UCSF CTCRE submission to UN on Draft Sustainable Development Goals; please submit your comments by June 21

The UN is in the process of preparing a new set of Sustainable Development Goals, a follow-on to the existing Millennium Development Goals.  This is a very important document because it guides a wide range of government and NGO policies worldwide.  The final document, goals and targets will be approved by the UN Member States in September.
 
The Co-Chairs of the Open Working Group on Sustainable Development Goals released the Zero Draft of the document proposing goals and targets for the post-2015 agenda and invited comment.  The Zero Draft is long, but do not be intimidated.  Our comments refer to the relevant sections for tobacco, so you can jump to them. 
  
The good news is that the draft specifically addresses accelerating implementation of the WHO FCTC and mentions decreasing premature mortality from NCDs.  However, there is not enough specificity about tobacco, the draft does not list the FCTC as part of global commitments, and does not exclude the tobacco industry from public-private, as required by the FCTC.  This exclusion could be exploited by the tobacco companies as an endorsement of their “corporate social responsibility” efforts that are designed to undermine implementing the FCTC and effective tobacco control policies.
 
To date there have been few comments submitted by tobacco control organizations, which could lead to missing an important opportunity to influence global and national public health policies for years to come.
 
We submitted the following comment suggesting that the Working Group add specific FCTC-language, including the importance of implementing FCTC Article 5.3,  to the goals and highlight that tobacco control is key for sustainable development (as evidence by hundreds of published papers and reports).  
 
It is very important that tobacco be an important element of the Sustainable Development Goals, which will only happen if public health suggests it.
 
Submitting comments is very easy.  Just click here and type your comments into the boxes on the form. 
 
The deadline is June 21. Please act now.
 
Here is what Stella Bialous and I submitted on behalf of  the UCSF Center for Tobacco Control Research and Education.  Suggested additional text is in [brackets].  We did not suggest any deletions.  Feel free to use this material to frame your comments:
 
Overall Feedback
 
The University of California, San Francisco Centre for Tobacco Control and Education, a WHO Collaborating Center, applauds the Member States’ commitment to poverty eradication and the recognition that health-related outcomes are integral to sustainable development.  We support the need to accelerate the implementation of the UN’s WHO Framework Convention on Tobacco Control as integral to achieve the SDG goals. Tobacco use leads the world as a cause of premature death and disease, with a heavier burden on LMICs. It is well documented that the tobacco production chain threatens food security, water supply and the environment. Additionally, scientific evidence demonstrates that tobacco use leads to poor prognosis and treatment outcomes in people affected by HIV-AIDS and tuberculosis. Therefore, strengthening tobacco control will be pivotal to reach the SDG goals by 2030. Several UN documents note the deleterious role of the tobacco industry in reaching health and development and urge Member States to protect its policies against the commercial and other vested interests of the tobacco industry. We encourage Member States to specifically include protection against the tobacco industry interference as part of the SDG. Additionally, In recognition of the link between tobacco control and sustainable development, recently highlighted by the UNDP, add the UN’s WHO Framework Convention on Tobacco Control to the UN processes listed on Page 8 paragraph 4.
 
Intro paragraph 23
 
In light of the UN High-Level Meeting on NCDs (on 19-20 September 2011) and scientific evidence demonstrating the most effective methods of tackling NCDs, in the last sentence, add language to read:
 
At the same time we shall devote greater effort to tackling non-communicable diseases [in order to reach the WHO global targets for NCDs through policies and programs the reach beyond individual behavior.]
 
Intro paragraph 37
 
The tobacco industry is excluded from partnering with governments in the Guidelines for Implementation of Article 5.3 of the UN’s WHO Framework Convention on Tobacco Control. Added to the scientific evidence of the negative influence of the tobacco industry and tobacco products production chain to the environment, food security, health and development, add an exception to read:
 
We emphasize more generally the critical importance of engaging all relevant stakeholders in implementation of the new Agenda [, as long as there are no real or perceived conflict of interests between the new Agenda and the stakeholders, exemplified by the tobacco industry as specified in UN WHO Framework Convention on Tobacco Control Article 5.3]…
 
Feedback on Proposed Revision for Target 17.2
 
Add a new paragraph  (and re-number as appropriate) 17.20 to read:
[17.20. Protect the public interests and the Agenda by ensuring that there are no real or perceived conflict of interests between stakeholders involved in partnerships with government, as exemplified by the tobacco industry [in accordance with UN WHO FCTC Article 5.3.]
 
Means of Implementation and the Global Partnership (Pages 22-28)
 
Feedback on MOI for Goal 3
 
3.a: add to read:  Strengthen the implementation of the World Health Organization Framework Convention on Tobacco Control in all countries, as appropriate[, recognizing the fundamental conflict of interest between the tobacco industry and public health as recognized in UN WHO FCTC Article 5.3].
 
3d: add NCDs to read: Strengthen the capacity of all countries, in particular developing countries, for early warning, risk reduction and management of national and global health risks[, including risks for NCDs.]