Beverage-alcohol industry trade groups didn’t hold back in their feedback to the Interagency Coordinating Committee on the Prevention of Underage Drinking (ICCPUD) about recent changes to the process by which the Dietary Guidelines Advisory Committee (DGAC) evaluates alcohol’s place in the Dietary Guidelines for Americans (DGA).
Comments from the Beer Institute (BI), Brewers Association (BA), National Beer Wholesalers Association (NBWA) and Distilled Spirits Council of the United States (DISCUS) come as a broader discussion about alcohol consumption has boiled over into mainstream media. ICCPUD requested comments be sent to it directly, rather than posted publicly on the Federal Register, by August 2.
The DGAC – a collaborative effort from the U.S. departments of Agriculture (USDA) and Health and Human Services (HHS) – meets every five years to revise the guidelines. In recent months, bev-alc trade groups have circled their wagons in opposition to the DGAC’s diversion from its usual process concerning alcohol consumption guidelines.
This year, alcohol has been separated from the DGAC’s work and is being examined in two separate reviews, one by ICCPUD, which has been the focus of the groups’ comments, and one by the National Academies of Sciences, Engineering and Medicine (NASEM).
Similar themes weave through the groups’ letters to Robert Vincent, the reports clearance officer for the Substance Abuse and Mental Health Services Administration (SAMHSA), ICCPUD’s parent organization. They include allegations that ICCPUD, which was created by the 2006 Sober Truth on Preventing Underage Drinking Act (STOP Act), is operating beyond its scope, duplicating NASEM’s work and lacking transparency.
“Despite the well-established record on congressional intent, the clear directive expressed in the STOP Act and the lack of historical precedent for providing input into the DGA process, ICCPUD is currently engaged in the 2025-2030 DGA review, including its proposed study on adult alcohol intake,” NBWA president and CEO Craig Purser wrote. “This expansion of authority clearly exceeds its original mandate and is a diversion from its national leadership on underage drinking concerns.”
In their joint letter, BI president and CEO Brian Crawford and BA president and CEO Bob Pease called out the disparity between ICCPUD’s focus on underage drinking and the DGA’s historic exclusion of minors from people who should drink.
“The policy and program development authorized by the STOP Act does not extend beyond underage illicit drinking and illegal underage access to alcohol,” they wrote. “The STOP Act does not mention the DGA, which is not surprising, given that the DGA historically has included those ‘under the legal age for drinking’ as people who should not drink at all.
“Not only does the language of the STOP Act fail to give ICCPUD the requisite authority to conduct independent research on legal alcohol consumption by adults, including research to inform the DGA or create bureaucratic panels to do the same, but the legislative history of the STOP Act fails to mention any authority to conduct research regarding LDA adults,” Crawford and Pease continued.
DISCUS SVP of science and research Amanda Berger pointed out that, by nature of ICCPUD’s original mission, it lacks the necessary professional experience to weigh in on nutrition.
“It is inappropriate for an underage drinking prevention group – comprised of researchers who lack expertise in diet, nutrition, and key health outcomes such as cardiovascular disease – to help develop dietary guidance for adult alcohol consumption,” she wrote.
All three letters called out a perceived lack of transparency into ICCPUD’s participation in the DGAC process, which Purser wrote was “being conducted with minimal or no transparency.”
“Neither HHS nor USDA has explained why ICCPUD has assumed the work traditionally conducted by the DGAC,” he wrote. “When limited information was finally made available in January regarding some of ICCPUD’s activities already underway at that time, details regarding its efforts and intended plan for a research review panel, the selection process for participants and the panel’s specific areas of review were not provided.”
Purser cautioned that the process’ opacity jeopardizes public faith in and acceptance of the DGA: “If the DGA is to serve as a credible source of information for the public, it is imperative that its development is supported by a legitimate and transparent process, review panelists are appropriately vetted for potential biases or conflicts-of-interest and final recommendations are based on a preponderance of objective scientific research and information.”
Crawford and Pease agreed: “The process should be far more open and transparent to ensure credibility and earn the public’s trust. Policymakers, stakeholders, and the public should know how ICCPUD selected the scientific review panel, why 50% of the panel members are from Canada as opposed to U.S. organizations, whether there are protections to prevent bias in its review and recommendations, and who will author the report.”
Both the BA and BI’s letter and DISCUS’ letter objected to tacks ICCPUD is taking. In particular, Crawford and Pease pointed out that ICCPUD is examining alcohol consumption on a weekly basis when the DGA focuses on daily consumption rates.
DISCUS’ Berger deemed it “inappropriate and unjustified” that ICCPUD is studying “non-health outcomes (e.g., motor vehicle crashes)” in its work.
“While these outcomes are important when it comes to developing guidance on reducing outcomes that are linked with alcohol misuse and abuse, these are not health/physiological outcomes that are caused by alcohol consumption,” she wrote.
Berger also called out the modeling research method ICCPUD is deploying, which she cautioned could result in “cherry-picking.”
“The research methods at the core of this work involve modeling, an easily manipulable methodology: what ‘goes in’ the model impacts what ‘comes out’ of it, and the researchers decide what ‘goes in,’” she wrote. “This is a genuine threat to the credibility of the proposed ICCPUD study. For instance, they frequently ‘cherry-pick’ the research/data to include in their models, often citing – but not defining – the ‘quality’ of the research/data in question.”
DISCUS requested an extension of the 30-day comment period, but received no response from ICCPUD, the trade group told Brewbound.