CCSA Report Academic Commentary
1. Augustine Brannigan & Richard Wanner, professors emeriti of sociology at the University of Calgary
Edmonton Journal, 01 February 2023
The public dissemination of the CCSA’s recommendations also has been marked by cherry- picking of results. For example, the evidence suggests that, among males, ischemic stroke is reduced by eight per cent for daily intake of 5-20 grams of alcohol.
Also, regarding diabetes, an illness of enormous concern in modern societies, the CCSA’s data suggest that consumption of alcohol increases the onset of diabetes only one to three per cent for males regardless of consumption levels (but the estimates are non-significant) and actually decreases the risk for females by about a third even at the highest levels of consumption.
We should put the risk assessments in context. What are the benefits of moderate alcohol consumption that the CCSA guidelines are designed to eradicate? This is something that the CCSA mentions but never discusses. Hot dogs, bacon and hamburgers are also carcinogenic. Who endorses a policy to have government warnings on these products?
Bottom line: you may minimally reduce your risk of certain illnesses by dramatically reducing your consumption of alcohol. Or you can assume very marginal risks for illness by adhering to the original guideline of two drinks a day.
2. Kiffer George Card, Assistant Professor in Health Sciences
The Conversation, 25 January 2023
Canada’s new drinking guidelines don’t consider the social benefits of alcohol. But should they?
… As the lead researcher on a national study aiming to develop Canadian Social Connection Guidelines, I would argue that the social benefits of alcohol use are fundamentally important to the development of public health guidelines for alcohol consumption.
Just as most people do not know that alcohol increases your risk for cancer, most of us also don’t realize that poor social health is just as, if not more, harmful than smoking, drinking, being obese, sedentary living and exposure to poor air quality.
In fact, the list of diseases and conditions that have been linked to social disconnection is expansive and includes depression and anxiety, psychotic disorders, cardiovascular disease, cancer, diabetes, neurocognitive impairments, poorer immune response, inflammation and poor metabolism.
While decades of research have warned about the dangers of loneliness and social isolation, public health bodies have not fully embraced the need to prioritize social connection.
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Reconciling the benefits and consequences of alcohol is certainly a challenge. This is especially difficult given that many studies on alcohol risk fail to capture meaningful dimensions of social life.
For example, studies rarely account for the social context of drinking when measuring the impact of alcohol on poor health. Similarly, the fact that many drinkers may have been exposed to high levels of second-hand smoke has not been fully accounted for in estimating its health consequences.
Measuring these potential confounders is especially important given that even if alcohol doubles or triples your risk for a given cancer, the risk in the first place may have been extremely low. Measuring very small changes in risk is hard. More and better studies are still needed.
3. Sylvain Charlebois, professor in food distribution and policy
Ottawa Citizen, 06 September 2022
Charlebois: Study concludes Canadians are drinking too much. But we may not care
These recommendations are based on improved science, but one can only assume Canadians won’t take these recommendations seriously. Notwithstanding the labelling recommendations, which will likely be received by the Canadian public with great apprehension, alcohol is very much part of the daily lives of many Canadians. Watching a hockey game, being with family and friends — it’s hard to imagine these moments without alcohol. Alcohol abuse and over-consumption are real issues and need to be dealt with, but most Canadians will probably feel that the proposed guidelines are not realistic.
In addition, governments in Canada rake in millions in tax revenues from alcohol sales every single year. The net income of liquor authorities in total taxes and other revenue in Canada was well over $13 billion in 2021, according to Statistics Canada. Total tax revenues were over $6 billion. Provinces and Territories depend on these sales to provide dividends to support public expenditure in various ways. Total revenues from liquor boards from across the country are up 13 per cent since 2016, which really should be considered a reasonable rate. But the balance between strong returns and social benefits for consumers is indeed delicate. The guidelines under study will influence our behaviours around drinking, as well as what health professionals will promote to patients and the community at large.
But what strikes many as strange is the relationship between Health Canada and the CCSA. The Ottawa-based group is supported with funding from Health Canada. The CCSA is essentially a non-governmental lobby which advocates for the reduction of harm caused by alcohol and drugs. When reading reports from the group, it is almost as if alcohol should be outlawed — well, almost. In other words, the CCSA’s goal is to raise awareness, reduce the amount of alcohol consumed in Canada and influence policy. It would be like asking People for the Ethical Treatment of Animals to review guidelines for the beef industry. It’s simply impossible to overlook potential predispositions and biases.
