Recommended Canadian Drinking Guidelines: Advocacy Solution in Search of a Policy Problem
By now, most Canadians know that the Canadian Centre on Substance Use and Addiction (CCSA), a research and advocacy organization contracted by the federal government, has recommended radical changes to guidelines for liquor consumption, and purports to speak for Health Canada in issuing “Canada’s Guidance on Alcohol and Health” (January 2023). In late February 2023, Canadians learned that Statistics Canada data show a decline in the volume of liquor sold between 2021 and 2022. Canadians purchased (and drank) 1.2% less alcohol last year than we did in 2021: 4% less wine and 2.8% less beer. The average consumption level of 9.7 standard drinks per week is lower than the 2011 guidelines of ten standard drinks per week for women and 15 for men.
The CCSA report is an advocacy solution in search of a policy problem. The problem presented itself in 2020 and 2021: elevated pandemic-era liquor consumption by Canadians. CCSA’s proposed solution – two standard drinks per week for women and three for men – rests on a selective interpretation of its terms of reference, narrow reference to international research on the health harms of wine, beer, spirits and other drinks, and an incomplete risk picture for deleterious health and social effects from drinking. Worse, it leverages a set of conditions that no longer hold: Canadians are drinking less, which implies that when conditions changed (i.e. pandemic restrictions loosened or ended) citizens generally exhibited a sense of personal responsibility and reasonable self-regulation in their consumption.
International Scientific Critique
On scientific merit, the report’s characterization of risk and harm has come under blunt criticism. The International Scientific Forum on Alcohol Research (50 university-affiliated experts worldwide) has reviewed (“Critique 261”) the CCSA’s recommendations and found them selective and biased in their source research, out of line with peer countries’ guidance, and misleading in ascribing overall risk from drinking across Canada’s adult population. The lengthy quotation below captures the main points of the Forum’s critique:
“The scientific evidence relating to both abusive and moderate alcohol consumption is itself not sufficiently consistent to produce precise recommendations for safe drinking for every alcohol consumer. There is no clear scientific evidence that uniformly applies to all population groups.
Current scientific data clearly indicate that, in comparison with abstainers, individuals who report the regular consumption of small to moderate amounts of an alcoholic beverage, when consumed with food markedly reduces their risk of coronary heart disease, type II diabetes mellitus, and total mortality. These relations have been found in essentially every well-done cohort study for many decades. By being very selective in choosing studies that support their preconceived ideas, by combining in their analyses data from many diverse cultures and populations with varying lifestyles, and especially by ignoring the pattern of drinking (regularly versus in binges, with or without food, etc.), the authors have created guidelines for drinking that do not apply to any single individual or population.
Accordingly, the Forum believes that these recommended guidelines do not contribute to their own intention to allow Canadians to make well-informed decisions on alcohol use and how it will affect their health. Furthermore, the evidence base assessing all-cause mortality and the risk of mortality from any cause at the 2011 alcohol level of 135 g/week for women, with no more than 27 g/day most days and 202 g/week for men, with no more than 40 g/day most days, remains robust and the hence the 2011 guidelines remain relevant to Canadians rather than the 2023 CCSA recommendations.”
The culture of an advocacy organization like CCSA, founded as it was to prosecute Canada’s war on drugs (under former Prime Minister Mulroney in the 1980s to mirror the same initiative in the U.S. under President Reagan) eventually comes through in a report’s language, providing clues about the orientation of the authors to their subject matter. In this case it is decidedly prohibitionist. Canadians should know that the authors regard alcohol as a “sinful good” which they define as follows: “when people use it they get pleasure now and suffer the consequences later” (at p. 48). How this pejorative statement is appropriate to liquor but not cannabis or other drugs (on which it also produces research and commentary) is not explained by CCSA.
This bias casts the recommendations in a darker light than has yet been presented to the public, and raises troubling policy questions for Health Canada, for which the report was prepared. Health Canada, in particular Mental Health and Addictions Minister Carolyn Bennett, has yet to comment publicly on the radical reduction in recommended consumption from 2011 - which remain in line with most Commonwealth and other peer countries.
Health Canada’s Public Policy Obligation to Canadians
Health Canada has an obligation to present a complete picture to Canadians by reviewing the recommendations and making public its findings. As Dan Malleck, Professor of Health Sciences at Brock University noted to me, there is a policy vacuum in Canada around the consumption of liquor, and the CCSA is seeking to fill it. It is not appropriate for a federal department to implicitly outsource policymaking to a biased advocacy organization on such an important and complex public health and societal matter.
A proper response by Health Canada would include a scientific review of the research literature and CCSA’s assertion of the strength of the causal connection between drinking, mortality and development of severe disease; and a more comprehensive risk profile for sub-sets of the population.
Further, a Health Canada public policy evaluation would address the awkward disconnect between its own terms of reference directing CCSA to incorporate methodology from recent research by Australia and the United Kingdom and the reality that neither of those countries has reduced its official consumption guidance in response to such research.
It should offer Canadians an accounting of the beneficial personal, social - and yes, physical - effects of low to moderate consumption beyond the parameters of purely physical public health. As Edward Slingerland, Professor of Philosophy at UBC pointed out in our interview, a glass or two of beverage alcohol has an intrinsic hedonistic value (it makes you feel good), as well as dulling the functions of our pre-frontal cortex just enough to make possible cooperation, innovation and the formation of social bonds. (To be discussed more fully in a future post.)
Finally, when Health Canada conducts its review of CCSA’s report, it must decide whether to adopt or alter recommended consumption levels; respond to the policy advice of adding a health warning to the label of every alcohol container sold in Canada; and reconcile its permissive, harm-reduction messaging regarding cannabis and other recreational drugs with the impression deliberately created by the CCSA that no level of alcohol consumption should be tolerated in Canadian society.
If you wish to receive all WineDrops posts, please join the mailing list here: https://winedrops.ca/contact.