Assessing the evidence base of tobacco industry submissions to public consultations: The case of ‘plain packaging’ of tobacco products in the UK

BACKGROUND
The UK’s public consultation on ‘plain packaging’ of tobacco products generated an unprecedented volume of responses. Given the track record of the tobacco industry’s misuse of science to oppose policy change, and the fact that plain packaging has only recently been introduced in a single jurisdiction – Australia, December 2012 – how can policymakers weigh up evidence submitted to them? In this paper, the authors deliver an analysis of the relevance and quality of evidence on ‘plain packaging’ submitted to the UK Department of Health by the UK’s four largest tobacco companies to support their argument that plain packaging will not meet associated public health objectives for disease prevention.
METHODS
We conducted a case-study based comparative analysis of the quality of evidence cited in tobacco industry submissions consultation with that presented in favour of ‘plain packaging’ in a ‘Systematic Review ’ of the literature. We coded each piece of evidence for relevance of subject matter and three quality criteria - funding source, primary or secondary research and peer-review status – and compared the relevance and quality of the two bodies of evidence.
RESULTS
We identified 101 pieces of evidence which present arguments about whether or not plain packaging will influence smoking behaviour – 64 from industry submissions, and 37 from the ‘Systematic Review’. Our preliminary findings are that the tobacco industry cited10 sources of evidence which critique the evidence for ‘plain packaging’. These were funded by the tobacco companies and were not peer-reviewed. The tobacco companies cited a further 55 sources of new evidence, 34 presenting primary research. Of these 34, 2 related directly to ‘plain packaging’, one of which was funded by the tobacco industry, and 14 of the 34 appeared in peer-reviewed journals. In contrast, all of the 37 ‘Systematic Review’ papers were funded independently of the tobacco industry and presented primary research directly related to plain packaging. 22 of these reports appeared in peer-reviewed journals.
CONCLUSIONS
Our preliminary findings suggest that evidence cited by the tobacco industry to oppose ‘plain packaging’ is, overall, not as relevant or robust as the growing body of evidence in favour of this regulatory proposal. We propose that an evidence assessment framework, based on four criteria – relevance of research, independence of funding, nature of research and peer-review may offer a structure by which policy-makers can make an assessment of the evidence base of submissions to public consultations, especially where response volumes are high.