Understanding Programs" are being broadened to include point-ofsale educational materials for retailers, student and teachers' guides for classroom use, public information projects for beer wholesalers, consumer brochures for civic and other community clubs, and information for local licensing authorities and motor vehicle departments. In addition, the program now includes press releases and materials for public service newspaper advertisements. Many of these program materials are being adapted for use at military bases as well. 8. The Association's field staff works closely with area Armed Forces Disciplinary Control Boards to assure that retail outlets patronized by military personnel meet required standards. 9. The Association cooperates with state alcohol beverage administrators in their enforcement of minimum age laws. 10. The Association has commissioned a 30-month research study at Washington University in St. Louis, under the direction of Dr. David Pittman, chairman of the Sociology Department, to investigate whether there is a causal relationship between advertising and consumption. 11. The Association has pledged its cooperation with the Department of Health, Education, and Welfare and the Bureau of Alcohol, Tobacco, and Firearms in the development and implementation of an awareness campaign to alert women, and medical and other health professionals to the fetal alcohol syndrome. In conjunction with this awareness campaign on the fetal alcohol syndrome, urges the association that expectant mothers consult a physician on all health matters, including the consumption of alcoholic beverages. 12. In May 1979, the Association launched its Alcohol Awareness Program entitled "Think Twice. . . About Drinking." This is a three-phase educational awareness program directed toward the youth of the nation to encourage responsible decisions about the use or nonuse of alcoholic beverages. The National Beer Wholesalers' Association has agreed to join with USBA to carry out simultaneously the Alcohol Awareness Education Program. The Wine Institute Code of Advertising Standards has received high praise. It reads as follows: Guidelines: These guidelines shall apply only to the voluntary subscribers to this Code of Advertising Standards. 1. A distinguishing and unique feature of wine is that it is traditionally served with meals or immediately before or following a meal. Therefore, when subscribers to this code use wine advertising which visually depicts a scene or setting where wine is to be served, such advertising shall include foods and show that they are available and are being used or are intended to be used. This guideline shall not apply to the depiction of a bottle of wine, vineyard, winery, label, professional tasting, etc., where emphasis is on the product. 2. Wine advertising should encourage the proper use of wine. Therefore, subscribers to this code shall not depict or describe in their advertising: A. The consumption of wine for the effects its alcohol content may produce. B. Direct or indirect reference to alcohol content or extra strength, except as otherwise required by law or regulation. C. Excessive drinking or persons who appear to have lost control or to be inappropriately uninhibited. D. Any suggestion that excessive drinking or loss of control is amusing or a proper subject for amusement. E. Any persons engaged in activities not normally associated with the moderate use of wine and a responsible lifestyle. Association of wine use in conjunction with feats of daring or activities requiring unusual skill is specifically prohibited. F. Wine in quantities inappropriate to the situation or inappropriate for moderate and responsible use. 3. Advertising of wine has traditionally depicted wholesome persons enjoying their lives and illustrating the role of wine in a mature life-style. Any attempt to suggest that wine directly contributes to success or achievement is unacceptable. Therefore, the following restrictions shall apply to subscribers to this code: A. Wine shall not be presented as being essential to personal performance, social attainment, achievement, success, or wealth. B. The use of wine shall not be directly associated with social, physical, or personal problem solving. C. Wine shall not be presented as vital to social acceptability and popularity or as the key factor in such popularity. D. It shall not be suggested that wine is crucial for successful entertaining. 4. Any advertisement which has particular appeal to persons below the drinking age is unacceptable. Therefore, wine advertising by code subscribers shall not: A. Show models and personalities in advertisements who appear to be under 25 years of age. B. Use music, language, gestures, or cartoon characters specifically associated with or directed toward those below the legal drinking age. C. Appear in children's or juveniles' magazines, newspapers, television programs, radio programs, or other media specifically oriented to persons below the legal drinking age. D. Be presented as being related to the attainment of adulthood or associated with "rites of passage" to adulthood. E. Suggest that a wine product resembles or is similar to another type of beverage or product (milk, soda, candy) having particular appeal to persons below the legal drinking age. F. Use traditional heroes of the young such as those engaged in pastimes and occupations having a particular appeal to persons below the legal drinking age. (For example, cowboys, race car drivers, rock stars, etc.) G. Use amateur or professional sports celebrities, past or present. 5. Code subscribers shall not show motor vehicles in such a way as to suggest that they are to be operated in conjunction with wine use. Advertising should in no way suggest that wine 6. Wine advertising by code subscribers shall not appear in 7. Wine advertising by code subscribers shall make no reference to wine's medicinal values. 8. Wine advertising by code subscribers shall not degrade the image or status of any ethnic, minority, or other group. 