Harm

In March 2020, IPH Director of Policy, Dr Helen McAvoy, gave evidence, alongside the British Medical Association in Northern Ireland, to the UK Commission on Alcohol Harm as part of an inquiry into the Effects of Alcohol on Society.

This briefing paper provided supplementary evidence to the UK Commission on the profile of harm in Northern Ireland and efforts to prevent and respond to those harms.

Themes addressed in this response document include the following:

Impact of alcohol on health since 2012
Impact of alcohol on the NHS and other public services
Challenges for alcohol treatment services in supporting people impacted by alcohol harm
Impact of alcohol consumption on family life, relationships and sexual behaviour
Impact of alcohol harms on different demographic groups, including age, sex and social class
What impact does alcohol have on economic productivity; and changes since 2012?
What current evidence is there of links between alcohol and violent behaviour and other crime?
What recent evidence is there of links between alcohol and other addictive behaviours (such as smoking, drug use and gambling)?
The effect of the current approach to alcohol marketing and licensing have on alcohol harm
Policy changes to help to reduce the level of harm caused by alcohol

Consultation Response: Advertising restrictions on TV and online for products high in fat, salt or sugar

maresa.fagan@publichealth.ie — Tue, 02 May 2023 09:13:39 +0000

Consultation Response: Advertising restrictions on TV and online for products high in fat, salt or sugar maresa.fagan@p… Tue, 02/05/2023 - 10:13

Consultation Response: Advertising restrictions on TV and online for products high in fat, salt or sugar

Commercial Determinants of Health

Food

Obesity

14 Apr, 2023

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Consultation Response: Advertising restrictions on TV and online for products high in fat, salt or sugar

The Institute of Public Health (IPH) recently responded to a UK-wide consultation on introducing further advertising restrictions on TV and online for products high in fat, salt or sugar.

The consultation by the UK Department for Digital, Culture, Media & Sport and Department of Health & Social Care sought views on proposals to bring forward secondary legislation that will reduce children’s exposure to high in fat, salt or sugar (HFSS) product advertising on TV and online.

In IPH’s submission, the following points were highlighted:

issues relating to the implementation and monitoring of the measure in the unique media, political and regulatory environment in Northern Ireland
contextual issues relating to Northern Ireland’s obesity epidemic, patterns of food purchasing and consumption
specific concerns on exemptions which hold the potential to dilute the impact of the regulations – specifically, alcohol substitute drinks, breast milk substitutes and baby food; SME businesses and services connected to regulated radio services and the audio-only exemption
concerns regarding the potential for ongoing brand advertisement
concerns regarding the long time period for implementation of the policy to 1 October 2025.

Improving Health within Criminal Justice - IPH Consultation Response

webadmin — Thu, 20 Apr 2023 09:55:24 +0000

Improving Health within Criminal Justice - IPH Consultation Response webadmin Thu, 20/04/2023 - 10:55

Improving Health within Criminal Justice - IPH Consultation Response

Health Inequalities

Social Determinants of Health

20 Feb, 2016

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Improving Health within Criminal Justice - IPH Consultation Response

The Institute of Public Health in Ireland (IPH) believes that contact with the criminal justice system could be turned into an opportunity for improving health and wellbeing. This is an opportunity for health and social care services to identify and work with some of the most vulnerable people in our communities. It is also an opportunity to take a rights-based approach to tackling inequalities in society.

An overall theme throughout the draft strategy is for greater collaboration and a more joined-up approach from point of entry to the criminal justice system to resettlement in the community. In addition, a key theme that resonates throughout the draft strategy is the potential for criminal justice institutions as health promotion settings. IPH is pleased to see such an approach however work is required prior to point of entry to ensure health equity, and throughout the criminal justice experience to ensure equity of service provision. An overall approach of health equity would; address the inequalities that cause contact with the criminal justice system, address the
inequalities that result from contact with the criminal justice system, and address the inequalities in service provision.