NABI Comments on Dietary Guidelines Advisory Committee Scientific Report Recommendation on Moderation in Beverage Alcohol Consumption – More Science is Needed
Source: NABI
August 13, 2020
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.2
1 https://www.cdc.gov/alcohol/fact-sheets/moderate- drinking.htm#:~:text=To%20reduce%20the%20risk%20of,adults%20of%20legal%20drinking%20age. and https://health.gov/myhealthfinder/topics/health-conditions/heart-health/drink-alcohol-only-moderation
2 https://www.mayoclinic.org/healthy-lifestyle/nutrition-and-healthy-eating/in-depth/alcohol/art-20044551 and https://www.hsph.harvard.edu/nutritionsource/healthy-drinks/drinks-to-consume-in-moderation/alcohol-full- story/
“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.