9. Wine advertising by code subscribers shall not exploit the human form, feature provocative or enticing poses, nor be demeaning to any individual. All advertising—including but not limited to direct mail, point-of-sale, outdoor displays, radio, television, and print media—should adhere to both the letter and the spirit of the above code. The Wine Institute in cooperation with the Alcoholism Council of California has launched a pilot prevention project in 8 communities in California. With a task force of community leaders concerned with developing effective alcohol awareness programs, the industry is joining the volunteer sector in catalyzing initiatives tailored to specific local needs. This California prevention project is the response of industry and the volunteer sector to the need for education and information programs which encourage "positive personal alternatives" to the abuse of alcoholic beverages. The goal of the project is to establish volunteer task forces in each target county with the common purpose of preventing alcohol problems. This is being accomplished by motivating leaders and providing opportunity for development of action plans. The Wine Institute has also developed an Employee Alcoholism Program, the primary objectives of which are to provide effective assistance to alcoholic employees and to provide information and education designed to prevent employee alcohol problems from developing. These public service activities of the alcoholic beverage industry have been spelled out in some detail because the industry deserves praise for its efforts in these areas. Indeed, in part to assure such recognition of industry public service activities, Senator Riegle and Senator Orrin G. Hatch, Chairman and ranking minority member of the Alcoholism and Drug Abuse Subcommittee, recently distributed to their fellow Senators copies of the DISCUS-supported book. The Diagnosis and Treatment of Alcoholism, edited by Dr. Mendelson and Nancy K. Mello (New York: McGraw-Hill, 1979). Against this record of public service is the strong opposition of the industry to consideration of consumer health warning labels of any kind, even concerning the fetal alcohol syndrome. C. Peter Brock, then with the Group Health Association and currently president of the Johnson Institute, raised this point in a letter to Paul Gavaghan, vice president for research and public information of the Distilled Spirits Council of the United States, Inc. Gavaghan had been quoted as saying that concern over the fetal alcohol syndrome had been "inadequately communicated, arousing needless fears and concerns among normal pregnant women." Brock wrote: With all the noise DISCUS and others have been making about responsible drinking decisions, I would have thought [NIAAA'S FAS] health warning was something industry spokesmen would have welcomed and supported, not an act they would have interpreted as a threat. I am much less concerned about alarming a few pregnant women than I am with drinking mothers bearing defective offspring. If a woman elects to abstain completely from alcohol during her term of pregnancy this does not strike me as a decision which will cripple her socially or physiologically. I am sorry that your attitude, where human lives are involved, seems to reflect a priority of sales over caution. Mark Worden, director of the Douglas County, Oregon, Council on Alcoholism, agreed: It seems to me totally illogical that health hazard warnings are required for certain other over-the-counter drugs and food products, but no ingredient labeling or health hazard warning is required for beverage alcohol. If the alcohol industry were as truly concerned as they professed to be, I would think they would be falling all over themselves to label their beverages as their show of good faith and social responsibility. Regrettably, the opposite appears to be true. Thus it is that we have to enter into acrimonious debate in which the labeling position is portrayed as a "cosmetic solution." One response to that characterization would be the response that the industry shows nothing but contempt for the consumer by withholding information about health hazards and ingredients. But I don't know whether this is accurate. I don't know whether in fact they do feel contempt for the consumer or whether their concern is motivated by the possibility of a loss of profits. Opposition to consumer health warning labels for alcoholic beverages has been expressed not only by industry organizations but also by individual companies, retailers, employees, and individuals whose work the industry supports. (In summarizing responses to its Advance Notice of Proposed Rulemaking, BATF noted that "Many of the comments from doctors and consumers opposing warning labels originated from California, with at least 500 form letters coming from employees of wineries in California.") Many of the responses to Senator Riegle's questions not only contested the proposed warning of health hazards but also asserted that drinking may promote good health. John A. DeLuca, president of the Wine Institute, wrote: Wine is 6,000 years old, classified by physicians for centuries as a beverage food and as part of a healthful diet. Leon Adams, noted wine historian has written, "Wine is not (Despite this contention, the Wine Institute participated in a judicial battle to have alcoholic beverages exempted from the definition of "food" for the labeling aspects of the Federal Food, Drug, and Cosmetic Act, so that ingredient and health warning label standards applicable to all other foods would not apply to alcohol.) The Wine Institute also quoted a study by Dr. A. L. Cochrane, director of the medical research council epidemiology unit, Cardiff, South Wales, which found a strong and specific negative association between ishaemic heart disease deaths and alcohol consumption in 18 developed countries which the Institute stated "was shown to be wholly attributable to wine consumption." The Distilled Spirits Council of the United States, Inc. (DISCUS) also stated that consumption of alcoholic beverages may be beneficial to health: There is abundant medical and scientific testimony that many people derive health benefits from moderate use of alcohol beverages. A health warning label speaking only of the dangers gives at best a half truth. If it has any effect, it may be to discourage consumption by those who currently benefit from occasional consumption of alcohol beverages. The United States Brewers' Association responded similarly: Take, for example, the seemingly simple statement, "consumption of alcoholic beverages may be hazardous to your health." The reverse side of the slogan, based on scientific evidence, is equally valid for labeling, i.e., "consumption of alcoholic beverages could be beneficial to your health." While we are not advocating the latter label, there is evidence from A. L. Klatsky, M.D., of the Kaiser-Permanente Medical Group in California, in a longitudinal study of 100,000 individuals, that moderate drinking (2-3 drinks daily) in comparison to abstaining, reduces the probability of myocardial infarction (heart attack) by 30 percent. (The Kaiser-Permanente research was financed through a grant from the U.S. Brewers.) Alfred A. Smith, M.D., Department of Pharmacology, New York Medical College; Jackson Smith, M.D., professor of psychiatry, Loyola University; Leon Greenberg, Ph. D., professor emeritus of physiology, Rutgers University; David Pittman, Ph. D., chairman, Department of Sociology, Washington University (at St. Louis); and Fred Ellis, Ph. D., professor of pharmacology, University of North Carolina, all members of the DISCUS Scientific Advisory Council, wrote or wired members of the Subcommittee in opposition to warning labels. Alfred Smith wrote: Drinking of alcoholic beverages is not hazardous to one's health except under limited circumstances. These include drinking of large doses repeatedly over long periods of time, |