Food and Drugs Act

Honourable senators, I’m going to rise and speak to Bill S-202, an Act to amend the Food and Drugs Act (warning label on alcoholic beverages).

I rise today to speak as the critic of this bill, and I want to thank Senator Brazeau for his diligent work on this issue and for his efforts to ensure that Canadians have current and accurate health information relating to alcohol consumption.

As indicated in the title, Bill S-202 will amend the Food and Drugs Act to require that a warning label be placed on alcoholic beverages. Let me say at the outset that I support the objective of this legislation completely, which is laid out clearly in the three statements found in the preamble of the bill.

Parliament recognizes there’s a direct causal link between alcohol consumption and the development of cancers. On this point, colleagues, there is really no debate. Although public awareness of this fact remains low, it is not a new discovery. It has been 38 years since the International Agency for Research on Cancer identified alcohol as a Group 1 carcinogen in 1987, placing it in the same category as tobacco and asbestos. This classification was based on strong evidence linking alcohol use to several types of cancer, which now include breast, liver, oral cavity, throat and larynx cancers.

In 2000, the U.S. National Toxicology Program listed consumption of alcoholic beverages as a known human carcinogen in the ninth edition of its Report on Carcinogens.

In January of this year, the United States Surgeon General released an advisory titled Alcohol and Cancer Risk, which noted that alcohol use is “. . . a leading preventable cause of cancer . . . .”

The preponderance of the scientific evidence supports the first statement of the bill’s preamble, “. . . that a direct causal link exists between alcohol consumption and the development of fatal cancers.”

Public awareness of the health risks associated with alcohol consumption, particularly its link to cancer, remains alarmingly low despite the scientific consensus. This lack of awareness is not unique to Canada. A World Health Organization report found that only 15% of Europeans knew alcohol causes breast cancer, despite breast cancer being one of the most prevalent alcohol-related cancers.

Bill S-202 proposes that the knowledge gap be addressed by mandating specific labelling requirements for alcohol products. At last count, there were at least 47 countries around the world that have already implemented health warning labels on alcohol products. However, only South Korea’s labels currently warn of the risk of cancer.

Unlike nutritional labels or tobacco warnings, alcohol products in Canada are not required to display any health warnings, but effectively implementing such a measure is not without its challenges. Cancer Care Ontario noted this in its 2014 publication Cancer Risk Factors in Ontario, where it stated the following:

While alcohol is a risk factor for cancer when consumed in any quantity, light to moderate levels of consumption can protect against cardiovascular disease. This poses unique challenges for increasing awareness of the link between alcohol consumption and cancer.

This supposed contradiction in the health outcomes of alcohol consumption makes the discussion much different than the one surrounding the use of tobacco, for instance. This focus is not a prohibition approach but a question of how much alcohol can be safely consumed. Bill S-202 wisely leaves these details up to the Department of Health to determine.

But our awareness of this challenge is important because despite the growing popularity of alcohol warning labels, the evidence on the effectiveness of warning labels has always been mixed. A recent study titled “Alcohol Health Warning Labels: A Rapid Review with Action Recommendations” was published in 2022 in the International Journal of Environmental Research and Public Health. What their findings suggest is that simply affixing a label to alcohol containers is not, in itself, an effective strategy. There is a broad range of factors that must be considered when evaluating or designing alcohol warning labels.

Bill S-202 proposes four required components for alcohol warning labels, but there are many other possible inclusions. For example, what about warnings concerning the risks to pregnant women or the dangers of impairment, high blood pressure, liver and heart disease, or even the addictive potential of alcohol itself? Each of these is a valid focus, and all are significant public health concerns.

The evidence shows that labels don’t always produce the expected results. For instance, negatively worded messages had the strongest effect on heavier drinkers. Among younger drinkers, however, prominent warnings could create a boomerang effect, actually enhancing the product’s appeal, enabling a person to get intoxicated quickly and cheaply.

This, of course, will always be a danger and a problem with any labelling on any alcoholic product. This challenge was captured in the findings of a 2023 study published in the Journal of Addictive Diseases entitled “A systematic review on the impact of alcohol warning labels.” The abstract of the article begins with the following admission:

Findings on the effects of alcohol warning labels (AWLs) as a harm reduction tool have been mixed. . . .

But it ends with this statement:

AWLs appear to be a promising approach for supporting more informed alcohol consumption and should be considered as one component in a comprehensive control strategy.

I believe Senator Brazeau’s bill represents not just an opportunity to examine the matter carefully but a responsibility for us to do so. For this reason, I support the bill in principle and will be voting in favour of sending it to committee for a thorough examination.