3 The evidence base
The 1995 Sensible Drinking report
15. As
explained in the previous chapter, today's alcohol guidelines
arose from a review of the Government's sensible drinking message
in the light of evidence which indicated that drinking alcohol
might give protection from coronary heart disease.[29]
The findings of the review were published in the 1995 report Sensible
Drinking.[30] The
Department of Health explained the process that the working group
had followed:
The authors of the 1995 report drew upon a wide
range of research, including epidemiological evidence, and written
and oral advice of experts, as set out in the report. The report
considers the harmful effects of alcohol consumption to both health
and mortality and considers the evidence for its potential benefits.
[...]
The 1995 report carefully described the scientific
basis for its recommendations, which included review by the authors
of the major published research evidence, review of written evidence
submitted by a wide range of contributors, independent assessment
and critique of the medical and scientific evidence by an external
academic statistician, and receipt of oral evidence by invited
key experts.[31]
16. Sources of evidence to the 1995 review included
relevant reports of the various Royal Colleges.[32]
As mentioned in paragraph 5, these reports had re-endorsed the
1987 consumption guidelines of no more than 21 units of alcohol
for men and 14 for women per week.[33]
Weekly vs. daily guidelines
17. Possibly the most significant change in the guidelines
following the 1995 Sensible Drinking report was the move
from providing weekly guidelines to daily guidelines. Dr Richard
Harding, member of the 1995 Sensible Drinking working group,
explained that the working group had thought it sensible to move
away from advice based on weekly consumption in favour of daily
consumption because "weekly drinking could mask episodes
of heavy drinking (21 units/week could be consumed in two binges
of 10 units each)". The working group also considered that
it was difficult for individuals to keep account of their own
consumption over a week. Furthermore, there was evidence that
showed there could be benefit in regular drinking, so long as
it was moderate. As a result, the working group decided to couch
advice in terms of daily drinking.[34]
The Sensible Drinking report therefore stated
that for men:
Regular consumption of between 3 and 4 units
a day by men of all ages will not accrue significant health risk.
Consistently drinking 4 or more units a day is
not advised as a sensible drinking level because of the progressive
health risk it carries.[35]
And for women:
Regular consumption of between 2 and 3 units
a day by women of all ages will not accrue any significant health
risk.
Consistently drinking 3 or more units a day is
not advised as a sensible drinking level because of the progressive
health risk it carries.[36]
18. Two concerns were raised about the shift to daily
guidance. First, the change appeared to increase the weekly "allowance"
of alcohol from 21 for men and 14 for women to 28 for men and
21 for women. The Institute of Alcohol Studies (IAS) argued that
the move:
effectively increased the weekly limit for men
by 33 per cent and women 50 per cent, exceeding the recommended
threshold for low risk drinking as presented by the medical profession.
These changes were met with concern by the health community, as
they contradicted the evidence base.[37]
Secondly, some felt that the move "appeared
to endorse daily drinking".[38]
This issue is examined in paragraph 49 where we look at drinking
patterns.
HEALTH BENEFITS OF DRINKING ALCOHOL
19. The primary rationale for the shift to daily
guidelines was evidence that regularly drinking alcohol at low
quantities may confer health benefits, particularly in relation
to coronary heart disease (CHD), which, according to Dr Marsha
Morgan, Institute of Alcohol Studies, is where "the biggest
body of evidence on the potential beneficial effects of alcohol"
lies.[39] According
to the 1995 Sensible Drinking report, "the evidence
shows alcohol consumption confers protection from CHD mortality,
starting at levels as low as 1 unit a day".[40]
However, the report also cautioned that there was only a slight
dose response relationship, meaning that drinking more than one
to two units a day "confers only a little extra benefit"
and that at very high levels of consumption, the risk of mortality
increases.[41]
20. The report summarised possible biological mechanisms
that would explain the beneficial effect, although it acknowledged
that a causative mechanism had not been firmly established. It
explained that a major cause of CHD is deposition of fatty tissues
in coronary arteries, largely consisting of cholesterol, which
cause narrowing or blockages of arteries. In blood, two types
of protein work to either increase or decrease cholesterol levels.
Simply put, low density lipoproteins (LDL) carry most of the cholesterol
in blood and high density lipoproteins (HDL) remove cholesterol.
It is the ratio of LDL and HDL that determines how much cholesterol
is deposited in fatty tissues in arteries. The report stated that:
Physical activity appears to raise HDL cholesterol
but does not change LDL cholesterol levels. Alcohol, more than
any other dietary factor, raises HDL levels in the blood.
