The following is an email I sent as remarks regarding request for public comment on the involvement of the Interagency Coordination Committee on the Prevention of Underage Drinking in drafting the upcoming US dietary guidelines. There is one more day to make a comment. For an excellent overview, please read Felicity Carter’s summary at Wine Business, “Questions are Being Asked About the U.S. Alcohol Guidelines Review.” Here is my public comment:
To: Robert Vincent, SAMHSA Reports Clearance Officer, Center for Behaviors Health Quality and Statistics, Substance Abuse and Mental Health Services Administration, 5600 Fishers Lane, Room 15E45, Rockville, MD 20857; Phone: (240) 276-0166; Email: samhsapra@samhsa.hhs.gov.
Dear Mr. Vincent:
I am a professional consultant in the wine industry and a commercial vineyard owner. I’ve been involved in the wine industry for over 40 years.
The issue of alcohol and health is a complex one. There is no question that alcohol consumption has negative impacts on people and society, as alcohol is a natural toxin to the human body.
However, it is often how alcohol is consumed that dictates the negative impacts, not the actual toxicity of alcohol itself. People face health choices in many aspects of their lives, such as how much exercise they do, diet, lifestyle choices, and economic standing. Time and again, many foods, beverages, and activities are shown to have the potential for negative outcomes – if done in excess. Sugar in soft drinks, salt in processed foods, and improper exercise can all cause harm to individuals and society.
The same applies to the consumption of alcohol. Excessive consumption can lead to personal health and societal problems, just as many other products can. The goal is to promote safe and moderate consumption that enhances personal satisfaction, like moderating the intake of red meat or sweet desserts.
Despite recent studies focusing on the toxicity of alcohol, showing that excessive consumption can cause health effects and cancers, the overwhelming body of science indicates that any negative health effect from the moderate consumption of alcohol, combined with a good diet and healthy lifestyle, is negligible to non-existent for most adults.
Studies of blue zones, which identify populations with high concentrations of individuals living to 100+ years of age, reveal that small and moderate amounts of alcohol consumption are often part of regional diets and societies. These studies show that communal enjoyment of alcohol, combined with diet and moderate exercise, reduces daily stress, promotes digestion, and fosters community – all positives for a healthy life.
Given the above, the recent government committee ICCPUD, as learned as they are, is mostly comprised of agencies focused solely on the toxicity of alcohol rather than the broader dietary and health care perspectives that the Health and Human Services and United States Department of Agriculture would offer. These two agencies, HHS and USDA, are responsible for drafting the upcoming dietary guidelines. The ICCPUD has half of its panel based in Canada, making it even less suited to providing dietary guidelines for Americans that also directly affect American farmers and businesses.
Preventing underage drinking is important, and more can always be done to reduce underage drinking and access to alcohol. However, according to the US National Institute on Alcohol Abuse and Alcoholism, “NSDUH findings indicate a decline in underage drinking. From 2002 to 2022, the prevalence of alcohol use in the past 30 days decreased by 47.4% among people ages 12 to 20.” This positive trend persists despite the current dietary guidelines recommending moderate consumption of alcohol for adults if desired. Having a committee devoted to reducing underage drinking on the current panel ignores the successes achieved in the last two decades and suggests a larger concern that the upcoming dietary guidelines are being heavily influenced by groups promoting abstinence and the prohibition of alcohol in the US. Underage drinking is not a dietary issue, other than citizens under the age of 21 do not drink.
I assure you that everyone in the alcohol industry takes underage drinking, driving under the influence, health issues, addiction issues, and societal concerns VERY seriously. It is our responsibility to maximize the well-being of our consumers. All in the industry understand that our products are not for everyone, and we work to educate our consumers on the proper consumption of alcohol.
I urge you to review the current members and groups involved in the upcoming dietary guidelines and ensure that they best represent the health community, the alcohol industry, and the business and agricultural communities. Crafting the dietary guidelines is a tremendous responsibility and directly affects the well-being of Americans and businesses. Drafting a balanced recommendation that promotes the best possible societal and economic outcomes should be the goal.
Best regards,
Paul
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Paul Tincknell
Tincknell & Tincknell, Inc.
Wine Sales and Marketing Consultants since 1997