Comment 04110125

MessageFrom: Linda Jo Parrish [lindajo@womenshealthresearch.org]
Sent: Tuesday, August 16, 2005 10:43 AM
To: Rulemaking, TTB
Subject: Re: Notice # 41

                        

 

 

August 16, 2005

 

 

Chief, Regulations and Procedures Division

Alcohol and Tobacco Tax and Trade Bureau

Attn: Notice No. 41

P.O. Box 14412

Washington, DC 20044-4412

 

Re:       Notice No. 41

 

 

Dear Sir or Madam:

 

The Society for Womens Health Research is the nation's only non-profit advocacy group whose sole mission is to improve the health all women through research, education and advocacy. The Society takes great interest in issues that affect the health of women and is writing this letter to urge TTB to require a mandatory Alcohol Facts panel on the labels of all alcoholic beverages, regardless of product category. Moreover, because this rulemaking will likely take years to complete and consumers need alcohol content, calorie, and allergen information now, we request that TTB issue an interim policy allowing bottlers to voluntarily provide this information on their labels immediately. 

 

From the standpoint of public health, there are several reasons why having access to beverage alcohol labeling is so important. First, alcohol is a significant source of calories.  As extensive scientific evidence makes clear, counting calories and balancing energy consumed against energy expended is the key to maintaining a healthy weight. Thus, requiring information on all beverage alcohol products with the number of calories per serving will make it possible for consumers to estimate the number of calories they are consuming and take the appropriate steps to maintain a healthy weight. 

 

Another reason why mandatory beverage alcohol labeling is needed is to help consumers determine how much alcohol they are consuming, including the number of drinks per serving and per container, as well as the absolute amount of alcohol per serving and per container.  Accordingly, the Society urges TTB to require the following information on all beverage alcohol products:

         The serving size (i.e., 12 fluid ounces (fl oz) for beer, 5 fl oz for wine, and 1.5 fl oz for distilled spirits);

         The amount of alcohol (in fluid ounces per serving);

         The percentage alcohol by volume;

         The definition of a standard drink; and

         The number of standard drinks per container.

Besides this necessary information, the Society recommends using the Alcohol Facts panel to make the public aware of the Dietary Guidelines advice on moderate drinking. This would include a statement that summarizes the recommendation contained in The Dietary Guidelines for Americans 2005, which defines moderate drinking as no more than two drinks per day for men and one drink per day for women. 

 

Of additional concern is requiring the labels of all alcoholic beverages to identify any major food allergens present in the product. Just as the sensitive populations are warned of the presence of potential allergens in food, consumers with food allergies need to know how to avoid these allergens when drinking beer, wine and distilled spirits.   

 

As background information, it is important to understand that after drinking the same amount of alcohol, the average woman has a greater percentage of alcohol in her bloodstream than a man. This is because women are usually smaller and have a greater proportion of body fat than men. Additionally, womens bodies produce less of an enzyme called alcohol dehydrogenase, which helps breaks down alcohol in the body, so more alcohol circulates in womens bodies. Women are more likely than men to develop heart, brain, bone, and liver damage from drinking alcohol. Serious liver damage, from cirrhosis of the liver, can be fatal. Women who drink too much are also vulnerable to sexually transmitted diseases, unplanned pregnancy, and rape. A survey of college women revealed that one in 20 had been raped, and alcohol was involved in 75 percent of rape cases. 

 

The use of drugs and alcohol during pregnancy is a particular problem. There is no consensus on the amount of alcohol a pregnant woman can safely consume without harming the fetus. Among the problems that alcohol can cause is fetal alcohol syndrome, which affects appearance, intelligence, and behavior. 

 

In summary, the Society for Womens Health Research urges TTB to require an Alcohol Facts panel on labels of all beverage alcohol products and in the interim, to allow voluntary labeling that includes alcohol, calorie, and allergen information. Having this information will significantly advance important public health goals.

 

Thank you for your consideration.

 

cer
Phyllis Greenberger, President & CEO

Society for Womens Health Research

1025 Connecticut Avenue, NW, Suite 701

Washington, DC 20036

202-223-8224

phyllis@womenshealthresearch.org

L. Jo Parrish, MA, MBA
Vice President, Institutional Advancement
Society for Women's Health Research
1025 Connecticut Avenue NW, Suite 701
Washington, DC 20036
202-223-8224
202-496-5008  direct
202-833-3472  fax
lindajo@womenshealthresearch.org
www.womenshealthresearch.org

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