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Last week, the U.S. Surgeon General issued an advisory entitled “Alcohol and Cancer Risk 2025” which garnered a significant amount of media attention since it concludes that the consumption of alcohol is so risky that all alcohol sold in the U.S. should contain warning labels to alert consumers about the cancer risks caused by alcohol consumption. It includes some worrying statements such as that the risks of alcohol related cancer “may start to increase around one or fewer drinks per day”.

In many places, it emphasizes the risks related to low levels of consumption including by stating that “17% of the estimated 20,000 U.S. alcohol-related cancer deaths per year occur at [consumption] levels” within the U.S. recommended drinking guidelines of 2 drinks per day for men and 1 drink per day for women. It also asserts that the majority of the public is uninformed about the extent of such risks.

The end of the advisory concludes with a call to action for “reducing alcohol-related cancers in the U.S.” that includes a reassessment of recommended consumption levels as well as advocating for the inclusion of warning labels “about the risk of cancer associated with alcohol consumption”. Here is an excerpt:

I am not convinced that this advisory is correct or that it even provides useful information for the general public. Here’s why I think that.

A major part of the advisory, and one that is of interest to the public, is an explanation of the risks related to alcohol consumption … and specifically how those translate into the likelihood of poor health. While there is some reference in the advisory’s discussion to other sources, the most “hard-hitting” part of it (and the easiest to understand) is an infographic (shown below, from p.13 of the advisory) which concludes that more alcohol consumption (even at relatively low levels) increases the risk of cancer in both men and women. 

It states that the lifetime risk (up to age 80) of being diagnosed with an alcohol-related cancer is 16.5% for women and 10% for men if they drink less than 1 drink per week (i.e. this is the chance of getting one of these types of cancer even if you drink basically nothing). It then asserts that these risks increase to 19% for women and 11.4% for men at a consumption level of 7 drinks per week (the current U.S. recommended level for women). The risk further increases to 21.8% for women and 13.1% for men at a consumption level of 14 drinks per week (the current U.S. recommended level for men). 

The infographic further explains that these increases in risk would translate to “about 5 more women out of 100” and “about 3 more men out of 100” developing alcohol related cancer (up to age 80) if they consumed two drinks per day (i.e. about a 5% increase for women and 3% increase for men in absolute risk). 

All of these infographic explanations of risk are based on a single study from Australia that was published in 2021. Here is the link to the study if you are interested. After reading through the study, I am having considerable difficulty in understanding both how the Surgeon General came to the conclusions that he did … and how the conclusions regarding risk were generated. 

The authors of the study generated conclusions of risk related to alcohol consumption that are similar to the ones contained in the advisory. These are tabulated by age and gender and by alcohol consumption groups (see excerpt from table below which highlights the important parts, the complete Table 3 can be reviewed as part of the supplementary material to the study which can be found at the link above.

If one reviews the actual assessments of risk calculated in the study up to age 80 (table 3 above – in red), one can see that the study determined the following:

• The lifetime risk for alcohol related cancer for those in the group who drink less than 1 drink per week (i.e. almost nothing) is 9.96% for men and 16.53% for women. These numbers are the same as those in the advisory infographic (above) and indicate the chance of being diagnosed with an alcohol related cancer even if you drink next to nothing. 

• The lifetime risk for alcohol related cancer for those in the group who drink amounts between 1 and 14 drinks per week (median/average of 6 drinks for men and 5 for women) is 10.86% for men and 17.6% for women. This is an increase of about 1% in the absolute risk to the first set of numbers (i.e. little difference in risk to drinking almost nothing). The advisory infographic provides a different set of higher risk numbers (11.4% and 19%) for consumption at 7 drinks per week which it is claimed is based on the same data.

• The real problem lies in the final set of numbers. Here the lifetime risk for alcohol related cancer for those in the group who drink more than 14 drinks per week is calculated for everyone in that group who declared above this consumption level and for all greater consumption amounts (some of whom would be heavy drinkers … the median/average consumption in this group was 21 drinks per week for men and 20 drinks per week for women – see red text above). The lifetime risk to age 80 for this group is stated as 13.46% for men and 21.17% for women. These risk percentages are almost the same as those quoted in the advisory infographic (13.1% and 21.8%) for a consumption level of 14 drinks per week. This makes no sense. How can the analysis from the actual study indicate a risk level for a group with a median consumption of 20-21 drinks per week that is quoted by the advisory as being essentially the same as one for 14 drinks per week. One set of numbers appears to be incorrect … and that is more likely to be those in the advisory infographic.

