APPENDIX

TEXT OF RESPONSES

The following letters responded to the six questions on consumer health warnings for alcoholic beverages and related issues posed by Senator Riegle:

1. Would warning labels be effective in raising public awareness of the health hazards involved in the use of alcohol? 2. Should such warning labels, if any, be of a general nature, or should they address specific dangers such as the fetal alcohol syndrome, driving impairment, etc.?

3.

Should Congress consider requiring a rotating system of labeling? For example, Congress could require that 10 percent of the labels contain a warning about the fetal alcohol syndrome, 10 percent on driving impairment, etc. Should such warning labels be required on beer and wine as well as distilled spirits?

4.

5. Should beer and wine containers be required to indicate the percentage of alcohol per volume?

6. Should warning labels also be required on advertisements of alcoholic beverages?

Some names and addresses haye been deleted to preserve Fights of privacy.

Thank you for your letter concerning warning labels on
alcoholic beverages.

As you know, alcohol abuse and alcoholism are major national health problems--taking a terrible toll each year in death, crime, lost productivity, health care costs, social services, and shattered families. Because alcohol abuse and alcoholism are preventable and treatable, we have a special responsibility, and a special opportunity, to reduce the extent of these health problems.

Alcohol abuse and alcoholism arise from complex interactions
of social stresses, economic problems, behavioral reactions,
prevailing attitudes and individuals' choices about how to
cope. Because these causes are so varied, if we are to reduce
the levels of alcohol abuse and alcoholism in our society, we
must use all the means at our disposal.

For this reason, HEW has recently undertaken a major initiative against alcohol abuse and alcoholism, involving educational efforts directed at the young, expanded research, occupation based alcoholism programs, training programs for health care professionals, exploring increased coverage by Medicare/ Medicaid and private insurance of alcoholism treatment--as well as efforts to warn people about alcohol abuse.

In such an overall effort to encourage sensible attitudes and
behavior concerning alcohol, the use of warning labels may well
have a worthwhile role. Alone it is not, of course, an answer
to the problem; but it may be one of the useful tools which
can be used. I commend your Subcommittee for the careful
consideration it is now devoting to this issue.

My views on the specific questions you have raised are as follows:

1.

Would warning labels be effective in raising public awareness of the health hazards involved in the use of alcohol?

There can be little question that warning labels would raise public awareness of the health hazards of excessive or irresponsible use of alcohol and that this would have some effect on patterns of alcohol use. However, there is an active debate at present over just how effective warning labels are in reducing alcohol abuse. In an analogous area, a 1977 study on cigarette warning labels by the Federal Trade Commission concluded that the impact of warning labels is very difficult to assess. Although the total number of cigarettes consumed has not decreased since the requirement of warning labels became effective in 1966, the percentage of people who smoke has declined from 42 percent to 33 percent and many smokers have switched from non-filter to filter cigarettes.

In a study appended to the FTC report, Dr. Martin Fishbein of the University of Illinois concluded that "there are enough reported successes in the literature to warrant [the conclusion] that it is possible to both inform the public and to influence their smoking decisions."

The analogy of cigarette or drug warnings to alcohol may not be perfect, and it is necessary to learn more about the dynamics of alcohol use. However, our experience to date suggests that warnings are more effective where people have a means of partially moderating their behavior, rather than a stark choice of either doing or not doing the potentially hazardous activity. For this reason, alcohol labelling might well be effective since it is excessive or irresponsible use, not use per se, which is of concern.

There is another reason why warning labels are desirable: even if people decide to consume alcohol in an unwise way, they will know the risks and can reach an informed decision. Though most people are familiar with alcohol, many do not know of all the dangers which may be entailed by its use, such as fetal alcohol syndrome.

I believe that the government has an obligation to warn people of scientifically established health hazards. Warning labels are but one way to carry out this obligation. Other methods include physician information, educational efforts in schools, and public service messages in the media. The alcoholic beverage industry itself has developed an educational campaign on responsible use of alcohol. HEW has been working with the Treasury Department's Bureau of Alcohol, Tobacco and Firearms (BATF) on an educational effort concerning the dangers of fetal alcohol syndrome. Such educational efforts must be expanded, whether or not warning labels on alcoholic beverages are required.

2. Should such warning labels, if any, be of a general nature, or should they address specific dangers such as the fetal alcohol syndrome, driving impairment, etc.

[and]

3. Should Congress consider a rotating system of labeling? I believe that specific warning labels may well be more effective than general labels, and that at least their use should be explored. We now know that at certain levels of consumption, ingestion of alcohol poses hazards for persons with heart disease; in combination with various drugs, poses risks including death; during pregnancy, may cause birth defects; is addictive; impairs driving; and increases the risks of head and neck cancer. Specific warning labels addressed to some of these risks might well convey to consumers helpful, precise information. Of course, there are pros and cons to every such effort. A specific label warning may be irrelevant to many of the consumers who see that particular warning. But in the long run, they will probably have a strong effect on everyone.

The experience in Sweden, in which alcoholic beverages are labeled in random sequence with one of a series of health warnings, suggests that such a system may provoke more interest and capture more public attention than a single, general warning. I favor exploring the use of this and other creative measures for conveying the risks of alcohol to potential

consumers.

4.

Should such warning labels be required on beer and wine as well as on distilled spirits?

I strongly believe that, if warning labels are applied to distilled spirits, they should also be required for beer and wine. The key question from a health perspective is the amount of alcohol consumed during a given period of time, not the source of the alcohol. In fact, a can of beer has about the same alcohol content as an average drink--so it should be consumed with equal caution.

There is now conclusive evidence that excessive consumption of beer and wine is responsible for a significant proportion of the medical and other problems associated with excessive alcohol consumption. Excluding beer and wine from a labeling requirement would risk encouraging consumption of these alcoholic beverages by implying that they are safer than distilled spirits.

This is just the wrong message to convey

to our nation's youth, for whom beer or wine is often the beverage of choice.

For these reasons, any labeling requirement should be applied to beer, wine and distilled spirits alike.

5. Should beer and wine containers be required to indicate the percentage of alcohol per volume?

I believe that containers of alcoholic beverages should clearly state the percentage of alcohol by volume. At present, .containers of wine do indicate the percentage of alcohol by volume. Containers of distilled spirits indicate proof, which is measured on a different standard. And containers of beer do not state the volume of alcohol--or that beer contains alcohol at all. It is important that all containers of alcoholic beverages contain clear information on alcohol content, so that those who wish to consume alcohol only in moderate amounts will have the information necessary to do so.

6.

Should warning labels also be required on advertisements of alcoholic beverages?

As you know, HEW does not have statutory authority to regulate the advertising of alcoholic beverages. However, I believe that those agencies which have such authority--the FTC and the BATF--should seriously consider requiring such warnings.