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EQUALITY IMPACT ASSESSMENT TOOL

The council has a statutory duty to consider the impact of its decisions on age, disability, gender reassignment, pregnancy & maternity, race, religion or belief, sex (gender) and sexual orientation. The Council also has a duty to foster good relations between different groups of people and to promote equality of opportunity. Completing an Equality Impact Assessment (EIA) is the simplest way to demonstrate that the Council has considered the equality impacts of its decisions and it reduces the risk of legal challenge. EIAs should be carried out at the earliest stages of policy development or a service review, and then updated as the policy or review develops. EIAs must be undertaken when it is possible for the findings to inform the final decision. Keep all versions of your EIA. An EIA should be finalised once a final decision is taken. When should you undertake an EIA?

You are making changes that will affect front-line services

You are reducing the budget of a service, which will affect front-line services

You are changing the way services are funded and this may impact the quality of the service and who can access it

You are making a decision that could have a different impact on different groups of people

You are making internal reorganisations that will result in staff changes including Transfer of Undertakings (TUPE), redundancies, change in job roles or terms and conditions.

EIAs also need to be undertaken on how a policy is implemented even if it has been developed by central government (for example cuts to grant funding)

Section 1 of the EIA Tool: Initial Screening, will help you decide whether a full EIA is necessary

Who should undertake the EIA?

The person who is making the decision or advising the decision-maker Further Guidance

Step-by-Step Guidance to the questions

An EIA e-learning module is available for all Westminster staff: www.learningpool.com/westminster/course/view.php?id=159

Please contact the Equalities lead to inform them when you begin and then complete an EIA: equalities@westminster.gov.uk

SEB will monitor compliance with the requirement to complete EIAs.

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Title of Proposal Reducing the Harm of Shisha: Towards a Strategy for Westminster (2015)

Lead Officer i. Collette Willis ii. Principal Policy Officer iii. Policy, Performance and Communications iv. 020 7641 2387 / cwillis@westminster.gov.uk

Has this project, policy or proposal had an EIA carried out on it previously? If yes, please state date of original and append to this document for information. Yes No x Date of original EIA:

Version number and date of update You will need to update your EIA as you move through the decision-making process. Record the version number here and the date you updated the EIA. Keep all versions so you have evidence that you have considered equality throughout the process. 1.

SECTION 1: Initial screening: Do you need to complete an Equality Impact

Assessment (EIA)? Not all proposals will require an EIA, this initial screening will help you decide if your project or policy requires a full EIA by looking at the potential impact on any equality groups. .

1.1 What are you analysing?

What is the project, policy or proposal?

What is the purpose of the policy/project/activity/strategy?

In what context will it operate?

What results are intended?

Why is it needed?

Who is it intended to benefit and how?

Who, potentially, could this project, policy or proposal have a detrimental effect on, and how?

What is the project, policy or proposal? Publication a draft strategy on managing the impact of shisha smoking ‘Reducing the Harm of Shisha: Towards a Strategy for Westminster’ for public consultation. What is the purpose of the policy/project/activity/strategy? Shisha smoking can have an adverse impact on health arising from individuals using waterpipes and from secondary smoke and fumes. The harmful impact on health is recognised at a national and international level, including bodies such as Public Health

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England and the World Health Organisation. Studies have shown that many of those who smoke shisha are unaware of its impact on health, believing it is ‘safer’ than cigarette smoking. Shisha smoking can also affect the quality of life for residents, as it now takes place in outdoor spaces and can occur late into the evening which can disturb amenity through noise and fumes. Current regulatory powers have not enabled the council to work effectively with shisha businesses to ensure they are compliant within a reasonable timeframe. There is no legislation that specifically regulates shisha smoking. Premises serving alcohol, and premises serving late night refreshment (hot food and hot drink between 11pm and 5am), require a licence and can have conditions imposed to control the operation. Premises offering shisha smoking are not required to have a licence. The purpose of the strategy, therefore, is to promote the health of Westminster’s residents, workers and visitors by raising awareness of the impacts on health; and to protect the amenity of neighbourhoods in Westminster, particularly residential amenity by enabling businesses to be compliant with existing regulations and to lobby for a more effective regime to manage the impacts on amenity. In what context will it operate? With the responsibility for public health having transferred to local councils on 1st April 2013, the city council has greater scope to take account of health impacts in its service provision and decision making. Some of the health and amenity concerns arising from shisha smoking can be managed using a range of regulatory powers - premises need to comply with a range of regulations that come under the council’s licensing, trading standards, planning and enforcement functions. The strategy encompasses the wider issues of health and wellbeing, information and awareness, lobbying, in addition to enforcement and regulatory powers. What results are intended? There are three key strands to the strategy:

to educate and engage - By engaging with both shisha smokers and businesses to raise awareness of the health and amenity impacts of shisha smoking, the objective is to help individuals and businesses make informed choices.

