The pros and cons of PPPs
Earlier this month, ADPH published an update to our policy position paper on the commercial determinants of health. It is a topic I have blogged about many times before but, in short, the commercial determinants of health is a catch all term for the various ways commercial organisations influence our health.
It is important to recognise that these commercial determinants can be positive. For example, the supply and use of products like clean water, sanitary products, and bicycles all help to maintain or improve our health. A good working environment is also a positive commercial determinant of our health because it is a commercial decision that (can) have a positive impact on our health and wellbeing.
All commercial decisions are ultimately designed to sell products and/or increase profits. However, the activities of some industries also actively contribute to escalating levels of avoidable ill-health, planetary damage and inequity. For example, just four products – tobacco, alcohol, ultra-processed foods, and fossil fuels, are linked to 9 million deaths around the world.
The industry giants behind these products – and indeed a range of other health harming products – all share a common ‘playbook’ of tactics, adopted from those used by the tobacco industry. These tactics are specifically designed to keep consumers buying their products through, for example, advertising and marketing, or lobbying the Government not to introduce policies that would reduce consumption.
The result is that as well as keeping shareholders happy, consumers are kept in a cycle of wanting, buying and using products that can cause significant harms.
As a Director of Public Health, my job is to enable and promote the positive determinants of health, while putting in place measures and initiatives that help to combat the negative.
Unfortunately, there is no one solution for overcoming the negative impact of commercial influences on our health. Instead, it is a question of making sure health harming industries are regulated in such a way that ensures everyone has the freedom to choose which products they want to buy and use. And that needs a multi-pronged approach.
One mechanism that can be helpful is the polluter pays principle – an economic policy that forces industries that produce harmful products to bear the environmental and social cost of their actions.
We have for example seen this approach used to great effect to reduce sugar content in soft drinks. The so called ‘sugar tax’ has brought about a reduction in the amount of sugar purchased in soft drinks by around 15 grams per household every week. This in turn is likely to lead to fewer children and young people becoming overweight or experiencing tooth decay, which is the biggest cause of hospitalisation in under 5s.
However, PPPs are not without risks and so, drawing on evidence from a wide range of experts, we have set out the principles and conditions that we believe must be put in place for any polluter pays policy (PPP) to operate effectively as a public health measure.
For instance, there should be a clear, evidence-based, aim that goes beyond simply raising funds. For example, that could be to bring about industry and/or population behaviour change or product design changes.
There should also be an agreed approach to calculating the level of penalty to ensure that it is proportionate to the burden the product in question places on society. It is vital though that this calculation, and the method of its collection and enforcement, is developed by people who are completely independent from the industry involved.
It is important that the tax or levy is paid by the relevant industry and not passed on to the consumer by just adding it to the price of the product. Then, the funds raised need to be ring fenced for public health and the prevention of harm, with Directors of Public Health given oversight for how it is spent at a local level.
However, even with these considerations, a PPP may not be appropriate – and these types of policies should never be used if they risk exacerbating health inequalities, or as a substitute for robust, evidence-led public health policy.
There are also a number of challenges and unintended consequences which may arise from implementing a polluter pays policy. For example, the Government could become reliant on using the money raised to fund a particular service which could potentially divert focus from trying to reduce sales and use of the harmful product.
There is also a risk that the PPP is seen as a ‘license to harm’, or that they are used by industry to promote their corporate social responsibility activities as effective which, through improved brand reputation, could provide an indirect boost to sales of the very product the policy is trying to limit.
However, as long as these risks are considered and mitigated against, PPPs can – and already do – play a significant role in supporting our efforts to reduce the scale of ill health and death that is caused by non-communicable diseases like heart disease and many cancers.
These diseases, which are indisputably linked to the consumption of harmful products, are very often entirely preventable. Figures from 2019, for example, reveal that over one in five deaths in the UK that year were preventable. Sadly though, these numbers will continue to rise if we don’t take action to limit the affordability, accessibility and appeal of health harming products and give everyone, regardless of where they live or how much money they have, the freedom to live a healthier, happier life for longer.