Mapping the Milestones:
The Bias Uncovered
The Review Process
The Dietary Guidelines for Americans (DGA) have included recommendations on alcohol consumption since their first edition in 1980. For over 20 years, these guidelines have consistently advised that moderate drinking—defined as up to one drink per day for women and up to two drinks per day for men—is considered safe and not harmful to health.
This long-standing recommendation is supported by a robust body of scientific evidence. Any changes to these guidelines should be based on a preponderance of medical and scientific evidence, ensuring that updates reflect the most accurate and unbiased information available.
Traditional Process
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Advisory Committee Established
Formation of an ad hoc committee under NASEM. A Congressional bipartisan group passed a law that designated NASEM as the review panel.
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Panel of Experts
NASEM conducts a transparent, deliberative review process led by experts with a defined scope of research, and with ongoing opportunities for public comment and stakeholder participation.
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Scientific Findings
NASEM makes recommendations on alcohol consumption based on the preponderance of scientific evidence.
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Accurate Guidance
HHS and USDA issue accurate guidance on alcohol consumption in the 2025-2030 Dietary Guidelines to inform the public on safe drinking levels to promote health and reduce risk of disease.
Unprecedented
Current Process
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Advisory Committee Established
Formation of subcommittee under ICCPUD. Unknown group forms ICCPUD technical review committee.
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Panel of Activists
ICCPUD subcommittee convenes a "Scientific Review Panel" led by unvetted, foreign activists with alarming ties to anti-alcohol interest groups.
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Biased Findings
The panel conducts rogue research in an opaque review process, drawing biased conclusions.
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Flawed Guidance
HHS and USDA consider flawed guidance on alcohol consumption in the 2025-2030 Dietary Guidelines that misleads Americans interested in living a balanced lifestyle.
THE CRUX OF THE ISSUE
Every five years, the Departments of Human & Health Services (HHS) and Agriculture (USDA) update Dietary Guidelines for Americans (DGAs). These guidelines must be grounded in the body of scientific and medical knowledge available at the time and not based on any individual studies or opinions. The process for developing the 2025-2030 DGAs is underway now.
Breaking from a decades-long process, HHS & USDA have determined that updating the alcohol guidelines should be handled separately from the work of the 2025 Dietary Guidelines Advisory Committee, the group officially tasked with reviewing the science for Dietary Guidelines topics. Instead, they have created a duplicative process with a group that was appointed without transparency or public input. In the Advisory Committee’s place, two parallel reviews are being conducted on the topic of adult alcohol consumption.
The first review, conducted by the National Academies of Sciences, Engineering, and Medicine (NASEM), was Congressionally mandated. The second review, conducted by the Interagency Coordinating Committee on the Prevention of Underage Drinking (ICCPUD) has been marred by issues such as unaddressed conflicts of interest, a lack of stakeholder input, a lack of public transparency, and the use of an unprecedented review process. This ICCPUD process threatens to undermine the bedrock credibility of the DGAs, which rests on transparency and accurate descriptions of the existing body of scientific knowledge.
UnprecedentED Process
The Dietary Guidelines for Americans review of alcohol has been handled by USDA and HHS-appointed panels. This year a duplicative review panel was established under the Interagency Coordinating Committee on the Prevention of underage drinking, which lacks expertise in moderate alcohol consumption.
LACK OF TRANSPARENCY
Timeline Discrepancies
Official statements and public spending records don’t align with the timeline provided to us by USDA and HHS.
Ignored Oversight
ICCPUD’s overseeing bodies have been unresponsive to public and expert concerns.
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Less than 30 days were provided for public comments, fewer than standard. Multiple requests for an extension were turned down.
Significant Impact
A biased review process will undermine government programs and trust in government recommendations.
Unprecedented Process
Lack of Statutory Authority
ICCPUD lacks the statutory authority and congressional authorization to advise on this issue.
Original Research
The ICCPUD panel intends to develop original research to guide DGA recommendations. This goes against the precedent set for DGA supporting evidence.
Ignoring Past Guidelines
Past guidelines have been consistent in their tolerance for moderate alcohol consumption, significant evidence should need to be provided to alter existing recommendations.
LACK OF STAKEHOLDER INPUT
Secret Selections
ICCPUD panel members were hand-selected in a secretive process without a public comment period or nomination.
Lack of Expertise
The panel includes no cardiologist, despite heart health being central to discussions on the physiological impact of alcohol.
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Review Panel
Closed Door Meetings
The panel has consistently rejected requests for additional public insight into their proceedings.
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Example: Comment Period
ABUNDANCE OF BIAS AND CONFLICTS OF INTEREST
Undisclosed Conflicts
Some of the ICCPUD scientific review panel members failed to meet basic conflict of interest disclosure standards.
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Jurgen Rehm’s work has been touted by Movendi.
Financial Ties
Panel members received direct funding from international anti-alcohol groups.
Recycled Evidence
Many studies supporting “no safe level” are repackaged, not new research.
Flawed Methods
Anti-alcohol activists rely on unproven methodology, like Mendelian randomization and opaque modeling methodology.
How Are the NASEM and ICCPUD Reviews Different?
The ICCPUD approach to the 2025-2030 alcohol guideline review does not align with the overall dietary guidelines process. Alcohol is currently the only commodity undergoing a different review process.
Does the review panel have the authority and expertise to complete the alcohol review?
Congressionally mandated in the 2023 Consolidated Appropriations Act.
Made up of individuals with expertise in underage drinking prevention, NOT adult dietary guidance.
Is the review free from bias and conflict(s) of interest?
Conducted by 14 experts who were publicly nominated and vetted.
Conducted by 6 secretly chosen experts who are anti-alcohol activists, 3 of whom are from Canada.
Does the process align with the standard Dietary Guidelines process and protocols?
Using methods that align with the rest of the Dietary Guidelines process, including a review of existing evidence and responding to publicly vetted research questions.
Using original research and modeling, which is UNPRECEDENTED for any DGA topic. This is an easily manipulatable methodology.
Is the review transparent and inclusive of stakeholder input?
Held meetings open to the public and provided opportunities for stakeholder input.
Held secret meetings for more than a year with no meetings open to the public or public comment opportunities.
Is the review grounded in health and nutrition science?
Examining 8 alcohol and health topics identified and refined with stakeholder and researcher input.
Including non-health outcomes in research that are inappropriate for developing dietary guidance, outcomes like motor vehicle accidents, child maltreatment, drowning, and firearm injuries.