HEALTH AND SOCIAL SERVICES DEPARTMENT TOBACCO CONTROL STRATEGY 2015-2020 DRAFT FOR PUBLIC CONSULTATION [This page is intentionally left blank] Draft Tobacco Control Strategy: Health and Social Services Board Section A: EXECUTIVE SUMMARY States Policy: Yes Period covered Political sponsors Tobacco Control Strategy 2015 - 2020 Health and Social Services Department Programme Authors The Head of Health Improvement and the Director of Public Health, with the multi-agency Tobacco Control Strategy group. Summary This draft of a new Tobacco Control Strategy builds on and reinforces the work of the previous Strategy. It aims to continue to reduce prevalence of smoking, which is a principal cause of premature death and preventable disease in the Bailiwick, and third party exposure to second-hand smoke. It has been developed through examination of evidence of the most effective measures to reduce smoking, and engagement with partners and the public, and the document is now offered for consultation. Proposals under the new Strategy include, but are not limited to: Legislation to prevent smoking in cars carrying children, in children’s playgrounds and in designated outside eating areas: Making it more difficult for children and young people to get tobacco and continuing to raise awareness of the dangers. Introducing mandatory plain packaging (subject to legal advice): targeting and tailoring help to quit campaigns and support to socio-economic and other groups where smoking rates are highest and increasing numbers of brief interventions: Year on year increases in duty on cigarettes (RPI+10%) and tobacco (RPI+15%): Some data in the document will be refreshed following publication of the Healthy Lifestyle Survey 2013, but we do not wish to delay public and partner consultation on the proposed measures. Implications States Policy Governance Public and Media Staff and Trade Unions Staffing £ revenue – current year £ revenue – full year effect Source of revenue £ capital Yes (following consultation and HSSD Board review) None additional to current work Yes Yes None additional to current None additional to current budgets Proposes continuation of current States Strategy funding levels for 2015-21 n/a 3 Draft Tobacco Control Strategy: Health and Social Services Board CONTENTS PAGE SECTION A INTRODUCTION * EXECUTIVE SUMMARY 3 * Diagram: States Strategic Plan 5 * Programme Summary Overview 6 1 Purpose of this document 7 2 Developers of this document 8 3 Foreword from the Minister for Health and Social Services and Board members of Health and Social Services 9 SECTION B STRATEGIC FRAMEWORK 4 Strategic Framework Overview 11 * Diagram: Tobacco Control Strategy Framework 13 SECTION C KEY PERFORMANCE INDICATORS 5 SECTION D Key Performance Indicators 15 GOVERNANCE 6 Strategy Group Structure 20 7 Strategy Time-frames & Review Periods 20 LIST OF CONSULTEES 22 APPENDIX I 4 Draft Tobacco Control Strategy: Health and Social Services Board STATES STRATEGIC PLAN The Tobacco Control Strategy is a delivery programme within the States Strategic Plan. The framework of the States Strategic Plan is shown below at Figure 1. Fiscal & Economic We have a social environment and culture where there is active and engaged citizenship Environmental We have sustainable long term finances and programmes Social PURPOSE To focus government and public services on protecting and improving quality of life of Islanders, the Island’s economic future, and the Island’s environment, unique cultural identity and rich heritage. COMMUNITY OUTCOMES To enable the States to decide what they want to achieve over the medium to longterm and how they will manage or influence the use of Island resources to pursue those objectives. AIMS Figure 1: We adapt to climate change We have a balanced, internationally competitive, high value economy We have a skilled, sustainable and competitive workforce We have equality of opportunity, social inclusion and social justice As individuals we take personal responsibility and adopt healthy lifestyles We manage our carbon footprint and reduce energy consumption Our countryside, marine and wildlife are protected and preserved 5 Draft Tobacco Control Strategy: Health and Social Services Board PROGRAMME SUMMARY OVERVIEW Programme Name Period covered Programme Authors Political sponsors Related Strategies / Reviews Tobacco Control Strategy 2015 - 2020 The Head of Health Improvement & Public Health Strategy, and the Director of Public Health, with the multi-agency Tobacco Control Strategy group. Health and Social Services Department 2020 Vision for Health and Social Services Health Improvement Strategic Framework (under development in Health & Social Services) Mental Health & Wellbeing Strategy (Health & Social Services) Cancer and Respiratory Care and Maternity Care