Comment-11080-Casey Miles
Sir/Ma'am-
I feel that Prop. 65: Modifying a Listing: Alcoholic Beverages is a mistake. The damage it will cause to a 95Bil industry in America (CA is 51% of that market) in lower taxes, decreased revenues for bars and restaurants, decreased jobs in the state, reducing opportunities for production and wholesale, and in general economic depression in a large California market effecting small business owners to large brands alike is not justified by the study referenced.
Study:IARC Monographs on the Evaluation of Carcinogenic Risks to Humans VOLUME 96 Alcohol Consumption and Ethyl Carbamate.
The problems with this study are evident:
1. Epidemiological studies are not a study in causality. This should be known throughout the scientific community. If pool drownings increase when a new Transformers movie comes out, it does not mean one caused the other. There is no proof of causality in the study.
2. The cohort studies were self-reporting. As outlined on page 172 & 173. The study also mentioned all of the problems with self-reporting: difficulty recalling information, adjusting to the interviewer's questions, etc...
3. The report itself shows that alcohol consumption reduces kidney cancer risks and all but 2 types of cancer were inconclusive. Only breast cancer and colon cancer showed a minimal increase in risk factor. The range given was a relative risk factor of 1.3 to 1.6 with a 95% confidence interval. 1.1 is considered no difference in these kinds of studies and not worth even reporting. If the confidence interval was opened to 98%, it would be from 1.1 to 1.8. This would include a large portion of statistically insignificant data. Even at 1.3, you're not 15 to 30 times more likely to get cancer like smoking tobacco. You're not even 5 times more likely, or even 2 times more likely. At 1.3 you're about 0.8% times more likely. This is insignificant when you consider that these studies were based on regressive, self-reporting data. 1.3 is lost in the margin of error and not significant.
These are glaring problems:
1. Epidemiological studies do not show causality
2. The data about alcohol consumption was self-reporting (many people lie about alcohol consumption)
3. The increased risk is insignificant
4. The confidence interval is too low due to a tight relative risk range. However, if the range was widened, the study would be deemed insignificant because to be 98% sure that reality lands in the range, the range would have to be opened to include no significant difference. This shows bias.
5. Alcohol consumption decreases the risk of liver and kidney cancer and might reduce the risk of stomach and throat cancer (results were inconsistent with the hypothesis = numbers shows decreased risk)
6. Colon cancer is a function of how long you live. Everyone will get colon cancer if they live long enough. Basing this regulation on a statistically insignificant increased risk factor to a cancer that 100% of everyone will get is dishonest.
7. The study does not backup the argument that beverage alcohol causes cancer. This is why nobody has touched it in almost 10 years. It just doesn't prove that. If that is the goal, then a randomized control test should be used. The test should be proactive, not retroactive. The data is bad (self-reporting), the test was lazy (retro vs proactive), and the type of test was wrong (Epidemiological).
Please consider these arguments. What I am telling you is factual. What you're doing is dishonest. Do not believe a bunch of bias scientists trying to prove a hypothesis with retroactive data from poor sources. They are trying to pull the wool over your eyes.
Consider the damage this will do to the very young and fragile craft spirits industry in America. What you are proposing is protectionist laws that are being lobbied for by foreign interest. There is a deal of shame involved with promoting protectionist laws. American made wine has build a huge industry across our great nation. It has increased tourism, local economies, and provided jobs for craftsmen. Craft beer has done the same. Please consider the damage this could do to American small business. Please consider that the study you are reading is inconclusive on a subject people have been studying for decades. This should be a clear sign that ethanol is not bad for you. If you haven't proved it in 100 years of trying, then accept that something that makes you feel good can also be good for you. Throw off the puritan chains. Look away from foreign protectionist laws. Stand up for Californians and DO NOT MAKE THIS AMENDMENT. It is a mistake. I promise you. It's dishonest and it will hurt California.
Link to the study that this proposed amendment is based on (read it for yourself): https://monographs.iarc.fr/wp-content/uploads/2018/06/mono96.pdf
Understand that relative risk factor is the percentage of people in group B who got cancer divided by the percentage of people in group A that got cancer. If they are the same, then the relative risk factor = 1. We are talking about a relative risk factor that the study is 95% sure will fall somewhere between 1.3 and 1.6. Even if it did, it is insignificant. They did not increase the confidence factor to 98% because you would have had to open the relative risk factor to 1.1 to 1.8. Keep in mind 1= no difference. The study is bias, dishonest, retroactive, epidemiological, and made up of self-reported data about alcohol consumption! When was the last time you told your doctor the truth about how much you drink? It's the wrong kind of study to prove causality in the first place! Nobody has taken it seriously. Not even England, the EU, Scandinavian countries: nobody. Don't make California the laughing stock because we don't know how to read relative risk and confidence intervals.