to regulate the activity - There are a range of regulatory tools which can be used to limit the impact of shisha smoking, involving a number of different services and agencies. The strategy aims to best utilise these available powers in a coordinated and cost effective way.

to pursue lobbying and partnership – There is no legislation that specifically regulates shisha smoking. Current regulatory powers have not enabled the council to work effectively with shisha businesses to ensure they are compliant within a reasonable timeframe. The strategy includes the aim to lobby for changes to legislation which enable premises to be better regulated and managed to reduce the impact on residential amenity. Other local authorities and organisations, both in London and nationally, have identified the need to address the impacts arising from shisha smoking. It is important to work in partnership and learn from relevant agencies.

The overall aim of the strategic approach to shisha is not to prevent this activity but to manage the way in which it is done to ensure that it causes as little harm and nuisance as possible, to smokers and to the wider public. We also seek to ensure that people who choose to smoke shisha are equipped with clear and reliable information about the risks.

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Why is it needed? As mentioned above, shisha smoking can have an adverse impact on health arising from individuals using waterpipes and from secondary smoke and fumes, and there are often misconceptions about the health impact of shisha smoking. Shisha smoking can also affect the quality of life for residents, as it now takes place in outdoor spaces and can occur late into the evening which can disturb amenity through noise and fumes. Current regulatory powers have not enabled the council to work effectively with shisha businesses to ensure they are compliant within a reasonable timeframe. The number of shisha premises in Westminster has risen rapidly in recent years, Premises Management Licensing Enforcement recorded approximately 60 premises in 2010, rising to 122 in 2015, with new premises continuing to open. Shisha bars are now establishing themselves outside of what was thought of as the more ‘traditional’ areas for such activities in the north west of the City, on and around the Edgware Road and Harrow Road/Church Street, although the greatest concentration of shisha bars remains in the Edgware Road Stress Area (36% of all known premises). Studies have shown that many of those who smoke shisha are unaware of its health impacts; perhaps wrongly believing that because the smoke is inhaled through a flavoured waterpipe that it is ‘safer’ than traditional cigarette smoking. Whilst studies looking at the long term health effects of shisha smoking are limited, there is increasing amounts of evidence which suggest the health effects of shisha smoking are similar to or worse than those of cigarette smoke. Recent studies and reports have indicated the dangers in relation to shisha smoke’s heavy metals content. Although there is a lack of research into the health effects of second hand smoke specific to waterpipe smoking, the evidence concerning the health risks for passive smokers is well documented. Short term effects include eye irritation, headaches, coughs, sore throats, dizziness, and nausea. Longer term, passive smoking can lead to lung cancer and ischaemic heart disease in adults, and to respiratory disease, cot death, middle ear infections and asthma attacks in children. There is some evidence of an association with stroke, tuberculosis, and a susceptibility to infectious diseases such as pneumonia (ASH, 2011). The World Health Organisation updated its advisory note on Waterpipe Tobacco Smoking in 2014, which acknowledges the increasing body of research on the health hazards and increasing prevalence of waterpipe smoking in many countries. It also noted there remains a prevailing public misconception that waterpipe smoking is ‘safer’ than cigarette smoking. In addition to its health impacts, shisha smoking and the premises in which it takes place can give rise to or contribute towards a number of amenity and quality of life issues. Noise pollution is a significant problem in Westminster and can have serious effects on the health of the city’s residents as well as having adverse impacts on general wellbeing and reduce quality of life. A review of enforcement action in Hyde Park and Bryanston & Dorset Square in 2012 established that shisha premises were often not compliant with a range of planning and other licensing regulations including complaints regarding nuisance from noise and smoke. The impact from two premises was having such a negative impact on neighbours that the council secured anti-social behaviour orders to halt the activity.