programmes (Health and Social Services) Children & Young People’s Plan (Health & Social Services) Today’s Learners: Tomorrows World (Education) Drug and Alcohol Strategy (Home Department) Disability & Inclusion Strategy (Policy Council) Supported Living and Ageing Well (Policy Council) Primary Care Review (under development) Review periods Ongoing monitoring of key performance indicators; Annual formal review of objectives and key performance indicators; 5yr review of strategic commitments. Other relevant other documents that can be accessed when reading this document Billet D’Etat III, 2008: Health and Social Service Department – Guernsey Tobacco Control Strategy, p. 391 – 415 Health Profiles for Guernsey & Alderney 2006-8 and 2010-12 Tobacco Control Profile of Guernsey and Alderney Tobacco Control Strategy: Report of Public Engagement exercises to date Research and evidence underpinning Tobacco Control measures in the proposed Tobacco Control Strategy Tobacco Control Strategy - Action Plan and Monitoring schedule 110th and 112th Medical Officer of Health reports All these are available at web-link addresses shown on page 22 6 Draft Tobacco Control Strategy: Health and Social Services Board 1. 1.1 PURPOSE OF THIS DOCUMENT The purpose of this document is to invite comment on a proposed approach for the continuation of a strategy to control the use of tobacco. This approach includes commitment to Smoking Cessation support: initiatives to reduce third party exposure to second-hand smoke: and initiatives to prevent uptake of smoking in the Bailiwick of Guernsey for the years 2015-2020. This consultation will run from July 10th to August 22nd 2014, when it will close to allow analysis and consideration of responses. The following are presented in this document and its associated Action Plan: 1.2 The Strategy’s Statement of Purpose, its Vision, the outcomes that partner organisations hope to achieve together and the strategic commitments that drive us all towards achieving these outcomes; Identification of where the Tobacco Control Strategy sits within the States Strategic Plan; Identification of areas requiring appropriate attention and action in the period 2015-2020, as based on existing evidence and professional judgement; Identification of what will be done, by whom and with whom; Identification of where we wish to be within o the short-term (a 2yr period); o the medium-term (a 5yr period); and o the long-term (a 10yr period and beyond). An indication of measures of progress. 7 Draft Tobacco Control Strategy: Health and Social Services Board 2. DEVELOPERS OF THIS DOCUMENT 2.1 This document has been produced by the Head of Health Improvement & Public Health Strategy and the Director of Public Health of the Health and Social Services Department, with input from the Tobacco Control Strategy group and key stakeholders, and advised by the Health and Social Services Board. The following organisations and representatives have been involved in development (in alphabetical order): Chamber of Commerce; Education Department; Guernsey Border Agency; Guernsey Police; Guernsey Prison; Home Department; Health and Social Services Department; Law Officers’ Chambers; Medical Specialist Group; Office of Environmental Health and Pollution Regulation; Primary Care Medical Practices (Guernsey). These organisations and individuals work in conjunction with key partners in other areas including other States of Guernsey Departments and corporate strategies such as the Education Strategy, the Transport Strategy, the Criminal Justice Strategy, and also businesses and third-sector parties where appropriate. 2.2 The production of this document, and the contribution of resources to support the Strategy’s development and ongoing maintenance, is sponsored by the States of Guernsey Health and Social Services Department. 8 Draft Tobacco Control Strategy: Health and Social Services Board 3. 3.1 3.2 3.3 3.4 3.5 FOREWORD FROM THE HEALTH AND SOCIAL SERVICES DEPARTMENT BOARD The Health and Social Services Department (HSSD) is mandated to advise the States on matters relating to the mental, physical and social well being of the people of Guernsey and Alderney. This mandate gives HSSD responsibility for:- Promoting, protecting and improving personal, environmental and public health; and - Preventing or diagnosing and treating illness, disease and disability. Smoking remains a principal cause of early death and avoidable ill-health in Islanders. The States of Guernsey has continued to support the development of Bailiwick Tobacco Control strategy since 1997, and this is essential to improve the health of the population. It makes an important contribution to: meeting government objectives through coordinated service delivery: encouraging individuals to take personal