Joint Statement of Public Health Officials Regarding the BATF Rulemaking on Allowing Health Related Statements in the Advertising of Alcoholic Beverages or on the Labels of Alcoholic-Beverage Containers

To the Bureau of Alcohol, Tobacco and Firearms
RE: Notice 884

Providing advice about alcohol consumption can be risky business for individual health practitioners and even riskier for government agencies that seek to help consumers make healthy choices. This task is made more difficult by simplistic newspaper headlines or sensational television reports that proclaim that moderate drinking reduces coronary artery disease and enhances longevity.

Although we recognize the evolving epidemiological evidence associating the consumption of small amounts of alcoholic beverages with some health benefits, we believe that this information fails to provide support for generalized, population-wide recommendations to drink for one's health.

The balancing of risks and benefits that might be expected from consumption of alcohol will vary greatly from individual to individual depending on that person's genetic makeup, age, sex, race, body-mass, and susceptibility to a variety of diseases. The variety of factors which help determine whether or not a given individual might expect a small improvement, or worsening of health from consuming alcohol is far too complex to be reduced to a message on an alcoholic-beverage container or in an advertisement for alcoholic beverages.

We are concerned that allowing any health related statements or claims in conjunction with the sale of alcoholic beverages will only mislead consumers, and persuade them to drink alcohol "for health reasons." Furthermore, any suggestion that there are potential benefits for some people in consuming small amounts of alcoholic-beverages may also help heavier drinkers rationalize their consumption and justify their dependency, with catastrophic health and safety consequences for themselves and others. Many people should not drink at all.

Finally, we note that there is clear evidence that any recommendation about individual drinking that results in a greater consumption of alcohol for the American population as a whole, will lead to an increase in the alcohol-related health problems in our society.

We urge the BATF to disallow any health related statements or claims on alcoholic beverage containers or in the advertising of alcoholic-beverage products.

Signed by:

Former Surgeons General

M. Jocelyn Elders, Surgeon General of the United States, 1993-1994
Julius B. Richmond, Surgeon General of the United States, 1977-1981

Deans of Schools of Public Health

Dr. Kenneth J. Bart, Dean, Graduate School of Public Health, San Diego State University
Dean John B. Conway, School of Public Health, State University of New York at Albany
Dr. James W. Curran, Dean, Rollins School of Public Health, Emory University
Dr. Alida de Galetti, Acting Dean, Graduate School of Public Health, University of Puerto Rico
Dr. Holger Hansen, Director, Graduate Program in Public Health, University of Connecticut
Dean Richard Hart, Loma Linda University School of Public Health
Dean Richard S. Kurz,, School of Public Health, St. Louis University
Dr. Edith Leyasmeyer, Dean, School of Public Health, University of Minnesota
Dr. Patricia Dolan Mullen, Professor of Behavioral and Health Sciences, Houston School of Public Health, University of Texas
Ms. Elise Papke, Director, Department of Public Health, Indiana University
Dr. Paul Pomrehn, Head, Department of Community & Behavioral Health, University of Iowa
Dean William Roper, School of Public Health, University of North Carolina at Chapel Hill
Dr. Allen Rosenfield, Dean, Joseph F. Mallman School of Public Health, Columbia University
Dr. Ronald L. St. Pierre, Interim Dean for Public Health, Ohio State University College of Medicine and Public Health
Dr. Alfred Summer, Dean, School of Hygiene and Public Health, Johns Hopkins University
Dean Patricia W. Wahl, School of Public Health & Community Medicine, University of Washington

Directors of State Departments of Public Health

Dr. Fay W. Boozman, Director, Arkansas Department of Health
Dr. Carmen Feliciano de Melecio, Secretary of Health, Government of Puerto Rico
Dr. Howard K. Kohl, Commissioner, Massachusetts Department of Public Health
Rice C. Leach, Commissioner, Kentucky Department for Public Health
Dr. A. Dennis McBride, State Health Director, North Carolina Department of Health & Human Services
Dr. Garry L. McKee, Director, Wyoming Department of Public Health
Jan Malcolm, Commissioner, Minnesota Department of Public Health
Dr. Kenneth C. Spitalny, Director, Center for Community Health, New York State
Dr. Ulder J. Tillman, Director, Delaware Division of Public Health

Directors of State Alcohol and Drug Abuse Departments

Luceille Fleming, Director, Ohio Department of Alcohol & Drug Addiction Services
Philip McCullough, Director, Wisconsin Bureau of Substance Abuse
Grace A. Pesikey, AOD Director, State of Delaware Department of Services for Children, Youth and Families
Michael E. Townsend, Director, Division of Substance Abuse, State of Kentucky
Gordon R. Tush, Director, Division on Alcoholism, Drug Abuse and Addiction Services, State of Nebraska
Janet Wood, Director, Colorado Alcohol and Drug Abuse Division

February 19, 2000