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Who is it intended to benefit? The strategy aims to promote the health of Westminster’s residents, workers and visitors; to protect the amenity of neighbourhoods in Westminster, particularly residential amenity, and to enable businesses to operate effectively and to be well managed. Raising the awareness of shisha smokers of the health risks will help them to make informed choices about smoking. The research carried out by Westminster PCT in 2009 suggested that the groups most likely to smoke shisha in Westminster are young people and Arabic families. Better engagement with businesses about the range of regulations that need to be complied should help to enable well managed premises and reduce the need for enforcement, and together with more effective regulation/enforcement should help to reduce adverse impacts on the amenity of surrounding neighbours. Who, potentially, could this project, policy or proposal have a detrimental effect on, and how? The research carried out by Westminster PCT in 2009 suggested that the groups most likely to smoke shisha in Westminster are young people and Arabic families. Positive impacts of Strategy:

Raising awareness of the health impacts of shisha smoking will have improved health outcomes in reducing smoking, and prevention of uptake. As well as improving the health outcomes of smokers and potential smokers, people will also be protected from the impact of secondary smoke. These aims align with the Tobacco Control Strategy priorities which aim to reduce the number of young people who smoke, and reducing smoking in black and minority ethnic groups who have higher rates of smoking compared with other ethnic groups – also identified as groups most likely to smoke shisha

Continued and coordinated regulation will help to control the associated impacts of smoking shisha which impact the amenity of neighbouring residents such as noise and smells, particularly late at night. Control of structures on the highway will ensure safer passage for pedestrians, and can particularly benefit those with disabilities.

Negative impacts of strategy:

Targeting shisha smoking and shisha premises, an activity which has traditionally been associated with particular ethnicities and cultures could be perceived as the city council targeting those groups in particular. In addition, the activity is considered an important social activity for certain groups, sometimes in particular for those who do not drink alcohol on religious grounds. However, the strategy does not seek to prohibit shisha smoking, but seeks to provide people with information to make informed decisions about smoking, and to ensure the activity is carried out in a responsible manner, which is compliant with the necessary regulations.

1.2 From a service user and staff perspective, does the project, policy or proposal have the potential to disproportionately impact on any of the following groups? If so, is the impact positive or negative?

None Positive Negative Not sure

Disabled people x

Particular ethnic groups x x

Men or women (include impacts due to pregnancy/

x x

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maternity)

People or particular sexual orientation/s

x

People who are proposing to undergo, are undergoing or have undergone a process or part of a process of gender reassignment

x

People on low incomes x

People in particular age groups

x x

Groups with particular faiths and beliefs

x x

Are there any other groups that you think may be affected negatively or positively by this project, policy or proposal?

If the answer is “negative” or “unclear” consider doing a full EIA

1.3

What do you think that the overall NEGATIVE impact on groups and communities will be? None or minimal impact would be where there is no negative impact identified, or where there will be no change to the services for any groups. Wherever a negative impact has been identified you should consider undertaking a full EIA by completing the rest of the form.

None / Minimal Significant

x

1.4 Using the screening and information in questions 1.2 and 1.3, should a full assessment be carried out on the project, policy or proposal?

Yes x No

1.5 How have you come to this decision?

Because potential negative impacts have been identified for two particular groups.

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SECTION 2: EQUALITY IMPACT ASSESSMENT Building an Evidence Base: What do you know? This section will help you build your evidence base and interpret what the likely impact will be of your service. Complete this section if your proposal is service user related. If your proposal only affects staff, go to section 2.2

2.1 Build up a picture of who uses/will use your service or facility and identify who are likely to be impacted by the proposal

If you do not formally collect data about a particular group then use the results of local surveys or consultations, census data, national trends or anecdotal evidence (indicate where this is the case). Please attempt to complete all boxes.

How many people use the service currently? What is this as a % of Westminster’s population?

Westminster has an estimated residential population of approximately 230,000. This swells to over 1m everyday as a result of the influx of workers, visitors and tourists that visit the area. The proposed shisha strategy will affect shisha smokers (which can include residents, workers and visitors), those running shisha premises and residents and businesses neighbouring shisha premises. Research commissioned by Westminster PCT (One Deep Breath, 2009) found that the Edgware Road area was the epicentre for public waterpipe smoking, with smokers comprising of both local residents from cultures with a tradition of waterpipe smoking as well as tourists travelling to the area for this purpose. The research also undertook an analysis of shisha smoking by residents in Westminster. The task of comprehensively mapping the prevalence of shisha smoking amongst the residential population would require a large-scale quantitative study, therefore they sought to discover patterns of behaviour in a segmentation of the population into a group with certain defining characteristics and behaviours. They undertook community engagement to build a picture of the populations that predominantly smoke the waterpipe that has uncovered a particular segments of the Westminster Residential Community for which waterpipe smoking is an important part of their lives; Westminster youth groups and Westminster Arabic families.