responsibility and adopt healthy lifestyles: and maintaining a healthy, competitive workforce. In 2008 the States committed to a Tobacco Control Strategy to 2013 which has been driven forward by HSSD with partners. It has achieved most of its objectives for action over the five year period. The principal aim of the strategy was to reduce the burden of death and ill-health that tobacco causes in the islands of the Bailiwick. Guernsey life expectancies at birth for men and women have improved by 4-5% over the last 15-20 years and are now some of the highest in Europe. The rates of deaths from bronchitis, emphysema and chronic obstructive pulmonary disease appear to have declined locally between 2007-2009 and 2009-2011. Smoking is the primary cause of preventable illness and premature death in Guernsey, as in the UK. Targeted tobacco control initiatives can contribute to reducing health inequalities, as research tells us that smokers are more likely to be in less well-off groups. Smoking-related illness results in absence from the workplace and from school, reducing productivity in the workforce and affecting learning in children. The societal cost of smoking-related disease and environmental impact in Guernsey is estimated at £14.25 million a year in costs of healthcare, sickness and other benefits, and States services such as cleaning up cigarette butts in the street. Reduced expenditure on these side-effects of tobacco use could be used to reduce the need for publicly generated income or to release funds to improve services. The Guernsey Young People’s Survey (2013) indicated that 32% of secondary school pupils have a parent or carer who smokes. 30% of primary school pupils surveyed have a parent or carer who smokes (a reduction from 33% in 2010). The Young People’s Survey also indicated that 6% of boys and 8% of girls in 9 Draft Tobacco Control Strategy: Health and Social Services Board secondary schools smoke occasionally or regularly. Of those who smoke ‘regularly’, 67% would like to give up. In the 2008 Healthy Lifestyle Survey, 16% of respondents reported themselves as smokers and 60% of those smokers wanted to stop. They are more likely to succeed if help is available. 3.6 3.7 Between 2010 and 2012 there were an estimated average 43 preventable cancer deaths each year: 23 preventable cardiovascular deaths each year and seven preventable deaths from respiratory disease each year in Guernsey and Alderney. Smoking is the primary cause of these preventable deaths, therefore these figures, among others, should be viewed as a baseline for onward monitoring of the success of the Tobacco Control Strategy. Partnership working with Clinicians, the Guernsey Border Agency, the Police, other States departments, business and the voluntary sector has supported achievement in tobacco control to date. This partnership is essential to future success, as all have their part to play. Deputy Mark Dorey, Minister for Health and Social Services. Deputy Martin Storey, Deputy Minister: Deputy Barry Brehaut, Board Member: Deputy Elis Bebb, Board Member: Deputy Al Brouard, Board Member. June 2014 10 Draft Tobacco Control Strategy: Health and Social Services Board Section B: STRATEGIC FRAMEWORK 4. 4.1 STRATEGIC FRAMEWORK OVERVIEW States Strategic Plan The Tobacco Control Strategy is a delivery programme within the States Strategic Plan. Figure 1 on page 5 outlines the States Strategic Plan’s purpose and aims, and also the social policy, financial and environmental outcomes that it seeks to achieve. Figure 2 on page 13 outlines the framework of the Tobacco Control Strategy and identifies the social policy and financial outcomes with which it aligns. 4.2 Strategy Purpose The purpose of the Strategy is “to reduce the health, social and financial harms associated with tobacco use in the Bailiwick through action by government and public services in conjunction with business and community partners” (see Fig.2). 4.3 Strategy Vision The Strategy has been built to achieve our vision of “Guernsey as a jurisdiction where smoke-free lifestyles are the norm” The long-term objective (10 yrs) is to achieve this vision. (Smoke free lifestyles are considered to be ‘the norm’ when prevalence of adult smoking is reduced to 5% or less.) 4.4 Outcomes The outcomes are the benefits to individual residents and the wider community in the Bailiwick, which result from government, public policy, public service and individual actions. These are: A reduction in preventable mortality from cancer and respiratory disease A reduction in numbers of adults and children who smoke A reduction in the ready availability of cheap cigarettes and tobacco An increase in the number of smoke-free environments An increase in the number of people recorded by Quitline as moving towards a smoke-free