In addition, however, alcohol
lowers LDL blood levels, and it has been speculated that it is
through these lipoprotein cholesterol pathways that alcohol inhibits
the formation of coronary [fatty tissues].[42]
Another significant biological mechanism was thought
to be that alcohol reduced blood clotting. Additional and less
widely acknowledged mechanisms were also offered, including that
alcohol:
a) might lower blood pressure;
b) caused increased blood flow;
c) could reduce coronary artery spasm induced
by stress.[43]
However the report noted that "the full significance
of these additional mechanisms awaits further research".[44]
The submission from the International Scientific Forum and Alcohol
in Moderation stated that "the message is little and often
as the blood thinning effect of alcohol lasts for approximately
24 hours and one drink confers the benefit".[45]
Interestingly, the report also explored the theory that the low
rates of CHD in predominantly wine drinking countries could be
caused by the presence of antioxidants and other constituents
in wine. The report concluded that "overall, current research
indicates that the major factor conferring benefit is probably
alcohol rather than the other constituents of wine".[46]
21. The report highlighted other potential benefits
from drinking alcohol, including mixed evidence for the effects
of alcohol on stroke risks and a possible protective effect from
gallstones. It had also been reported that there could be a reduced
risk of non insulin-dependent diabetes, stress, rheumatoid arthritis,
gastro-intestinal diseases and colds, although the report stated
that "in our view, this evidence is not sufficiently strong
or consistent to inform public policy".[47]
22. The theory that drinking alcohol at low quantities
might confer health benefits greater than abstainers would enjoy,
but that drinking alcohol at high quantities increases mortality
risk is represented by the J-shaped curve. Figure
1: The J-shaped curve for all cause mortality and alcohol consumption[48]
![](153601.gif)
Explanatory note: A confidence interval helps assess the likelihood of a result occurring by chance. A confidence interval represents a range of values that is believed to encompass the "true" value with high probability (usually 95%). In figure 1, this means that the wider the gaps between confidence intervals surrounding the trends for men and women, the more uncertainty there is.
|
The International Scientific Forum on Alcohol Research
and Alcohol in Moderation explained that:
The J shaped curve shows that light and moderate
drinkers of any form of alcohol live longer than those who abstain
or drink heavily. The relative risk of mortality is lowest among
moderate consumers (at the lowest point of the J), greater among
abstainers (on the left-hand side of the J), and much greater
still among heavy drinkers (on the right-hand side of the J).
In addition to longevity in general, the J-shaped relationship
also exists for cardiovascular deaths, specifically for coronary
heart disease and ischemic stroke.[49]
The greater uncertainty for women, represented by
the wider confidence intervals, may be due to a lack of evidence:
the Sensible Drinking report noted that "sufficient studies
on all cause mortality do not exist to indicate clearly the advantages
or disadvantages of alcohol to women as compared to men".[50]
This issue is explored further in paragraph 29.
23. The evidence we took during this inquiry suggested
that a number of experts were less convinced that alcohol caused
beneficial effects in the body. For example, Sir Ian Gilmore,
Royal College of Physicians, stated:
There probably is an effect, but it does not
affect the main age group that is damaged by alcohol. The peak
deaths from alcohol are among 45 to 65-year-olds, who are in the
most productive phase of their lives. Certainly young people damaged
by alcohol get no cardio-vascular benefit whatsoever. There are
serious scientists who still believe that the apparent cardio-vascular
benefits are spurious. [...] I believe it is overplayed as a benefit.[51]
Professor Nick Heather, Alcohol Research UK, agreed,
and stated:
when the "Sensible Drinking" report
was written [...] there was much more confidence in the cardio-protective
effect, which is reflected in the report [...] That consensus
has now largely disappeared, which is the result of more careful
research.[52]
Dr Marsha Morgan noted that "there is enormous
contention [...] in general" and pointed out that "if
there were to be a cardio-protective effect, it would selectively
be found in middle-aged men and post-menopausal women, and you
do not gain that protective effect in middle life by drinking
at a younger age".[53]
She also disputed the evidence for other beneficial effects of
alcohol and highlighted evidence that had emerged since 1995 on
alcohol-related cancer risks:
The two other areas where there have been alleged
protective effects are in the development of diabetes and possibly
[...] on the development of cancers. However, the evidence is
very thin. There is no body of evidence like that for the cardio-protective
effect. Much more important, since the guidelines were last considered
in 1995, is that the major body of evidence has been on the detrimental
effect of alcohol and the cancer risk, particularly for breast
cancer in women, and that the risk levels are not far off the
top end of the current guidelines. Although there have been some
reports in the press for a protective effect about diabetes and
some types of cancer, there is not a strong evidence base.