Disabled people A potential impact of shisha smoking is the placing of structures on the highway which can cause obstruction and potentially have a greater impact on those with disabilities and impaired mobility.

Indicator

Number %(as a % of

18-64s)

People aged 18-64 estimated to have a moderate or serious physical disability

14,286 8.6%

People aged 18-64 estimated to have a common mental disorder

11,894 7.2%

People aged 18-64 estimated to 4068 2.5%

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have a learning disability

Number % (as a %

of 65+) Older People: Total Population aged 65 and over with a limiting long-term illness

12,142 44%

Source: PANSI & POPPI, Oxford Brookes University 2014, (all estimates are based on PANSI (18-64) and POPPI (65+) predictions for cohort and wider population in 2015.

The information collected by Oxford Brookes University on limiting long-term illness does not equate to the definition of disability in the Equality Act 2010. However, it is the best indicator of the number of disabled persons in Westminster.

Particular ethnic groups

The research carried out for Westminster PCT in 2009 suggested that the groups most likely to smoke shisha in Westminster are young people and Arabic families. After examining global data on the countries exhibiting high waterpipe smoking prevalence, the research did focus its consultation on those communities likely to bring their waterpipe smoking practices with them when they migrate to other cultures. These communities included: Arab Gulf States / Syrian / Lebanese / Iraqi / Iranian / Palestinian /Jewish / Ethiopian / Turkish / Eritrean / Kenyan / Bangladeshi) and were found to be focused around the North West (Queens Park / Harrow Road / Edgware) and Church Street, Hyde Park, Lancaster Gate, Bryanston and Dorset Square and Regents Park.

Men or women (include impacts due to pregnancy/maternity)

The Westminster PCT research (2009) noted a fairly even gender split. The report noted the risks to pre-natal health, pregnant women who smoke put their babies at risk of low birth rate, low Apgar score, risk of miscarriage, premature delivery and sudden infant cot death. The report also referred to information from the Arab National Council Against Addiction & Narcotics which found that some of the residents questioned admitted to smoking waterpipes when they were pregnant and post-natal suggesting that there was smoking around their infants Whole population data for Westminster: Age & Sex

Ages Persons Males Females Persons Males Females

All Ages 226,841 116,590 110,251 100% 51.4% 48.6%

0-4 13,749 7,058 6,691 6.1% 3.1% 2.9%

5-9 10,864 5,555 5,309 4.8% 2.4% 2.3%

10-14 9,295 4,751 4,544 4.1% 2.1% 2.0%

15-19 9,681 5,186 4,495 4.3% 2.3% 2.0%

20-59 147,394 77,309 70,085 65.0% 34.1% 30.9%

60-64 9,483 4,440 5,043 4.2% 2.0% 2.2%

65-74 14,344 6,956 7,388 6.3% 3.1% 3.3%

75-84 8,650 4,023 4,627 3.8% 1.8% 2.0%

85+ 3,381 1,312 2,069 1.5% 0.6% 0.9%

Source: *Mid Year Estimates 2013, ONS .

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Pregnancy & Maternity

Live births by local authority of usual residence of mother, numbers, General Fertility Rates and Total Fertility Rates, in 2013

Live births

General Fertility Rates1

Total Fertility Rates2

Westminster 2,677 48.3 1.25

London 128,332 64.0 1.74

England 664,517 62.4 1.85

Source: 2013 data, published by ONS 2014

People of particular sexual orientations

Not applicable.

People who are proposing to undergo, are undergoing or have undergone a process or part of a process of gender reassignment

Not applicable.