For Health Canada, to bring more credibility and perspective to the fore, it would have been more beneficial to either conduct consultation on its own or ask several groups to review the literature and come up with different sets of recommendations. It appears CCSA has the monopoly on scientific thought related to alcoholic consumption in Canada, and it should not. This important issue deserves much more consideration from a multitude of perspectives.
4. Sarah Dermody, assistant professor in the Department of Psychology at Toronto Metropolitan University
The Kit, 17 February 2023
So, Who’s Taking the New Alcohol Guidelines to Heart?
It’s true that drinking alcohol is really ingrained into our culture and has been for quite some time, says Sarah Dermody, an assistant professor in the Department of Psychology at Toronto Metropolitan University.” I think it is natural to question these new recommendations as they seem to contradict society’s understanding of alcohol as a substance for leisure, bonding, and coping,” says Dermody. “That being said, a large research literature has demonstrated that any alcohol use comes with risk. Of course, this risk will depend on the individual, situation, context, and so on. The guidelines are meant to provide a guideline for a level of drinking that will be relatively low risk.”
She notes that the two-glasses per week recommendation is a “one-size-fits-all approach” that is unfortunately the standard in public health communications. “On the one hand, some women may have underlying health conditions that suggest they should not drink at all. Other women may have different biology that could make them more or less susceptible to the harms of drinking,” Dermody explains. “It is important to keep in mind that these numbers may not apply to everyone. For instance, an issue with the guidelines is that they do not clarify how they should be used for gender diverse people, and this is a major limitation!”
She is also dubious about the two-drink limit. “I think we need to take it with a grain of salt. It’s like they can’t come out and say you shouldn’t drink at all, so they came up with this,” she says. “It’s like telling people it’s okay to just have two cigarettes a week. It’s unrealistic. For most, you either smoke or you don’t.”
5. Colin Farrelly, professor in the department of political studies at Queen’s University
National Post, 29 September 2022
Colin Farrelly: When public health becomes a tool of social control
Just a few weeks ago, a report was published by the Canadian Centre on Substance Use and Addiction, which states that “even very small amounts of alcohol (more than two drinks a week) can be harmful to people’s health.” This is about as trite as saying, “Driving your car can be harmful to your health.” What we really want to know is how risky such behaviour is.
Few things in life have no risks associated with them. And while the report highlights the seven cancers drinking alcohol can increase the risk of, such as breast and colon cancer, it is worth keeping in mind that there are over 200 different types of cancer and the incidence of most cancers increases with age. Abstaining from alcohol does not mean you will not get cancer.
So exactly how risky is having a glass of wine with dinner most nights? Good luck trying to get a clear answer on this question from the report.
By placing what is now considered low-risk levels of alcohol consumption into the highest-risk category, the report gives the impression that the risks of moderate or social drinking can be equated with those of alcoholism, or binge drinking, or drinking and driving, or drinking while pregnant. Rather than targeting those most at risk of the harms of drinking alcohol, these updated recommendations appear designed to try to persuade people not to tolerate any risks at all from alcohol consumption.
To which my response is: yeah, good luck with that! Abstaining from sex would also eradicate the risks of sexually transmitted diseases (as well as the human species). But I suspect few Canadians would be content to sign up for the monastic lifestyle, because the good life is not equated with the life of “maximally optimal health choices.”
6. International Scientific Forum on Alcohol Research
International Scientific Forum on Alcohol Research, 17 February 2023
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 134.5 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.
7. Dan Malleck, Professor of Health Sciences
CBC, 25 January 2023
Just how risky is it to drink more alcohol than Canada's new guide advises?
"My initial impression was, 'You've gotta be kidding!'" said Dan Malleck, a professor of health sciences at Brock University in St. Catharines, Ont., and an internationally recognized historian of alcohol and drug policy.
He suggested that the way the CCSA presented alcohol-cancer risks was overblown, adding that the lack of comparative risks made it difficult for people to absorb. "It was suggesting that somehow we can avoid death," he said.
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The CCSA authors point to a 2019 U.K study that compares the cancer risks of alcohol and tobacco. They say while it's not widely cited, and a bit problematic, due to the more addictive nature of tobacco, it's still an interesting comparison.
That study found that a standard drink is equivalent and comparable to one cigarette for men and two cigarettes for women. The summary explains that one bottle of wine per week is associated with an increase in lifetime cancer risk — the same as five cigarettes a week for men, or 10 for women.
But Malleck says there's nothing that clear in the new moderate alcohol-use guidelines, arguing cancer is being used as a scare tactic. He said the authors of the guidelines showed no evidence of a "radical" risk of cancer, except for people with oral cancers, liver diseases and a few other conditions, creating undue stress in the public.