Equally, there is much more important evidence
that we did not have in 1995 which suggests a quite significant
risk of cancer of the oropharynx, larynx and oesophagus and cancers
among people who already have liver damage, and there is evidence
on breast cancer and to a degree some early evidence on bowel
cancer. As far as I am concerned, those detrimental effects overwhelm
any potential benefit that there might be on diabetes.[54]
24. One reason why the beneficial effects of alcohol
are disputed lies in the methods used to gather data and produce
studies. To determine whether alcohol has a beneficial effect,
the mortality risks of drinkers must be compared to lifelong non-drinkers,
or abstainers. We heard that some studies had in fact included
"sick quitters"that is, individuals who abstained
from alcohol because "they have an alcohol problem or are
unwell"in the abstainer category.[55]
This would make abstainers appears less healthy and thus indicate
that there could be health benefits gained from drinking alcohol.
Professor Heather stated that more careful research on the cardio-protective
effects of alcohol had shown that "people who were classified
as lifetime abstainers were not really lifetime abstainers".[56]
In response, Dr Richard Harding, member of the working group,
stated that:
The "sick quitter" hypothesis is that
the abstainers are unwell and therefore have a higher rate of
disease. However, some studies have been large enough to take
them out, yet when you omit the sick quitters and lifetime abstainers
you still see the effect. In many studies, the confounding factor
has been taken care of.[57]
In addition, there are methodological difficulties
that arise from proving causation; that is, whether alcohol itself
confers health benefits rather than confounding factors such as
eating healthily and exercising, which may be common behaviours
amongst moderate drinkers. Studies may also be skewed by inaccurate
reporting of alcohol consumption by individuals.[58]
The Department of Health's
view on the matter was that:
A number of studies have been published since
1995 on the protective effects of low level alcohol consumption.
Some have suggested that the effect for coronary heart disease
may have been over-estimated [...] We think it likely that the
conclusion of the 1995 report that a risk reduction is likely
from levels of regular consumption as low as one unit per day,
with limited additional benefit at levels above that, is still
correct. However, we have acknowledged in advice to the public
that a similar reduction of risk may be achieved through other
means such as improved diet and exercise.[59]
We asked Anne Milton MP, Parliamentary Under-Secretary
of State for Public Health, whether the Government believed that
alcohol had beneficial effects. She responded:
There is, possibly, evidence to suggest that
it remains true for older adults. However, a number of experts
and research books recently have raised some questions about the
robustness of that body of evidence.[60]
Dr Mark Prunty, Senior Medical Officer for Substance
Misuse Policy, Department of Health, added:
It is true that the number of studies has increased
and multiplied. There have been major reviews which have looked
at the methodology underpinning those studies and questioned their
robustness. [...] There is still evidence of the health benefits,
particularly for coronary heart disease, but it is certainly true
that the concerns about how robust the methodology is and whether
there are other confounding factors has strengthened considerably,
particularly in the last five to 10 years.
There has also been increasing consensus that
many of those benefits are likely to be achieved by other methods
as well, such as diet and exercise. Certainly, the British Heart
Foundation has come to the conclusion that equal or greater benefit
may be accrued by diet and exercise, to which the 1995 report
did refer.[61]
25. There is a lack of consensus amongst experts
over the health benefits of alcohol, but it is not clear from
the current evidence base how the benefits of drinking alcohol
at low quantities compare to those of lifelong abstention. In
addition, it seems likely that the same purported health benefits
could be gained through a healthy lifestyle. Therefore we are
sceptical about using the alleged health benefits of alcohol as
a basis for daily alcohol guidelines for the general adult population,
particularly as these benefits would apply only to men over 40
years and post-menopausal women and the guidelines are aimed at
all adults.
Older people
26. As mentioned above, the CHD benefits of alcohol
would be predominantly applicable to men over 40 years and post-menopausal
women. In June 2011, the Royal College of Psychiatrists published
a report on alcohol related harm in the elderly. The report concluded
that "because of physiological and metabolic changes associated
with ageing, these [Department of Health] 'safe limits' are too
high for older people; recent evidence suggests that the upper
'safe limit' for older people is 1.5 units per day or 11 units
per week".[62] The
Institute of Alcohol Studies was critical of the report[63]
and the Royal College of Physicians stated:
there is no arbitrary age when drinking patterns
should be advised to change. Individual factors also contribute
to the risks of alcohol consumption, including factors such as
medication use, co-morbidity and frailty, as well as the physiological
changes associated with ageing.