People on low incomes

Information not available. The Westminster PCT research (2009) did not show any dominant socio-economic group and indicated further research was required. Not applicable

People in particular age groups

Research carried out by Westminster PCT in 2009 suggested that the groups most likely to smoke shisha in Westminster are young people and Arabic families. The report noted there was also a global trend of increasing take up of shisha smoking in the young people, and may be considered an important social activity for this group. It should be noted that where shisha smoking involves the use of tobacco, trading standards legislation on underage purchase applies. The Adult Services & Health Policy and Scrutiny Committee commissioned a research report on the ‘Public Health Implications of Shisha Smoking in London’ which noted there are a number of London-based studies which identify a growing shisha prevalence, especially among young people, university students and those of ethnic backgrounds typically associated with shisha smoking. The JSNA briefing (2013) on shisha smoking noted that there is recent evidence that water pipe smoking is a gateway into cigarette smoking for young people. The Westminster PCT report (2009) also noted that as with cigarette smoking, waterpipe smoking involves potential health hazards to non-smokers – from both tobacco smoke and smoke from the fuel.

1 The General Fertility Rate (GFR) is the number of live births per 1,000 women aged 15-44. The GFRs have been calculated using the

2013 mid-year population estimates. 2 The Total Fertility Rate (TFR) is the average number of live children that a group of women would bear if they experienced the age-

specific fertility rates of the calendar year in question throughout their childbearing lifespan.

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Passive smoking is of particular concern in households with children who are particularly vulnerable to passive smoking as they tend to spend a lot of time in the home. The research found that 46% of the waterpipe smokers interviewed said that they had children living in their house and that they smoked in the same room. Whole population data for Westminster: Age & Sex

Ages Persons Males Females Persons Males Females

All Ages 226,841 116,590 110,251 100% 51.4% 48.6%

0-4 13,749 7,058 6,691 6.1% 3.1% 2.9%

5-9 10,864 5,555 5,309 4.8% 2.4% 2.3%

10-14 9,295 4,751 4,544 4.1% 2.1% 2.0%

15-19 9,681 5,186 4,495 4.3% 2.3% 2.0%

20-59 147,394 77,309 70,085 65.0% 34.1% 30.9%

60-64 9,483 4,440 5,043 4.2% 2.0% 2.2%

65-74 14,344 6,956 7,388 6.3% 3.1% 3.3%

75-84 8,650 4,023 4,627 3.8% 1.8% 2.0%

85+ 3,381 1,312 2,069 1.5% 0.6% 0.9%

Source: *Mid Year Estimates 2013, ONS .

Groups with particular faiths and beliefs

The activity is considered an important social activity for certain groups, particularly for those who do not drink alcohol on religious grounds. The Westminster PCT report (2009) notes that there is some debate over the religious significance of smoking, in some countries advocate against waterpipe smoking, but in the UK it is commonly accepted as social activity which is an alternative to drinking alcohol. The Adult Services & Health Policy and Scrutiny Committee commissioned a research report on the ‘Public Health Implications of Shisha Smoking in London’ noted that in a study of smoking habits of London university students, practicing Muslims in the group described the religiously acceptable stance of shisha in their lives, enabling them to socialise outside of alcohol-centred venues. Whole population data for Westminster: Religion or belief

Religion Number %'s

Christian 97.8 45% Buddhist 3.2 1.5% Hindu 4.2 1.9% Jewish 7.2 3.3% Muslim 40.1 18% Sikh 0.5 0.2% Other religion 1.3 0.6% No religion 44.5 20% Religion not stated 20.5 0.1%

Source: Census, 2011 (ONS)

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Any other groups who may be affected by the proposal? Businesses providing shisha smoking

The number of premises providing shisha smoking in Westminster is currently 122 premises. Businesses which provide shisha smoking will be impacted in terms of being encouraged to meet existing regulations. Proposals to better inform people on the health impacts of smoking may affect numbers participating in smoking.

2.2 Summary (to be completed following analysis of the evidence above) Does the project, policy or proposal

have the potential to have a disproportionate impact on any of the following groups? If so, is the impact positive or negative?

None Positive Negative Not sure

Disabled people x

Particular ethnic groups x x

Men or women (include impacts due to pregnancy/maternity)

x x

People of particular sexual orientations

x

People who are proposing to undergo, are undergoing or have undergone a process or part of a process of gender reassignment

x

People on low incomes x

People in particular age groups x x

Groups with particular faiths and beliefs

x x

Are there any other groups that you think this proposal may affect negatively or positively?

x x

SECTION 3: Assessing Impact In order to be able to identify ways to mitigate any potential impact it is essential that we know what those potential impacts might be.

