Karen Kuehn Howell PhD Emory University School of Medicine

Comment 89 June 24, 2005 Chief, Regulations and Procedures Division Alcohol and Tobacco Tax and Trade Bureau Attn: Notice No. 41, P. O. Box 14412 Washington, D. C., 20044-4412 Dear Sirs: Thank you for requesting public comment on Labeling and Advertising of Wines, Distilled Spirits, and Malt Beverages. The Georgia Fetal Alcohol Syndrome Task Force submits the following comments and recommendations: Alcohol use during pre-conception and pregnancy poses serious risk to the unborn child, and can cause neurological deficits including mental retardation. Drinking during pregnancy increased greatly during the decade of the nineties in the U.S. Risky drinking among teen girls and young women approaching their child-bearing years continues to increase; this is deeply troubling because the Centers for Disease Prevention and Control report that prenatal drinking patterns are highly predictive of alcohol use during pregnancy. Government policy including limited sales, increased taxes, and warning labels are effective in reducing high-risk drinking, including drinking during pregnancy. These policies are low cost interventions that bring significant health benefits and substantial cost savings. (Cost for lifetime care of an FAS child has been estimated at more than $1.4 million.) Please include in your revised labeling requirements the following:  Special labels warning about dangers of drinking during pre-conception and pregnancy;  Labeling that includes the U.S. Surgeon General’s warning that women should not drink during pregnancy; and,  Messages that women who are pregnant and unable to stop drinking should seek help. Also, please provide that:  Messages will be presented in several versions, to promote reading and retention of the message; and,  Messages will be rotated on a periodic basis, such as annually, to promote reading and retention of the message. This low-cost intervention will help increase public awareness of risks of drinking during pregnancy and help reduce the incidence of alcohol-related neurological deficits and Fetal Alcohol Syndrome, a leading cause of mental retardation. Thank you for your consideration. Sincerely, Karen Kuehn Howell, PhD Senior Research Scientist, Emory University School of Medicine and Co-Chairperson Georgia Fetal Alcohol Syndrome Task Force Maternal Substance Abuse and Child Development Project 1256 Briarcliff Rd. N.W. Atlanta, Ga. 30306 404-712-9829