Recommended limits for safe drinking by older
people in the UK require further consideration, especially considering
the ageing UK population alongside changing drinking patterns,
which are expected to increase alcohol-related morbidity and mortality.[64]
27. The International Scientific Forum on Alcohol
Research and Alcohol in Moderation considered that despite suggestions
that older people should drink below daily guidelines, "moderate,
regular consumption within the guidelines helps protect against
cardiovascular disease, cognitive decline and all cause mortality,
especially among post menopausal women and men over 40".[65]
Sir Ian Gilmore, Royal College of Physicians, considered there
was a rationale for setting lower limits for older people, based
on their "propensity to fall" as well as the prevalence
of other diseases.[66]
However, he brought the question back to the issue of complexity:
If you start saying that it should be different
for men and women, different for people under 65 and over, different
for pregnant and not pregnant women, and different for under age
and over 18, you run the risk of getting to a level of complexity
that will not be understood by the public.[67]
28. As the Government provides guidelines for
specific population groups such as children and pregnant women
already, we consider that there could be merit in producing guidelines
for older people, balancing evidence of beneficial effects of
alcohol with evidence of increased risks. We deal with the
issues of guideline complexity further in the next chapter.
Women and alcohol
LOWER GUIDELINES
29. The 1995 report Sensible Drinking recognised
the difficulties of providing guidelines for women and alcohol,
stating that "the problems of giving accurate advice and
information about sensible drinking are nowhere more evident than
in this area", explaining that while the broad spectrum of
alcohol-related disease and social problems was similar for both
sexes, there was a "less secure scientific literature from
which to make conclusions about women as compared with men".[68]
The report considered physiological differences between
men and women and health risks to women such as coronary heart
disease, breast cancer and liver disease. The tendency for women
to drink less than men at that time was also considered. The report
stated that there was, in particular, "very little data linking
high levels of consumption in women with a variety of alcohol
related diseases".[69]
The conclusion was that it was not possible to produce an authoritative
statement about women and alcohol as the scientific evidence did
not allow that clarity. However, the report stated there was "sufficient
indication from the physiology and the patterns of illness for
women overall to be advised to drink at lower levels than men".[70]
30. We were interested in exploring whether the basis
for the guidelines for women were still considered to be scientifically
sound, 16 years after the Sensible Drinking report was
published. Dr Marsha Morgan explained that:
women have less body water [than men]. [...]
the difference in how the body is made up between fat and water
means that, if a woman of 70 kg drinks a double gin, a man of
70 kg would have to drink a triple gin to match her blood alcohol
level. Her blood alcohol tends to be about a third higher on a
weight-for-weight basis. The tissue dose of alcohol that she receives
is clearly higher. Overall, the propensity for her to develop
harm therefore kicks in earlier, after seemingly less alcohol.
That is beautifully demonstrated in studies of the 1970s from
Germany, where they looked at the risk of developing cirrhosis
of the liver, which kicked in at as low as 20 grams of alcohol
per day for women and at about 40 or 50 grams for men. There is
a physiological basis to it, and there is epidemiological evidence
showing that the risk of harm is higher. That was very much behind
the 21:14 differential [...] decided on in 1987. [...] There is
a physiological basis for assuming that women are at a different
risk, and there is epidemiological evidence that clearly shows
that that is the case.[71]
Aside from a minority, such as the Association of
Small Direct Wine Merchants, who stated that "suggesting
2-3 units of alcohol a day for women or 3-4 alcohol units a day
for men without reference to body size [...] is akin to having
driving speed limits of 20-30 MPH for women or 30-40 MPH for men",[72]
most of the written submissions we received did not challenge
the advice that women should be advised to drink less than men,
based on health risks. In fact, it appeared that even more evidence
had emerged to support this since 1995. For example, Dr Morgan
explained that "since the guidelines were last considered
in 1995, [...] the major body of evidence has been on the detrimental
effect of alcohol and the cancer risk, particularly for breast
cancer in women".[73]
However, Dr Harding suggested that as women "are exposed
to the risk of cardio-vascular diseases" after the menopause,
"the benefit that they gain from moderate consumption after
the menopause would outweigh any increased risk of cancer".[74]
31. The issue of whether alcohol confers health benefits
has already been discussed in paragraph 19. We are content
that there is sufficient physiological and epidemiological evidence
on health risks to support the retention of lower drinking guidelines
for women in general.
