Petition Asks Bureau of Alcohol, Tobacco, and Firearms
Labeling efforts from 1999
for Conspicuous and Readable Labels

WASHINGTON - Regulations governing health and safety warnings on alcoholic-beverage labels need to be improved, according to a coalition of more than 120 public health, consumer, safety, and child-protection organizations and four members of Congress. In a petition for rulemaking spearheaded by the Center for Science in the Public Interest (CSPI) and the National Council on Alcoholism and Drug Dependence (NCADD), the groups and U.S. Senator Robert Byrd (D-WV) and U.S. Representatives John Conyers (D-MI), Lucille Roybal-Allard (D-CA), and Zach Wamp (R-TN) asked the Bureau of Alcohol, Tobacco, and Firearms (BATF) to insure that alcohol warning labels meet basic criteria for effective label design. The mandated warning label alerts consumers about the risks of birth defects due to drinking alcohol during pregnancy and the risk of drinking and driving.

The petition to BATF recommends that the health warning be clear and conspicuous, appear in a prominent place on the front label of the alcoholic-beverage container, and be printed horizontally. It seeks a requirement for highly visible labels printed in black or red type on a white background and surrounded by a lined border. According to the petition, the warning message should include a red pictorial device or icon to draw attention to the notice. In order to improve legibility, the petition also asks that the text of the warning message appear in upper and lower case -- as specified in the current statute and regulations.

"A cursory review of bottles and cans of beer, wine, and liquor reveals that too many label warning messages are carefully designed to go unnoticed and ignored. It’s high time -- ten years since the warning-label law went into effect -- that the regulators at the Bureau of Alcohol, Tobacco, and Firearms start requiring what Congress intended: conspicuous, visible, and readable warning messages," said George A. Hacker, director of the Alcohol Policies Project at CSPI.

A brief survey of alcoholic-beverage labels found that current warning messages are often hidden on a back label or neck ring; printed vertically, rather than horizontally; and printed in a color that does not contrast with the background. Many label warnings are too small to read easily or so compressed as to be barely legible. In addition, all labels warnings appear to be printed exclusively in upper-case letters, making them even more difficult to decipher.

According to findings from the U.S. Centers for Disease Control, one in eight women of childbearing age (18 to 44 years old) reported "risk drinking" (seven or more drinks per week, or five or more drinks on any one occasion). One of every 29 women who knows that she is pregnant reports risk drinking. Drinking alcohol at those levels could pose a serious health threat to the unborn fetus. The estimated incidence of fetal alcohol syndrome ranges from 0.2 to 1.0 per 1000 live births, though potentially many more children suffer a wide range of less severe neurological and behavioral fetal alcohol effects.

Among pregnant women, alcohol use decreased from 22.5% in 1988 (before the label law went into effect) to 9.5% in 1992, and then increased to 15.3% by 1995. Frequent alcohol use among pregnant women decreased from 3.9% in 1988 to 0.9% in 1991 and then increased to 3.5% by 1995.

Current BATF regulations ignore the lessons of scientific research about factors that make warning labels visible and effective. According to the U.S. Department of Health and Human Services, "the modest effects of the alcohol warning labels may result from the use of labels that fail to follow established principles of effective warning design."

"If consumers are expected to heed the warning, they must be able to read the warning," said Sarah K. Kayson, NCADD’s Director of Public Policy. "This petition provides BATF with the support it needs to make effective modifications to the current warning label."

Efforts to pass the Alcoholic Beverage Labeling Act of 1988 (USC 27, Sec. 215(a)) in the House of Representatives were led by Rep. John Conyers. The Act prescribed a 42-word warning message that was implemented by BATF regulations in November 1989. The Act provides that the warning statement be "located in a conspicuous and prominent place" on alcoholic-beverage containers and "shall appear on a contrasting background." BATF regulations (27 CFR 16) require that the warning language be "readily legible under ordinary conditions," printed "on a contrasting background," and be placed "separate and apart from all other information." In both the Act and regulations, the warning message (except for the words, "GOVERNMENT WARNING") is spelled out using upper and lower case letters.

Co-petitioning organizations include: the American Academy of Pediatrics, American Medical Association, American Public Health Association, Mothers Against Drunk Driving, the National PTA, National Organization on Fetal Alcohol Syndrome, The Arc, Community Anti-Drug Coalitions of America, Consumer Federation of America, Elks Drug Awareness Program, and Join Together.

CSPI is a nonprofit health-advocacy organization based in Washington, D.C. that focuses on food safety and alcoholic-beverage issues. It is largely supported by the more than one million subscribers to its Nutrition Action Healthletter. CSPI led efforts to win passage of the law requiring warning labels on alcoholic beverages.

CSPI Alcohol Labeling Study
Final Results

Results of a nationally representative 10-15 minute telephone poll conducted among 801 U.S. residents 21 years of age and older. The study was conducted for CSPI by Penn, Schoen and Berland Associates. Margin of error is +/- 3.5% at the 95th percentile confidence interval level.

Abbreviations used are as follows:

• All (all 801 respondents),

• M (male),

• F (female),

• DRINK (drink alcohol),

• NO DRINK (do not drink alcohol).
   

Table of Contents

1. Awareness, Knowledge and Usage of the Health Warning Statement 2

2. Attitudes Toward the Health Warning Statement (Agree/Disagree Questions) 9

3. Effectiveness of Possible Changes to Health Warning Statement 11

4. Actual Wording of Questions 14

Notes:

• The number in parenthesis under the column heading is the number of respondents.

• The numbers that appear as whole numbers within the columns are actually percentages.

1. Awareness, Knowledge and Usage of Health Warning Statement

2. Attitudes Toward the Health Warning Statement (Agree/Disagree Questions)

I am going to read a list of statements. Please tell me whether you strongly agree, somewhat agree, somewhat disagree or strongly disagree with each.

3. Effectiveness of Possible Changes to Health Warning Statement to Make Them More Noticeable and Readable

I am going to read a list of possible changes to the health warning statement that appears on alcohol beverages. Please tell me whether you think each would be a very effective, a somewhat effective, a not very effective or a not at all effective method to make warning labels more noticeable and readable.