What is Moderate Drinking for a Man and a Woman Revisited After 20 Years
NABI Press Release - August 13, 2020
NABI Comments on Dietary Guidelines Advisory Committee Scientific Report Recommendation on Moderation in Beverage Alcohol Consumption – More Science is Needed
The National Association of Beverage Importers (NABI) today submitted comments opposing the recommendation to revise the Dietary Guidelines for Americans (DGA) by changing the moderation standard from 2 standard drinks per day for men to 1 standard drink per day for both men and women because of the paucity of scientific and medical research studies supporting the recommendation.
“We all recognize that abusive and irresponsible use of beverage alcohol causes harm to the health and safety of consumers and others in contact with those consumers. And for some vulnerable populations, any beverage alcohol consumption is deleterious. It results in huge human and financial costs to society and family. For these very reasons, it is essential in explaining moderation to consumers of beverage alcohol that it be based on solid and sound science and not social policy preferences” said Robert M. Tobiassen, NABI President. He added “It should not be ‘aspirational’ but clearly justifiable. Consumers pay attention to the Dietary Guidelines for Americans and any change in advice, particularly longstanding advice consistently given for 40 years, must come with clear, transparent, and widely accepted evidence from the scientific and medical community in order to avoid consumer confusion, at a minimum, and consumer loss of confidence in its public officials, at a maximum.”
Since its inception in 1980, the DGA, updated every five years, has always referred to 1 or 2 drinks daily or similar reiteration as the benchmark that over time consumers have come to know. A clear, consistent, and core message of the DGAs since 1990, has been moderate consumption of beverage alcohol is one drink daily for women and two drinks daily for men in the United States. United States Government websites1 repeat the 2/1 drinks moderation as do websites of highly respected medical institutions.
“A sizable population of consumers of wine, distilled spirits, and beer are fully aware of the 2/1 drinks moderation recommendation. Perhaps they are more aware of this concrete standard than any other specific standard in the DGA” said Tobiassen Other public commenters have raised procedural irregularities with the review process or identified specific objections and concerns with the methodologies of the scientific and medical studies cited to support this recommendation.
“Significantly, this is not a public policy that was adopted 40 years ago that has not been reviewed ever since; rather, this is a public policy that has been continuously reviewed every five years on the current science and medical knowledge. Adoption of the recommendation revising the daily drink standard for men must be founded on science and medical knowledge. Anything less, will cause lasting damage to the future work of the Dietary Guidelines Advisory Committees and will be received with circumspection by the public” said Tobiassen.
The comments are available on www.regulations.gov under FNS-2020-0015. For further information, please contact NABI at nabipresident@bevimporters.org
Download a copy of the Press Release here.
NABI Comment Letter - August 13th, 2020
Submitted via https://beta.regulations.gov/docket/FNS-2020-0015
Re: Dietary Guidelines Advisory Committee Scientific Report – Part D, Chapter 11, Alcoholic Beverages, Food and Nutrition Service, Docket No. FNS 2020-0015
Dear Messrs. Lipps and Wright:
The National Association of Beverage Importers (NABI) appreciates the opportunity to provide comments on the recommendation of the Dietary Guidelines Advisory Committee in Part D, Chapter 11, Alcoholic Beverages on revising the moderation standard from 2 standard drinks per day for men to 1 standard drink per day for both men and women. Since 1935, NABI has represented importers of beverage alcohol into the United States.
We all recognize that abusive and irresponsible use of beverage alcohol causes harm to the health and safety of consumers and others in contact with those consumers. And for some vulnerable populations, any beverage alcohol consumption is deleterious. It results in huge human and financial costs to society and family. For these very reasons, it is essential in explaining moderation to consumers of beverage alcohol that it be based on solid and sound science and not social policy preferences. It should not be “aspirational” but clearly justifiable.
Consumers pay attention to the Dietary Guidelines for Americans (DGA) and any change in advice, particularly longstanding advice, must come with clear, transparent, and widely accepted evidence from the scientific community in order to avoid consumer confusion, at a minimum, and consumer loss of confidence in its public officials, at a maximum. As a former Federal regulator of the alcohol industry, I am very sensitive to building trust with the consumers by the persuasive evidence you present in explaining the change in position by an agency.