DRINKING DURING PREGNANCY
32. The Sensible Drinking report's advice
on alcohol and pregnancy was that "to minimise risk to the
developing foetus, women who are trying to become pregnant or
are at any stage of pregnancy, should not drink more than 1 or
2 units of alcohol once or twice a week, and should avoid episodes
of intoxication".[75]
In 2006, the UK Chief Medical Officers published revised guidelines
taking into account a report commissioned by the Department of
Health on the fetal effects of prenatal exposure.[76]
The UK Chief Medical Officers advised that "pregnant women
or women trying to conceive should avoid drinking alcohol; if
they do choose to drink, to minimise the risk to the baby, they
should not drink more than one to two units of alcohol once or
twice a week and should not get drunk".[77]
In England, this was followed by guidance from the National Institute
for Health and Clinical Excellence (NICE) in 2007, who advised
that the risks of miscarriage in the first three months of pregnancy
mean that it is particularly important for a woman not to drink
alcohol at all during that period.[78]
A slight divergence of advice occurs in Scotland, where the Scottish
Chief Medical Officer's current advice on alcohol and pregnancy
is that "there is no 'safe' time for drinking alcohol during
pregnancy and there is no 'safe' amount".[79]
33. It is generally accepted that high alcohol consumption
levels can be harmful during pregnancy.[80]
However, the expert views we received suggested that no "safe
limit" of alcohol consumption had been identified and that
a great deal of uncertainty remains.[81]
This scientific uncertainty can be used to produce contrasting
but equally probable statements: (i) there is no evidence for
a level of risk-free drinking during pregnancy;[82]
and (ii) drinking one to two units once or twice a week has not
been shown to be harmful.[83]
Faced with this uncertainty, the development of policy and provision
of definitive advice is difficult[84]
and a precautionary approach is clearly attractive to health advice
providers. For example, the Royal College of Obstetricians and
Gynaecologists highlighted that the positions of its counterparts
in the USA, Canada, Australia and New Zealand were, based on factors
such as insufficient evidence and a lack of consensus, to encourage
abstinence during pregnancy.[85]
The UK's Chief Medical Officers (CMOs) reviewed the guidelines
for drinking during pregnancy in 2006 and produced updated guidelines
that encouraged abstinence but also provided advice for women
who chose to drink. We are satisfied that the CMOs have recently
reviewed the evidence base and consider that the current guidance
adequately balances the scientific uncertainty with a precautionary
approach. However, we note that the Scottish CMO has adopted different
advice. Consistency of advice across the UK would be desirable.
Sources of scientific advice
34. Sources of scientific advice to Government on
alcohol guidelines include the Chief Medical Officers and NICE.
We asked Sir Ian Gilmore whether the Government used advice from
a wide enough range of sources, and he responded:
They do not use a sufficient evidence base when
it comes to developing alcohol policy. That evidence base can
come from a wide range of sources, whether it is social sciences,
clinical sciences or basic sciences. The problem that I have is
that the evidence is out there on what will reduce alcohol-related
harm, but it is true that we need to persuade the Government to
use that evidence.[86]
The Minister told us that the Department of Health
monitors the evidence base "in a variety of ways", both
by using its own internal experts and commissioning external advice
and support from various bodies.[87]
Chris Heffer, Deputy Director, Alcohol and Drugs, Department of
Health, described some of the "bespoke" research that
had been commissioned by the Department in recent years, including
on pricing, licensing and other alcohol policies. However, he
noted that "we have not, to my knowledge, done specific research
on the guidelines of particular health risks".[88]
35. The Institute of Alcohol Studies suggested that
the Government establish a working group, "with representation
of health experts, to regularly review the evidence base and provide
scientific advice for public health messaging on alcohol".[89]
Dr Harding said that although all of the relevant information
is published in the literature, "what is needed is a mechanism
that brings it all together in a fair and balanced way, so that
sensible public health messages can be crafted".[90]
He suggested that a review of the relationship between alcohol
consumption and disease was "overdue" and recommended
the establishment of "a multidisciplinary team, involving
experts in the appropriate fields [for example] alcohol misuse,
epidemiology, public health, heart disease, dementia, and social
science, who are knowledgeable about the current scientific data
and who are capable of taking a broad overview".[91]
The Department of Health stated that it was "not currently
planning a formal review of the guidelines, but would be willing
to consider this if it were felt to be useful".[92]
36. When we announced our inquiry into alcohol guidelines
in July 2011, there was some media speculation about the possibility
of increasing the guideline limits. This appeared to be based
on international comparisons with countries that set higher drinking
limits in public guidelines as well as the claim that the Royal
College of Physicians' 1987 guidelines were "plucked out
of the air".[93]
However, none of our expert witnesses recommended an increase,
and several were in fact adamant that the guidelines should not
be increased.[94] Dr Richard
Harding also cautioned against relying on international comparisons.[95]
When we asked the Minister whether the guidelines should be lowered,
she responded: "I do not believe that there is currently
any evidence available that would suggest that we ought to alter
those guidelines".[96]
37. We have heard sufficient concerns from experts
to suggest that a thorough review of the evidence on alcohol and
health risks is due. The Department of Health and the devolved
health departments should establish a nationwide working group
to review the evidence base and use the findings of the review
to provide advice on whether the guidelines should be changed.
