Letter to the editor: IARD responds to Lim et al.’s (2019) analysis of framing and completeness of information disseminated by alcohol industry-funded organizations

On 14 June 2020 the Journal of Studies on Alcohol and Drugs published a letter which IARD submitted on 16 January 2020 in response to the publication: 
Lim, A. W. Y., van Schalkwyk, M. C. I., Maani Hessari, N., & Petticrew, M. P. (2019). Pregnancy, fertility, breastfeeding, and alcohol consumption: An analysis of framing and completeness of information disseminated by alcohol industry–funded organizations. Journal of Studies on Alcohol and Drugs, 80, 524–533. doi:10.15288/jsad.2019.80.524

In the same journal issue, the authors of the original publication responded to IARD's letter and those submitted by other organizations.

The text of IARD's letter follows:
Dear Editor:

The recent publication of the Lim et al. (2019) article in the Journal of Studies on Alcohol and Drugs makes misleading statements about the content of the International Alliance for Responsible Drinking’s (IARD’s) materials related to alcohol and pregnancy.

We wish to identify and address several statements made in the article.

1. IARD maintains on its website a set of alcohol-related policy tables ( that include national drinking guidelines (general population), national drinking guidelines for pregnancy and breastfeeding, minimum legal age limits, minimum legal blood alcohol concentration limits, and health warning and other labeling requirements for all countries where IARD has been able to verify the information with the respective national authorities. The purpose of these tables is to provide a source of alcohol-related national guidelines and requirements in one place. The World Health Organization (WHO) provides a table of similar information on its Global Information System on Alcohol and Health (WHO, 2018).

Lim et al. (2019) provide no justification or support for their assertion that IARD’s tables are “emphasizing uncertainty,” given that they reproduce government-published information from all countries where such information is available. The authors criticize the drinking guidelines for pregnancy and breastfeeding table ( for not including “accompanying text.” However, Lim et al. (2019) do not specify why this is warranted or what text is appropriate in a table providing objective information about existing government guidelines.

2a. Lim et al. (2019) claim that IARD and other organizations attempt to frame “[light] drinking, drinking within the guidelines, and abstention as equivalent options” and cite a selective quotation from the IARD fetal alcohol syndrome disorder (FASD) review. The full text is below, and the second sentence (bolded) clearly states that abstinence is the government recommendation for drinking during pregnancy. Abstinence is not equivalent to light or moderate consumption.

The full quotation reads:

“There is no conclusive evidence of a link between occasional, light, or even moderate drinking during pregnancy and an increased risk for FASD [9, 10]. However, as the threshold of maternal consumption at which risk increases has not been defined, government and other recommendations around drinking during pregnancy generally point to abstinence to avoid adverse effects on the developing fetus (see IARD Policy Table Drinking Guidelines: Pregnancy and Breastfeeding for more information).”

2b. Lim et al. (2019) further state that IARD is “focusing discussion away from alcohol to other risk factors” by “mix[ing] factual statements with extended discussion of methodological and other uncertainties.”

IARD’s April 2016 FASD review is a fully referenced review of published research focusing on the relationship between alcohol consumption and FASD. It is an accurate statement of fact that studies have reported evidence that certain factors modify the risk relationship between alcohol consumption and FASD (Esper & Furtado, 2014May & Gossage, 2011). These factors are important for understanding the etiology of FASD and how to prevent it. Since the review is a paper summarizing the research on this topic, it is appropriate to discuss known effect modifiers.

3. In the discussion section of their article, the authors say that IARD “seems to place significant emphasis on women in ‘less stable domestic partnerships’ and ‘women with low socioeconomic status and education level.’” There is only one mention of these subpopulations in the 12-page IARD review. The relevant section also includes mentions of age, parity, maternal nutritional status, body mass index, alcohol metabolism, drinking alone, and family history of alcohol abuse.

Further, there is no basis for Lim et al.’s statement that IARD’s review “may be intended to make the [abstinence during pregnancy] message appear less relevant to women of higher socioeconomic status, among whom FASD is less likely to be diagnosed and who are at the same time, because of their income, a valuable part of the alcohol market.” No basis for this inaccurate statement is offered by Lim et al.

4. Lim et al. (2019) fail to report or recognize the number of times that the IARD review describes the adverse outcomes associated with fetal alcohol exposure in the opening sentences of the review (five times on page 1) and repeatedly throughout the document.

5. Finally, Lim et al. (2019) state that, “Several alcohol industry–funded bodies introduce the idea of risk associated with different patterns of drinking, suggesting that some patterns are more harmful than others at different stages of the reproductive process.” It is a statement of fact that the risk of harmful pregnancy outcomes increases with amount or frequency of drinking alcohol.

Lim et al. (2019) fail to acknowledge that the content provided by the public health organizations cited as the comparison group to the content provided by industry-funded organizations also report this fact, including these two examples:

“How much you drink matters. The more you drink, the more likely it is that the baby will suffer some harm. The more alcohol and the more frequently alcohol is consumed during pregnancy, the higher the risk of FASD.” (Health Direct, 2018)

“[W]e don’t know how much alcohol it takes to cause harm. We do know that the risk of FASD, and the likely severity, goes up with the amount of alcohol consumed during pregnancy.” (Office on Women’s Health, 2019)

This letter attempts to address the most significant misstatements by Lim et al. (2019) of IARD’s FASD review and IARD’s policy table, and we hope that it will serve to correct their inaccurate portrayal of our work.

We invite readers to examine IARD’s materials, available on our website at, and draw their own conclusions.