Science and medical knowledge evolves and advances over time and the five-year update cycle of the DGA is based on this fact. However, the context of the recommendation to revise the moderation standard for men to 1 standard drink per day must be considered in the historic context of the DGA in order to avoid consumer confusion and distrust.
Since its inception in 1980, the DGA has always referred to 1 or 2 drinks daily or similar reiteration as the benchmark that over time consumers have come to know. The 1980 DGA advised “One or two drinks daily appear to cause no harm in adults. If you drink, you should do so in moderation.” The 1985 DGA advised “One or two standard sized drinks daily appear to cause no harm in normal, healthy, and nonpregnant adults. Twelve ounces of regular beer, 5 ounces of wine, and 1 1⁄2 ounces of distilled spirits contain about equal alcohol.” The 1990 DGA adopted the 2/1 concept in answering the question “WHAT’S MODERATE DRINKING? Women: No more than 1 drink a day. Men: No more than 2 drinks a day” and listed the standard 3 drinks as in 1985, except adding “(80 proof)” after distilled spirits explained moderation as “Moderation is defined as no more than one drank a day for women and no more than two drinks a day for men.”In the 2000 DGA, the “Advice for Today” was “Limit intake to one drink per day for women and two per day for men, and take with meals to slow alcohol absorption.” The “Key Recommendations” in the 2005 DGA include “Those who choose to drink alcoholic beverages should do so sensibly and in moderation—defined as the consumption of up to one drink per day for women and up to two drinks per day for men.” The “Key Recommendations” in the 2010 DGA again advised “If alcohol is consumed, it should be consumed in moderation—up to one drink per day for women and two drinks per day for men— and only by adults of legal drinking age.” (With a footnote directing the reader to moreextensive explanation of risk populations and other behaviors.) Finally, in the 2015 DGA, the “Glossary of Terms” explains “Moderate Alcohol Consumption—Up to one drink per day for women and up to two drinks per day for men. One drink-equivalent is described using the reference beverages of 12 fl oz of regular beer (5% alcohol), 5 fl oz of wine (12% alcohol) or 1.5 fl oz of 80 proof (40%) distilled spirits. One drink-equivalent is described as containing 14 g (0.6 fl oz) of pure alcohol.”
A clear, consistent, and core message of the DGAs for 40 years has been moderate consumption of beverage alcohol is one drink daily for women and two drinks daily for men in the United States. In a public educational document that grew from 19 pages in 1980 to 122 pages in 2015, this message has not changed.
The public attention and awareness to this portion of the DGA cannot be overstated. The publicity surrounding the “French Paradox” after the CBS broadcast of “60 Minutes” drew consumers to the DGA portion on Alcoholic Beverages. Moreover, starting with an Industry Circular in 1993 to commencing rulemaking in 1999 that was completed in 2003, in conjunction with litigation over “Directional Statements” referring to the DGA on wine labels, the Bureau of Alcohol, Tobacco and Firearms (ATF) and the Alcohol and Tobacco Tax and Trade Bureau (TTB) regulatory activities drew more public attention to the DGA portion on Alcoholic United States Government websites repeat the 2/1 drinks moderation as do websites of highly NABI respectfully submits that a sizable population of consumers of wine, distilled spirits, and beer are fully aware of the 2/1 drinks moderation recommendation. Perhaps they are more aware of this concrete standard than any other specific standard in the DGA. That being the case, the recommendation to revise the definition of moderation to 1 standard drink per day for men, should only be adopted if there is clear and convincing science supporting it for the public to accept the revision. The standard established by the Dietary Guidelines Advisory Committee Charter requires that the DGA “shall be based on the preponderance of scientific and medical knowledge current at the time of publication” for this very reason.
Changing a longstanding public policy may lead to consumer confusion and even consumer distrust of the regulator. Credibility counts in the eyes of the public. If this recommendation is adopted, then you may be sure that it will receive much news coverage and publicity; the consuming public will scrutinize this decision by the Departments of Health and Human Services and Agriculture and make up its own mind. Download a copy of the Comment Letter here: