Please see my comment letter below. The public comment period ends February 14, 2025 at 11:59 p.m. ET. If you would like to comment you can do so here, and feel free to reference or utilize any parts in this letter if they are helpful to you.

Visit this LINK to access other public comments. Comments are due February 14, 11:59 pm EST.

February 12, 2025

Ms. Janet de Jesus, MS, RD Senior Nutrition Advisory

Office of Disease Prevention and Health Promotion

U.S. Department of Health and Human Services 1101 Wootton Parkway, Suite 420

Rockville, MD 20852

RE: Request for Public Comments on the Reports on Alcohol Consumption and Health solicited by USDA and HHS to Inform the Dietary Guidelines for Americans, 2025-2030

I am a mother of three and hospitality professional with a Master Sommelier diploma, which is an advanced credential in food and beverage, including alcoholic beverages. I appreciate the opportunity to provide a public comment on the Reports that will inform the Dietary Guidelines for Americans (DGA), 2025-2030: The National Academies of Sciences, Engineering and Medicine (NASEM) report and the  Draft Report: Scientific Findings of the Alcohol Intake & Health Study for Public Comment – submitted on behalf of the Interagency Coordinating Committee on the Prevention of Underage Drinking (ICCPUD).

My comments concern four areas, summarized below:

1-Appropriateness of some of the report authors’ qualifications to do the vital work of alcohol and health guidance for legal drinking age (LDA) adults – The ICCPUD report’s authors do not include expertise in cardiovascular disease (CVD) risk, among many other disciplines critical to the DGA on alcohol. Rather, several of its authors’ dominant focus areas (alcohol policy, anesthesiology) do not seem appropriate to the task at hand. Additionally, three of the six researchers are from Canadian institutions, two of whose work on the Canadian Center on Substance Use and Addiction alcohol guidance, was not adopted because medical researchers and scientists found that they had used faulty methodology. This is in marked contrast to the NASEM panel of 14 scientists from leading US academic institutions, credentialed in highly relevant specialties such as obesity,CVD, substanceabuse,cancer,neuroscience,psychology,andnutrition.

2-Lack of: 1-clarity in HHS’ reasons for the duplicative reports, and 2-clear explanation of how they are “complementary” as described in the above-mentioned Federal Register Request for Public Comments notice. My Congressman Mike Thompson informed our district that “ICCPUD’s duplicative study redirected the Committee’s limited resources away from its core responsibility to prevent underage drinking. Additionally, unlike the NASEM review and overall development of the 2025 Dietary Guidelines, ICCPUD’s Scientific Review Panel members were not appropriately vetted for conflicts of interest. It is unclear from the information in the Federal Register notice, what the HHS considers complementary in these studies, and why the ICCPUD resources were redirected. Given that National Institutes of Health (NIH) findings show marked declines in American kids’ health, and that, as never before, polls show Americans lack confidence in government and public health guidance, this approach to informing DGA guidance seems inappropriate.

3-Apparent bias of some of the reports’ authors – My research, prompted by the Congressman’s above statement, shows that ICCPUD authors and their study collaborators have been strongly tied to temperance organizations for many years. These include Movendi, which posts “scientific summary” opinion pieces as established science and fact. For example, a 2023 alcohol issues newsletter presents as the “latest science” on moderate alcohol consumption and health, a 2014 “research report”  from the IOGT (International Organization of Good Templars – Movendi’s previous name), co-authored by one of the ICCPUD panel authors, Tim Naimi. This, and the author’s ongoing ties to that group, is a conflict of interest that should be disqualifying. Even without the explicit affiliation to Movendi, no credible scientist should lend their name to this newsletter, which misleads in other severe ways that scientists would immediately recognize, while lay persons might not – which seems to be the point. I also perceive bias in this author’s study methodologies and those of his long-time collaborators whose work was heavily relied on for the ICCPUD report. Both the report and their other works, regularly and currently cited in Movendi literature along with their direct quotes, variously decry, praise/employ, study methodologies, seemingly according to which studies and interpretations support Movendi’s stance of no safe level of alcohol consumption. As for the NASEM study, one author previously received research funding from, and made a speech for, alcohol industry entities. This study’s breadth of expertise (as described above) and study inclusion, as well as its further peer review, appears to have overcome any potential alcohol industry bias in its findings. If not, this should be further scrutinized as well.

4-Confusion and mistrust created by the conflicting conclusions of the two reports, especially in the context of the above issues – Both reports rightly align on long-known health harms of excessive alcohol consumption (both over time, and binge drinking) in adults. Both reports necessarily (for cost and ethical reasons) rely on observational data, which can establish correlation but not causation, due to confounding health and lifestyle factors that scientists know can significantly influence – both negatively and positively – the health outcomes being analyzed. The NASEM report addresses this with its breadth of scientific expertise and appropriate nuance, while the ICCPUD report does not.

Although I am like most Americans in that I lack the subject matter expertise to assess these reports’ analytical and messaging quality deeply, the above issues were clear to me in reading the reports, and the extensive news reports quoting one of the authors’ close co-collaborators (in both research and temperance-entity work). Unsurprisingly, these scientists seek to spotlight their research in high-profile, news-making contexts like the US DGA update. Sadly, many credible publications with trained reporters have missed or ignored the bias and bad science. In this time in which Americans face a constant onslaught of authority figures delivering distorted messages or outright falsehoods in service of an agenda, it is essential that the science informing the DGA update pass the quality and bias tests.

Respectfully submitted,

Andrea Immer Robinson, MS

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