In the meantime, we consider that there does not appear to be
sufficient evidence to justify increasing the current drinking
guidelines.
29 Department of Health, Sensible Drinking: Report
of an inter-departmental working group, 1 December 1995 Back
30
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
31
Ev 27, paras 1-2 Back
32
Ev 27 [Department of Health] para 1; The Royal College
of General Practitioners, Alcohol: a balanced view , 1987;
The Royal College of Psychiatrists, Alcohol: our favourite
drug, 1986; and The Royal College of Physicians,
A Great and Growing Evil: the medical consequences of alcohol
abuse, 1987 Back
33
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, Annex E Back
34
Ev 48 [Dr Richard Harding] para 26 Back
35
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
36
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
37
Ev 74 [Institute of Alcohol Studies] para 1 Back
38
Ev w32 [Grampian Alcohol and Drugs Partnerships] para 3.1.2 Back
39
Q 10 Back
40
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, para 5.5 Back
41
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, para 5.5 Back
42
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, para 5.7 Back
43
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
44
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, paras 5.8-5.9 Back
45
Ev w10, para 1.7 Back
46
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, para 5.11 Back
47
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, para 5.20 Back
48
Ev w9 [International Scientific Forum on Alcohol Research and
Alcohol in Moderation] Back
49
Ev w10, para 1.3 Back
50
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
51
Q 8 Back
52
Q 9 Back
53
Q 10 Back
54
Q 10 Back
55
Q 8 Back
56
Q 8 Back
57
Q 9 Back
58
Ev 37 [Alcohol Research UK] paras 2.8.1-2.8.4 Back
59
Ev 28, para 15 Back
60
Q 94 Back
61
Q 95 Back
62
Ev w43, para 6 Back
63
Ev 79, Attachment 4 Back
64
Ev 73, paras 41-42 Back
65
Ev w12, para 1.20 Back
66
Q 23 Back
67
Q 23 Back
68
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
69
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
70
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995, para 8.7 Back
71
Q 22 Back
72
Ev w4, para 3.3 Back
73
Q 10 Back
74
Q 10 Back
75
Department of Health, Sensible Drinking: Report of an inter-departmental
working group, 1 December 1995 Back
76
Gray, R. and Henderson J., "Report to the Department of Health:
Review of the fetal effects of prenatal alcohol exposure",
May, 2006 Back
77
Ev 27, para 6 Back
78
Ev 27, para 6 Back
79
Ev 27, para 7 Back
80
Royal College of Obstetricians and Gynaecologists, Alcohol
consumption and the outcomes of pregnancy, March 2006 Back
81
Royal College of Obstetricians and Gynaecologists, Alcohol
consumption and the outcomes of pregnancy, March 2006 Back
82
Ev 77 [Institute of Alcohol Studies] para 4 Back
83
Ev w38 [Royal College of Obstetricians and Gynaecologists] paras
1.2-1.3 Back
84
Ev 36 [Alcohol Research UK] para 2.6.1 Back
85
Ev w39 [Royal College of Obstetricians and Gynaecologists] para
1.5 Back
86
Q 27 Back
87
Q 65 Back
88
Q 66 Back
89
Ev 74, para 2 Back
90
Ev 49, para 31 Back
91
Ev 49, para 32 Back
92
Ev 29, para 19 Back
93
"Healthy alcohol limits likely to be increased", The
Independent, 25 July 2011; "Cheers... An extra glass
of wine is fine as the daily allowance could be raised",
The Daily Mail, 26 July 2011. Back
94
Q 11 [Professor Nick Heather; Sir Ian Gilmore] Back
95
Q 11 Back
96
Q 100 Back
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