future 11 Draft Tobacco Control Strategy: Health and Social Services Board 4.5 Priority Areas of Focus The priority areas of focus are those areas where we will concentrate our efforts. These areas have been chosen through examination of relevant evidence, and through professional and political judgement. They are: Preventing uptake of smoking and encouraging smokers to try to quit Protecting adults and children from second-hand smoke Helping people who want to stop smoking to do so successfully In each area of focus we have set specific objectives as shown in our Action Plan. 4.6 Strategic Commitments The strategic commitments enable and drive towards the delivery of outcomes. These are: RISK MANAGEMENT - Monitor and manage social and economic risk factors in implementation of strategic initiatives. COMMUNICATION - Proactively engage with the public so that the Strategy is reflective of and responsive to the concerns of the community. Maintain open and responsive communication between strategic partners. Use appropriately targeted effective messages to encourage smokers to quit. EQUALITY - Ensure equity of access to Quitline services and respond to the needs of a diverse community. 4.7 Objectives Objectives are shown within an action plan which covers the period 2015 - 2020 and includes short (2yrs) and medium term objectives (5yrs). These contribute to the achievement of outcomes. All objectives have an “end milestone”, or an indication of how we will know the objective has been achieved. 4.8 Key Performance Indicators To define achievement of our aims and objectives, a limited number of high level ‘key performance indicators’ are set against outcomes in order to give us broad indications of achievement. Further detail about key performance indicators is provided on pages 14-19. 12 Draft Tobacco Control Strategy: Health and Social Services Board 13 Figure 2: COMMUNITY OUTCOMES To reduce the health, social and financial harms associated with tobacco use in the Bailiwick through action by government and public services in conjunction with business and community partners KEY ENABLERS STRATEGIC COMMITMENTS PRIORITY AREAS OF FOCUS OUTCOMES VISION As individuals we take personal responsibility and adopt healthy lifestyles STRATEGY PURPOSE Tobacco Control Strategy Framework We have equality of opportunity, social inclusion and social justice We have a skilled, sustainable and competitive workforce Our vision is of Guernsey as a jurisdiction where smoke-free lifestyles are the norm A reduction in numbers of adults and children who smoke A reduction in preventable mortality from cancer and respiratory disease An increase in the number of smoke-free environments PROTECTING ADULTS AND CHILDREN FROM SECOND-HAND SMOKE A reduction in the ready availability of cheap cigarettes and tobacco An increase in the number of people recorded by Quitline as moving towards a smoke-free future PREVENTING UPTAKE OF SMOKING AND ENCOURAGING SMOKERS TO TRY TO QUIT HELPING PEOPLE WHO WANT TO STOP SMOKING TO DO SO SUCCESSFULLY RISK MANAGEMENT Monitor and manage social and economic risk factors in implementation of strategic initiatives. COMMUNICATION Proactively engage with the public so that the Strategy is reflective of and responsive to the concerns of the community. Maintain open and responsive communication between strategic partners. Use appropriately targeted effective messages to encourage smokers to quit. EQUALITY Ensure equity of access to Quitline services and respond to the needs of a diverse community GOVERNANCE Collective investment of expertise so as to ensure that the right organisations are involved at the right time EVIDENCE Application of international and local evidence to support legislation, campaigns, and decision-making and ensure cost-effective local practice. Draft Tobacco Control Strategy: Health and Social Services Board Section C: KEY PERFORMANCE INDICATORS 5. KEY PERFORMANCE INDICATORS 5.1 It is important that strategy is monitored on an ongoing basis in order to assess how we are performing against our desired outcomes. Key performance indicators are therefore set against each outcome. We will formally review and publish results of high level key performance indicators on an annual basis. 5.2 There may be times when there is little data to bench mark against and therefore some data will only become meaningful when it has been collected over a number of years. 5.3 We recognise that other HSSD and pan-States strategies for improving health will have an effect on the achievement of the key performance indicators for the first outcome of this strategy. Nevertheless, the evidence shows that tobacco control remains the most effective way to reduce the burden of early death (premature mortality) and preventable illness (morbidity). 