Comment 04116479

From: WDMiley@aol.com
Sent: Saturday, September 24, 2005 11:11 PM
To: Rulemaking, TTB; WDMiley@aol.com
Subject: alcohol labeling comments

Please accept my comments which are below:  I spent 32 years in public health services many of those working in preventive education programs and in alcohol and drug education.  I truly believe many people want to be informed about the ingredients of what they consume and the impact it has on their and others bodies.  Knowing how much alcohol is in beverage alcohol "serving" and how and how long the body takes to "breakdown" the alcohol so it does not continue to have a seditive effect on the body's function is most important.  I have sectioned my comments under theme labels.

Beer is really under labeled..
Beer labeling requirements have not changed since 1935.   I have noticed 
there is mostly no labeling information on malt alcohol beverages indicating alcohol by volume or by %.  I understand this is due to an arcane regulation which was done to prohibit competitors from pitching their beer as having a higher alcohol content.  This was overturned in court years ago, but nothing has been done to get the alcohol % labeling added as each state must enact a rule who permits such information.  Currently, based on a store  survey, I  only found 2 Budweiser brands which have 5% alcohol by volume on their container. 
I know there are a few more brands which have percentages of alcohol by 
volume listed somewhere on their labels.   Each 12 or 11 ounce bottle or can of 
beer has about 5% alcohol which is about 1/2 ounce. One brand had close to 8%.  
Our liver which is the bodys organ to break down or detoxify substance, in this case ethyl alcohol,  can do so at about 1/2 ounce per hour.  If one drinks
3 beers in one hour  it will take at least 3 hours for the body to be mostly free from alcohols influence.

What needs to be added to labels...
The labeling which will make a difference is that which clearly states the alcohol content in volume, in percent and in each serving.  Also there should be a statement indicating that the average person breaks down or detoxifies the 
alcohol substance 1/2 ounce per hour.  Thats the dosing/clearance rate.   
(currently most beer is unlabeled, wine 14% and over is required to have alcohol by %, and distilled is labeled by proof which is 2 times the alcohol
content...86 proof is 43 percent alcohol.  (A very arcane message going back to the Civil War when alcohol if strong enough could be used to burn a cannon fuse.) None of the current labels except for  wine which seems to be factually clear about the alcohol content by volume, lists any alcohol information which is usable in my opinion by the consumer.  

A New Serving Facts Label...
I understand that the proposed labeling would be a panel called  Serving Facts.  It is called Nutrition Facts on foods.  The Bureau seems to be most sensitive to any new labeling which might be misleading  to the public and cost more than its value.  I do believe that new labeling as proposed and with additional improvements ( like I suggest) would be very helpful to parents, consumers and educators. 

Here is an action I would like you to take...
This is a great chance to influence alcohol beverage labeling.  Except for the govt message about dangers to pregnant women and alcohol will impair your operation of a car or machinery, and may cause health problems there has been little required change since 1935.  There is some voluntary listing of ingredients but inconsistent from brand to brand.

I like what the Bureau is suggesting and have responded to your questions
here:  (1) Should there be a Serving Label Panel?  I think so.  2.  Should a 
standard drink size be specified?  Yes.   3.  Should the label be voluntary or 
mandatory?  Mandatory  4.  Should anyone be exempt?  like small wineries?  No.  
5.  Are the cost justified to provide the serving labels?  Yes.  All other foods have such labels and customers expect that.  

Some important reasons:  Alcohol can cause much pain, distress, damage and addictive illness so the need for better information about the product is very 
justified and worth the little extra expenditure initially.   Youth and young 
adult  beverage alcohol consumption is a big problem and now binge drinking is becoming a major public health concern.

In summary I want to  repeat my new suggestion:There should be a statement indicating that the average person breaks down or detoxifies the alcohol substance 1/2 ounce per hour.  Thats the dosing/clearance rate. 

This labeling which will make a difference is that it would clearly state the alcohol content in volume, in percent and in each serving. 

THANK YOU.     BILL MILEY,  919 NO. SIGNAL STREET, OJAI, CA 93023