"If you're creating anxiety and worry in people, you're not really doing anyone any favours, because we know that anxiety and worry have … negative physical health effects," said Malleck.
The Globe & Mail, 20 January 2023
Canada’s drastic new alcohol guidelines demand a closer look
Although reports have suggested that the guidelines are based on nearly 6,000 peer-reviewed studies, strict criteria ruled all but 16 systematic studies out from being used in the mathematical modelling. In other words, the CCSA is basing its recommendations on a relatively narrow understanding of how alcohol functions.
Often, too, these kinds of studies involve looking at a broad cohort of people and seeing if those with a certain condition were more likely to have been drinkers. If researchers are only looking for drinking as a factor, it can be easy to miss other potential contributors. We don’t know, for instance, whether they spent their time drinking in smoky bars or restaurants (back when that was allowed), or did so while eating less healthy foods; these factors are often marginalized when alcohol becomes the focus.
The CCSA also presents the relative risk, rather than the absolute risk, of developing the various conditions. According to its data, consuming three and a half drinks a day increases your risk of developing larynx cancer by nearly 100 per cent, which sounds shocking, and is presented in a table with scary red shading. But larynx cancer, which is mostly related to smoking, was diagnosed in roughly 0.0197 per cent of Canadians in 2022. Many of the other cancers the CCSA associates with alcohol also have low incidence rates. And everyone has a different level of risk for various conditions, based on factors including lifestyle and genetics.
Alcohol’s association with cancer is important to examine, and the disease should not be disregarded. But it also needs context. After all, life is about making choices – and it helps to be fully informed.
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And indeed, the CCSA made its recommendations without consideration of the potential (and well-documented) positive effects of alcohol on the lives of individuals, nor the potential harms caused by excessive and patronizing recommendations in the name of “for your own good” science.
These are important considerations, because human research on a population level (as compared with studies where all complicating factors are controlled in a lab, something you can’t do with long-term human research for legal and ethical reasons) is a point of contention among scholars. Although the CCSA does mention, near the end of the report, the considerable limitations to its conclusions, they do not seem to affect the urgency or excessiveness of its recommendations.
Meanwhile, persistent research results suggest that abstinence can cause greater health harm than moderate alcohol consumption. Moreover, alcohol can enhance lives in positive social ways: For many people, it is a way to celebrate or commiserate, to rejoice or mourn, to relax or blow off steam. There is robust research on the benefits of such social connectedness to health, showing that having positive social relationships can be more protective from long-term health harm than quitting smoking. Calling for significant lifestyle changes creates a stigma around something that can contribute to good health.
The CCSA has presented data that are largely removed from actual human behaviour, interactions and experiences – that is, the things that give life meaning. When you reduce human activity to a simplistic interpretation of biological processes, you are no longer looking at humanity. You’re just looking at numbers.
Without considering the potential dangers of such advice, and the potential benefits around moderate drinking, the CCSA recommendations seem worse than useless. They’re reckless.
8. Associate professor Jessica Mudry, director of the Healthcare User Experience Lab at Toronto Metropolitan University
Toronto Star, 29 January 2023
“More information is always better. And I’m a firm believer in evidence-based medicine,” said associate professor Jessica Mudry, director of the Healthcare User Experience Lab at Toronto Metropolitan University.
“But the second we quantify the consumption of anything … you create a framework for people to moralize others and to moralize themselves,” even if that one night out is a lifeline for someone craving social contact.
“On a cellular level, is alcohol a toxin? Absolutely. Will it kill you? Yes. So will sugar. So will meat. Life is pretty toxic.”
But, Mudry added, “is (alcohol) also an excuse for human connection? Yes. Is human connection vital to happiness and well-being and longevity? Yes.”
9. Dr. Edward Slingerland, professor of philosophy at UBC
The Ubyssey, 03 February 2023
Students, expert have mixed reactions to new CCSA alcohol guidelines
“The medical community is shifting toward a view that from a physiological perspective, alcohol is a net negative,” Slingerland said. “The problem with that, I think, is that it's looking at alcohol consumption solely from a medical perspective.”
Slingerland said humans have continued to consume alcohol despite dangers associated with it for thousands of years, and argued alcohol could be seen as, “as a cultural technology that humans have used in very specific situations to solve very specific problems.”
“[Alcohol] enhances creativity,” he said. “One of the functions of [alcohol] is to downregulate our prefrontal cortex. This is a very important part of the brain — it's what you need to get to work on time and focus on things and be a responsible adult — but it interferes with creative thinking, so turning it down a couple notches can help give you insights.”