5.4 The data gathered can give a broad indication of how successful our efforts are, and help us to make evidence-based decisions on what to do so as to achieve our targeted outcomes and, ultimately, our vision of “Guernsey as a jurisdiction where smoke-free lifestyles are the norm” 5.5 Our objectives (what we propose to do) contribute to the achievement of our outcomes. All objectives have an “end milestone”, or an indication of how we will know the objective has been achieved. These objectives will be shown within our action plan and will be monitored on a quarterly basis. 14 Draft Tobacco Control Strategy: Health and Social Services Board Outcome 1 A reduction in preventable mortality from cancer and respiratory disease Data-source Frequency of measure KPI 1.1 Life expectancy at birth for people in Guernsey in 2020 exceeds or is equal to 79.7 years for men and 84.1 years for women The Greffe and HSSD Public Health Intelligence Annual KPI 1.2 Rates of premature* death from cancer decline over a ten year period from a baseline of 94.9 per 100,000 in 2013** HSSD Public Health Intelligence Annual KPI 1.3 Rates of premature death from respiratory disease decline over a ten year period from a baseline of 15.1 per 100,000 in 2013 HSSD Public Health Intelligence Annual KPI 1.4 Rates of premature death from cardiovascular disease decline over a ten year period from a baseline of 49.4 per 100,000 in 2013 HSSD Public Health Intelligence Annual Incidence rates of lung cancer show reduction over a ten year period from the 2007-2011 baseline of an average of 60 per 100,000 population per year HSSD Public Health Intelligence Annual KPI 1.5 * Premature death = < 75 years. ** All rates are calculated as age standardised (Age Standardised Rates = ASR). 15 Draft Tobacco Control Strategy: Health and Social Services Board Outcome 2 A reduction in numbers of adults and children who smoke Data-source Frequency of measure KPI 2.1 Prevalence of adult smoking in Guernsey stands at 10% or less as reported in the Healthy Lifestyle Survey by 2020 Guernsey and Alderney Healthy Lifestyle Survey Five yearly KPI 2.2 Prevalence of smoking in ‘occasional and regular’ smoking in secondary school pupils stands at 5% or less by 2020 as reported in the Young People’s Survey Health-Related Behaviour Survey: Education Three yearly KPI 2.3 Percentage of school pupils reporting a parent who smokes shows a reducing trend by 2020 as reported in the Young People’s Survey Health-Related Behaviour Survey: Education Three yearly KPI 2.4 Prevalence of smoking in lower socio-economic groups reduces as reported in the Healthy Lifestyle Survey Guernsey and Alderney Healthy Lifestyle Survey Five yearly KPI 2.5 Prevalence of smoking in pregnant women (at date of delivery) shows a reducing trend over ten years HSSD Maternity services Annual 16 Draft Tobacco Control Strategy: Health and Social Services Board Outcome 3 A reduction in the ready availability of cigarettes and cheap tobacco Data-source Frequency of measure Price of cigarettes increases through year on year increases in duty (RPI+10%) Treasury and Resources Annual KPI 3.2 Price differential between cigarettes and tobacco reduces through year on year increases in tobacco duty (RPI+15%) Treasury and Resources Annual KPI 3.3 Levels of cigarettes and tobacco importation show a reducing trend over ten years Guernsey Border Agency Annual KPI 3.4 Options for reducing dutyfree allowances of cigarettes and tobacco are explored in conjunction with Jersey Treasury and Resources and Guernsey Border Agency Annual KPI 3.1 17 Draft Tobacco Control Strategy: Health and Social Services Board Outcome 4 An increase in the number of smokefree outdoor environments Data-source Frequency of measure Legislation prepared and implemented to prevent smoking in vehicles carrying children States Report and Enabling law Once at 2 year review Legislation prepared and implemented to prevent smoking in children’s playgrounds and designated outside eating areas States Report and Enabling law Once at 2 year review KPI 4.3 Campaigns prepared and delivered to raise awareness of effects of second-hand smoke in grounds of States properties Health Promotion (HSSD) Annual KPI 4.4 Audit and plan for a phased approach to introducing smoke-free grounds in States properties Tobacco Control Strategy Group Once at 2 year review Guernsey becomes a jurisdiction where smokefree lifestyles are the norm (prevalence of adult smoking is 5% or less) Guernsey and Alderney Healthy Lifestyle Survey 2025 (long-term aim) KPI 4.1 KPI 4.2 KPI 4.5 18 Draft Tobacco Control Strategy: Health and Social Services Board Outcome 5 An increase in the number of people moving through Quitline to a smoke-free future Data-source Frequency of measure KPI 5.1 Quitline records an average of 450 