Comment 04114654

'TTB Notice No. 41'From: Sheila Abood [Sheila.Abood@ana.org]
Sent: Thursday, September 08, 2005 4:01 PM
To: Rulemaking, TTB
Subject: 'TTB Notice No. 41'

name=Rose Gonzalez
name=American Nurses Association
Address1=8515 Georgia Ave
Address2=Suite 400
City=Silver Spring
State=MD
Zip Code=20910-3492
Comments=September 8, 2005


Chief, Regulations and Procedures Division
Alcohol and Tobacco Tax and Trade Bureau
Attn: Notice No. 41
P.O. Box 14412
Washington, DC 20044-4412

Re:     Notice No. 41

To Whom It May Concern:

On behalf of the American Nurses Association (ANA), the only full-service professional organization representing the nation's registered nurses (RNs) through its 54 constituent member associations, I am writing in response to the Alcohol and Tobacco Tax and Trade Bureaus (TTB) advance notice of proposed rulemaking on alcohol beverage labeling and advertising.

In sheer numbers and its toll in death and disability, obesity has reached crisis proportions in the United States. According to the most recent government statistics, U.S. obesity rates, already among the highest in the world, are continuing to go up -- from 19.8 percent of American adults in 2002 to 20.9 percent in 2000. As a result, more than 44 million Americans are now classified as obese, a jump of 74 percent since 1991.

To address this challenge requires providing the public with the tools to make more informed consumption decisions, including labeling information about the alcohol content, serving size and calorie content of all beer, wine and distilled spirits products. That is why ANA supports the TTBss effort to require a mandatory Alcohol Facts panel on the labels of all alcoholic beverages. Moreover, the Alcohol Facts panel should be required to contain the following information in a standardized format:
       The serving size (i.e., 12 fluid ounces (fl oz) for beer, 5 fl oz for wine, and 1.5 fl oz for distilled spirits);
       The number of calories per serving;
       The amount of alcohol (in fl oz) per serving);
       The percentage alcohol by volume;
       The definition of a standard drink;
       The number of standard drinks per container; and
       The Dietary Guidelines advice on moderate drinking (i.e., U.S. Dietary Guidelines advise moderate drinking: no more than 2 drink per day for men, 1 drink per day for women).

At the same time, the ANA supports the TTBs goal of requiring the labels of all alcoholic beverages to identify any major food allergens present in the product. Alcohol beverages can contain major food allergens, such as milk and eggs, the same as any other food product. Thus, labeling that identifies potential allergens will be a significant step in protecting the public health.

Finally, the ANA believes that the public will benefit from having this labeling information as soon as possible, which is why we would support an interim policy decision allowing bottlers to label their products voluntarily with information about the alcohol content, number of calories and allergen information.

We appreciate the opportunity to provide comments and TTBs consideration of these comments.

Sincerely,
Rose Gonzalez
Director Government Affairs
American Nurses Association
rose.gonzalez@ana.org