3.1 Consultation Information This section should record the consultation activity undertaken in relation to this project, policy or proposal

i. Who will you consult with?

Consultation on the draft strategy will be undertaken with a range of community and other stakeholders, including amenity and residents’ societies, businesses (including Business Improvement Districts and estates), charitable and voluntary organisations, community associations, ethnic associations, faith organisations, health and educational organisations, housing associations, landowners, the police, fire brigade and HMRC.

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The strategy has been drafted in consultation with the Shisha Working Group which includes representatives from services, councillors and Tri-borough Public Health. Public Health England has also informally commented on the draft strategy. Initial public consultation has already been undertaken on one of the actions set out in the strategy - the draft planning policy for shisha smoking as part of the revision to the Westminster City Plan. The draft policy was published on the council’s website on 12 March 2014 in consultation booklet ‘Food, Drink, Entertainment, Tourism, Arts and Culture’ for a six week period. In accordance with the Statement of Community Involvement consultation was undertaken with all Members, statutory consultees, the Mayor of London and the GLA family, consultees registered on the local plan database (currently comprising about 500 consultees including members of the public and residents’ groups) and internal consultees within the City Council, including SEB and the Senior Leadership Team. In addition, 130 shisha premises were contacted by letter to draw their attention specifically to the consultation on the new draft policy on shisha smoking. 20 responses were received regarding this policy, five of which were objections and 13 were in support. Funding of £10,000 has been secured from the Tri-borough Smokefree Alliance to deliver a symposium event, which will focus on raising awareness of the risks of shisha smoking and how to best drive changes in behaviour among target audiences. The event will aim to include international speakers and delegates to hear global perspectives from regions where public shisha smoking has been heavily regulated or banned. It is suggested that the symposium event would take place in November and would be used as a platform to launch a final, post-consultation version of the strategic document, at the end of the year.

ii. How will you consult?

The consultees will be contacted by letter/email , documentation made available on the website, and meetings arranged as appropriate. Timetable:

November 2015 Development of new shisha web pages

November 2015 Document launched for consultation

Business guidance published and promoted to relevant businesses

Early January 2016 Consultation closes

March 2016 Awareness raising / behaviour change symposium event

March 2016 Final launch of Reducing the Harm document

3.2 What might the potential impact on individuals, groups or staff be?

Consider disability, race, gender, sexual orientation, transgender, age, faith or belief and those on low incomes and other excluded individuals or groups

Generic impact (across all groups) In terms of impact of potentially reducing the levels of shisha smoking, this should have better health

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outcomes for smokers and those affected by passive smoking. In terms of better regulating the activity this should reduce incidences of nuisance caused by shisha smoking.

Men or women (include impacts due to pregnancy/maternity)

As generic impact above. In addition targeting of shisha smoking may be considered as discriminating given that the activity is considered an important means of socialising for both men and women.

People of particular sexual orientation

As generic impact above.

People who are proposing to undergo, are undergoing or have undergone a process or part of a process of gender reassignment

As generic impact above.

Disabled people As generic impact above, in addition, better management and enforcement should reduce structures on the highway and improve movement for those with disabilities and impaired mobility.

Particular ethnic groups As generic impact above. In addition targeting of shisha smoking may be considered as discriminating given that the activity is closely associated with particular ethnic groups.

People on low incomes As generic impact above

People in particular age groups As generic impact above. In addition, targeting of shisha smoking may be considered as discriminating given that the activity may be considered an important means of socialising for young people. It should be noted that where shisha smoking involves the use of tobacco, trading standards legislation on underage purchase applies.

Groups with particular faiths and beliefs

As generic impact above. In addition targeting of shisha smoking may be considered as discriminating given that the activity is sometimes considered an important means of socialising for some religious groups who do not drink alcohol.

Other excluded individuals and groups Businesses providing shisha smoking

Targeting of shisha smoking may be considered as discriminating given that the activity is closely associated with particular ethnic groups and religious groups. However this is in no way the intention of the strategy and the council seeks to be clear that the aim is to ensure premises are operating in a manner compliant with regulations wherever they occur across the city and its communities.