four-week quits per annum from 2014-2017 Quitline with Health Promotion HSSD Annual KPI 5.2 Audit equity of access to Quitline services and identify groups underrepresented in services Quitline with Health Promotion HSSD Annual KPI 5.3 90% of offenders who entered Guernsey Prison as smokers are pro-actively offered continuing Quitline support on release from 2014 to 2017 Prison HealthCare service: Quitline HSSD Annual The Health Trainer service will work with a minimum of 50 clients per year from 2014 to 2017 inclusive, to support demonstrable positive behaviour change, including referrals to Quitline and ongoing support for quitters Quitline with Health Promotion HSSD Annual KPI 5.4 19 Draft Tobacco Control Strategy: Health and Social Services Board Section D: GOVERNANCE 6. 6.1 STRATEGY GROUP STRUCTURE The Tobacco Control Strategy group is a multi-agency group, comprising membership from: Education Department; Guernsey Border Agency; Guernsey Police; Guernsey Prison; HSSD clinical staff; Medical Specialist Group; Office of Environmental Health and Pollution Regulation; Primary Care. Representatives from the Environment Department and Treasury and Resources Department have also attended for specific items. 6.2 The Tobacco Control Strategy group reports to the Health Improvement Programme Group. The Health Improvement Programme Group reports through the Director of Public Health to the Health and Social Services Board 7. STRATEGY TIME-FRAMES & REVIEW PERIODS 7.1 Our Action Plan is made up of a series of objectives that aim to be achieved across short, medium and long term time frames. 7.2 Progress on actions will be reviewed by the Tobacco Control Strategy group on an annual basis, and reported to the HSSD Board, and other Boards as relevant, through the Director of Public Health. The milestones will be refreshed in 2017 for the second phase of Strategy delivery. An interim public report on the success of this Strategy in achieving its milestones will be produced by December 2017 20 Draft Tobacco Control Strategy: Health and Social Services Board APPENDIX I: LIST OF CONSULTEES The range of organisations, including those listed below will be circulated with this document for consultation in summer 2014. Following analysis of consultation response: the document will be finalised and presented to the States by Health and Social Services. Airport and Harbour Authorities Chamber of Commerce and retailers Channel Islands Tobacco Importers & Manufacturers Association (CITIMA) Office of Environmental Health and Pollution Regulation General Public and the Media GP Practices Guernsey Border Agency: Police and Prison Health and Social Services Directors and Managers leading on associated Strategies Health Improvement Programme group and Tobacco Control Strategy group Health and Safety Executive Institute of Directors Law Officers of the Crown Pharmacies and Dentists Policy Council, States of Guernsey Schools and Parent Teacher Associations, GTA University Centre and College of Further Education Sports Commission States Departments Trading Standards Voluntary Sector and associated special interest groups Youth Commission 21 Draft Tobacco Control Strategy: Health and Social Services Board APPENDIX 2: WEB-LINKS TO RELATED DOCUMENTS Other relevant documents that can be accessed when reading this strategy are shown here with web-links to take you to the documents Consultation response form 2014 Web-link: http://www.gov.gg/healthandwellbeing Billet D’Etat III, 2008: Health and Social Service Department – Guernsey Tobacco Control Strategy, p. 391 – 415 Web-link: http://www.gov.gg/CHttpHandler.ashx?id=3851&p=0 Health Profiles for Guernsey & Alderney 2006-8 and 2010-12 Web-links: http://www.gov.gg/CHttpHandler.ashx?id=74886 and http://www.gov.gg/CHttpHandler.ashx?id=87388&p=0 Tobacco Control Profile of Guernsey and Alderney Web-link: http://www.gov.gg/healthandwellbeing This document is in the process of being updated with new data from the Guernsey Healthy Lifestyle Survey 2013 and will be posted as soon as possible. Tobacco Control Strategy: Report of Public Engagement exercises to date Web-link: http://www.gov.gg/healthandwellbeing Research and evidence underpinning Tobacco Control measures in the proposed Tobacco Control Strategy Web-link: http://www.gov.gg/healthandwellbeing Tobacco Control Strategy - Action Plan and Monitoring schedule Web-link: http://www.gov.gg/healthandwellbeing This document is undergoing final checks and will be posted as soon as possible. 110th and 112th Medical Officer of Health reports Web-links: http://www.gov.gg/CHttpHandler.ashx?id=2955&p=0 and http://www.gov.gg/CHttpHandler.ashx?id=4790&p=0 22 Draft Tobacco Control Strategy: Health and Social Services Board 23
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