“Another really important function is social bonding and social lubrication,” Slingerland said.
“It’s actually a tool for creating social bonds and helping strangers get over awkwardness and be able to feel connected to each other in some way.”
10. Christopher Snowdon, Institute of Economic Affairs (IEA)
Velvet Glove, Iron Fist, 19 January 2023
Canada's clown world drinking guidelines
Canada is on the brink of making itself an international laughing stock by cutting its drinking guidelines from two drinks a day to two drinks a week. The previous guidelines were only set in 2011 so Canadian drinkers can be forgiven for being suspicious about this dramatic change. The evidence base has not significantly changed in the interim. The evidence for the health benefits of moderate drinking has continued to pile up.
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The only source given for the claim about colon cancer is this meta-analysis which claimed that 10 grams of alcohol per day was associated with a seven per cent increase in colon cancer risk. This is a smaller risk than having a portion of red meat a day. It found no statistically significant increase in risk in studies which had data on what happens when people have one 'drink' a day.
A Canadian 'standard drink' contains 13.45 grams of alcohol. Three standard drinks equals 40 grams. Four standard drinks equals 53 grams. The meta-analysis has no data on people who drink so little, so the claim that colon cancer risk increases at three or more standard drinks is not supported even by the authors' own preferred source.
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This is just a flat out lie. As countless studies have shown, heart disease and stroke risk is substantially reduced among light and moderate drinkers. For example, a meta-analysis of prospective cohort studies (which track people’s drinking habits and health status over a number of years and are the most reliable studies in observational epidemiology) found that drinkers were 25 per cent less likely to die from coronary heart disease than teetotallers. The evidence for strokes is similar.
This is main reason why life expectancy is longer for moderate drinkers and the relationship between alcohol consumption and mortality is J-shaped.
The authors of the Canadian report essentially ignore all this evidence and instead focus on a cherry-picked meta-analysis written by Stockwell, Naimi and pals which massively adjusted the figures to arrive at their desired conclusion. This is inexcusable.
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The whole thing's a joke and I suspect the public will see it as such. There is a legitimate debate about whether low levels of alcohol consumption slightly increase cancer risk, but this has to put within the context of the reduction in risk for cardiovascular disease. The fact remains that the positive effects of moderate drinking on heart disease and other conditions exceed and outweigh the negative effects on cancer risk.
People want to know what the overall risks of light, moderate and heavy alcohol consumption are. This is what drinking guidelines should tell us. Focusing on small and unproven cancer risks at very low levels of consumption while ignoring the benefits is lying by omission.
11. David Sweanor, chairman of the advisory committee for the University of Ottawa’s Centre for Health Law, Policy and Ethics
City News, 31 January 2023
Will Canadians really accept two drinks a week?
“If you give people a scary message, but you don’t give them clear, actionable steps about what they can do about it, they just cut you out,”
12. Ronald Worton, former Geneticist-in-Chief at Toronto’s Hospital for Sick Children, and former CEO and Scientific Director of the Ottawa Hospital Research Institute
Health Debate, 19 March 2023
Health Debate: Context matters: Canada’s guidance on alcohol and health needs a rethink
As a moderate consumer of wine with dinner, I have examined the full technical report to determine my true risk. Using the report’s own data, I conclude that my risk is considerably lower than the high risk conveyed in the public summary – perhaps by a factor of five.
[various stats and calculations]…Taking all this into consideration, I calculate my actual risk in YLL/1000 to be 45 and for my wife 37. This gives us a risk of premature death of about 2.3 per 1,000, one fifth of the generic risk presented in the full technical report. And it should be noted that at our age, our risk of premature death from alcohol is small in comparison to all the other age-related risks we face.
Many people who attempt to estimate their own risk will use their current level of consumption as the starting point, and that would be wrong. The consumption data in the report is all based on lifetime average number of drinks per week, and that is what we used in our risk calculation. So, I can now confess that our current consumption is closer to two glasses of wine with dinner, but our estimated lifetime average is no more than seven standard drinks per week.
I acknowledge the extreme importance for Canadians to know and understand population health risks attributable to alcohol consumption. The report notes its own concern regarding the potential bias of information obtained through self-reported alcohol use. What my analysis shows is that guidance such as this must be accompanied by tools and data that allow individuals to estimate their own risk based on their age, current health, family history and consumption patterns over a lifetime.
Context really does matter, and a one-size-fits-all approach is unhelpful and for some, hurtful.