SECTION 4: Reducing & Mitigating Impact As a result of what you have learned, what can you do to minimise the impact of the proposed changes on equality groups and other excluded / vulnerable groups, as outlined above? 4.1 Where you have identified an impact, what can be done to reduce or mitigate

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the impact? (Remember to think about the Council as a whole, another service area may

already be providing services which can help to deal with any negative impact). Impact 1: Targeting of shisha

smoking may be considered as discriminating given that the activity is closely associated with particular ethnic groups

It should be emphasized that the strategy does not seek to prohibit shisha smoking, but seeks to provide people with information to make informed decisions about shisha smoking (which studies show to be commonly misunderstood), and to ensure the activity is carried out in a responsible manner, compliant with the necessary regulations. The positive benefits of the strategy should be highlighted to demonstrate that strategy is intended to improve health outcomes and reduce incidences of nuisance. Consultation should ensure affected groups are included and effective communication of the strategy objectives to help ensure the intentions and benefits are explained. Comparisons could also be drawn with international experiences where shisha smoking is being increasingly controlled and in some instances banned.

Funding has been secured from the Tri-borough Smokefree Alliance to deliver a symposium event, which will focus on raising awareness of the risks of shisha smoking and how to best drive changes in behaviour among target audiences. The event will aim to include international speakers and delegates to hear global perspectives from regions where public shisha smoking has been heavily regulated or banned.

Impact 2: Targeting of shisha smoking may be considered as discriminating given that the activity is considered an important means of socialising for some religious groups who do not drink alcohol.

As above.

Impact 3: Targeting of shisha smoking may be considered as discriminating given that the activity may be considered an important means of socialising for some age groups.

As above.

Impact 4: Targeting of shisha smoking may be considered as discriminating given that the activity is considered an important means of socialising for both men and women.

As above.

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4.2 Now that you have considered the potential or actual effect on equality, what action are you taking?

No major change (no impacts identified)

Adjust the policy/proposal

Continue the policy/proposal (impacts identified) x

Stop and remove the policy/proposal

4.3 Please document the reasons for your decision

Both positive and negative impacts of the strategy on different groups have been highlighted. The strategy does not seek to prohibit shisha smoking, but seeks to provide people with information to make informed decisions about smoking, and to ensure the activity is carried out in a responsible manner, compliant with the necessary regulations. The overall impact will be positive in seeking to improve health outcomes and reduce incidences of nuisance

4.4 How will the impact of the project, policy or proposal and any changes made to reduce the impact be monitored?

4.5 Conclusion This section should record the overall impact, who will be impacted upon and the steps being taken to reduce/mitigate impact

A strategy for managing shisha smoking could be seen as discriminatory by those groups closely associated with the activity, namely particular ethnic and faith groups. The strategy does not seek to prohibit shisha smoking, but seeks to provide people with information to make informed decisions about smoking, and to ensure the activity is carried out in a responsible manner, compliant with the necessary regulations. The overall impact will be positive in seeking to improve health outcomes and reduce incidences of nuisance. Consultation should target affected groups to help ensure the intentions and benefits are effectively explained.

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SECTION 5: Next Steps

5.1 Action Plan Complete the action plan if you need to reduce or remove the negative impacts you have identified, take steps to foster good relations or fill data gaps.

NB. Add any additional rows, if required.

Action Required Equality Groups Targeted

Intended Outcome Resources Needed Name of Lead, Unit & Contact Details

Completion Date (DD/MM/YY)

RAG

Consultation to effectively deliver the objectives of strategy in particular the health outcomes

All Understanding of health benefits of strategy

Existing

To deliver a symposium event, which will also explore global perspectives on shisha smoking

All Recommendations for how we can best engage with target audiences to raise awareness of the true dangers of shisha smoking.

Tri-borough Smokefree Alliance funding secured

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5.2 Risk Table Ref Risk Impact Actions in place to

mitigate the risk Current risk score Further actions to be

developed

R1.1 Challenge strategy on discrimination grounds under public sector equality duty

Legal challenge can be time consuming and costly?

Public consultation on strategy

C Work with stakeholders to explain the strategy and reasons for it.

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THIS SECTION TO BE COMPLETED BY THE RELEVENT SERVICE MANAGER

Signature: …….................................................... Full Name: …….................................................... Unit: …….................................................... Email & Telephone Ext: …….................................................... Date of Completion (DD/MM/YY): ……....................................................

WHAT NEXT?

Please email your completed EIA to the Equalities Lead: equalities@westminster.gov.uk