Report “seriously flawed” and proposal “not supported by preponderance of evidence”
WASHINGTON – The Distilled Spirits Council of the United States (DISCUS) submitted official written comments yesterday to the Departments of Agriculture (USDA) and Health and Human Services (HHS) highlighting critical flaws in the Dietary Guidelines Scientific Report and underscoring its opposition to the proposal to change the definition of moderate drinking. Click here to read the DISCUS comment
Under the proposal recommended by the Dietary Guidelines Advisory Committee, the 30-year Dietary Guidelines definition of moderate drinking for men would be reduced from up to two drinks per day, to no more than one drink a day.
The comments were written by DISCUS Chief Scientific Advisor Sam Zakhari, Ph.D., a renowned alcohol researcher with more than 40 years’ experience studying alcohol and health including 26 years at the National Institutes of Health.
“DISCUS supports the Dietary Guidelines for Americans (DGA) as an important source of helpful and practical information for healthcare professionals and for adult Americans who choose to consume alcohol,” Zakhari stated in the comments. “However, the 2020 DGAC Report reflects serious methodological and analytical flaws that undermine the scientific rigor and objectivity of its conclusions on alcohol consumption and all-cause mortality. In particular, the 2020 DGAC proposal to change the U.S. definition of moderate drinking deviates significantly and unjustifiably from long-standing, evidence-based U.S. dietary guidelines and contradicts decades of independent research findings.”
Zakhari said that the Dietary Guidelines Scientific Advisory Report, in fact, stated, “In the absence of binge drinking, low volume alcohol consumption…has low risk for most adults,” and pointed out that among those who drank alcohol, most studies found a lower risk of all-cause mortality among men consuming within ranges up to 2 drinks per day compared to those who never drank or consumed higher average amounts.
The DISCUS comment outlined significant shortcomings with the scientific report and its proposal, stating that the report:
- Violates the Committee’s published systematic review protocol that established rules for inclusion and exclusion of evidence;
- Lacks proper, transparent, and convincing citations and evidence to support its proposal to change the definition of moderate drinking; and
- Misrepresents information on alcohol consumption trends and exceeds the purview of the Dietary Guidelines.
“The Report’s conclusions on moderate alcohol consumption are seriously flawed, inadequately supported by evidence, and fail to address critical research questions (like the relationship between alcohol consumption and cardiovascular disease – the leading cause of death for Americans), while deviating into topics outside the scope of Dietary Guidelines,” said Zakhari.
“Remarkably, the Committee cited just one study that examined differences in risk amongst men consuming two drinks per day as compared to one drink per day—a study that has methodological problems.”
Zakhari called on USDA and HHS to retain the longstanding, evidence-based definition of moderate drinking included in the 2015 Dietary Guidelines stating, “the proposal does not reflect the preponderance of evidence and, therefore, should not be included in the 2020 Dietary Guidelines for Americans.”
USDA and HHS update the Dietary Guidelines for Americans every five years. The federal departments will consider the Committee’s Scientific Report, along with public and agency comments, as they develop the next edition of the Dietary Guidelines.