This is potentially serious because the infographic is claiming a particular level of increased risk at 14 drinks per week (which are the current U.S. drinking guidelines for men) which does not appear to be justified by the study upon which it relies. According to the study, that same level of increased risk is not reached until (on average) men drink 50% more than the guidelines and women drink 185% more than the guidelines.  

As such, I question the propriety of the conclusions in the advisory. In addition, and since the advisory relies so much on the Australian study, it is worth noting the following:

• The study group consisted of individuals over 45 years of age. Persons living in rural and remote areas were over-represented in the group. These factors raise questions related to the transferability of the conclusions to other demographic groups in other places such as the U.S. The authors note that the study’s conclusions regarding risk are higher than other studies, particularly a British one.
• Vital information related to lifestyle and alcohol consumption was obtained from the group by self-reporting via postal questionnaires. This raises questions about the accuracy of the data including the likelihood of under-reporting of alcohol consumption.
• The authors of the study note that 2.8% of cancer cases in Australia are attributed to alcohol consumption. Conversely, this means that 97.2% of cases are NOT attributable to alcohol.
• The authors note many limitations of the study including the possibility of under-reporting of consumption by participants and an inability to fully track consumption patterns or alcohol types.

In summary, I have the following questions about this advisory that raise issues about its utility: 

• Why is the Surgeon General using a single Australian study to provide risk justifications for alcohol policy interventions at the federal level for all of the United States? This particular study may not be applicable to the U.S. and/or could later be proved to be inaccurate.
• Policy decisions that are based on science should have broad scientific support. In contrast, the recent National Academies Review of Evidence on Alcohol and Health came to dramatically different (basically opposite) conclusions regarding moderate consumption and appears to be broader based.
• Why is the Surgeon General’s advisory using risk calculations that do not seem to be supported by the actual data in the study that it is relying upon?
• Why is the Surgeon General’s advisory narrowly focused on the health risks related to alcohol and cancer, particularly when the vast majority of cancer cases (97% according to the Australian study) are not attributable to alcohol consumption? Should the Surgeon General more properly be taking a broader look at alcohol and health … as the National Academies Review did?
• Why would relatively small increases in risk justify a conclusion that alcohol “causes” cancer (a more accurate statement might be that “alcohol can contribute to the development of cancer” at specified consumption levels)? Why would this lead to calls to reassess the existing drinking guidelines? And why would this lead to advocacy for warning labels that could be very misleading in respect of the actual risks involved?

Note: my discussions of risk above refer to absolute risk which is the primary discussion in both the advisory and the study … and, in my view, the most transparent way to discuss risks relating to health. I do not refer to relative risk (i.e. the % difference between two levels of absolute risk) because I think that is often misleading, particularly in situations where the absolute risk is small.

There continues to be a great deal of media coverage of anti-alcohol advocates who claim that there is “no safe level” of alcohol consumption. This series of blog posts provides 3 reasons why I will continue to ignore these assertions.

Reason #3 – Individuals Should Make Their Own Choices

The third reason that I am not paying much attention to anti-alcohol advocates is that their conclusions and recommendations are wholly incompatible with the notion that individuals are likely to have both different health outcomes from similar behaviours and different risk tolerances. The conclusion that there is “no safe level” of alcohol consumption is a prime example of this. 

Individuals have vastly different health histories, genetic predispositions to illness, diets and lifestyles. Even if it were true that there is an increased average health risk across a population related to a certain level of alcohol consumption, that does not mean that it is true that any one individual has the same level of risk. There could well be groups of individuals who have higher risks related to family health history, diet, exercise or susceptibility to problem consumption. It may well be appropriate to advise some of those individuals that the safest level of consumption for them is low or even none. But that does not mean that other individuals have the same risk factors. Someone who drinks moderately, who is fit, who has no problematic health history, and who eats well may have little to no risk from the same level of consumption. For that individual the blanket recommendation of “no safe level” is completely wrong. 

Any set of recommendations (and particularly the blanket “no safe level” statement) is simply not accurate on an individual level unless it takes into account all of the unique personal factors that apply to that individual. As such, public health guidance that creates blanket recommendations is inappropriate and bordering on the reckless. Unfortunately, I suspect that such guidance is being created to deliberately “scare” people into reducing consumption, even when there is no scientific basis to do so.

In a similar vein, individuals will likely have very different levels of risk acceptance when it comes to health and alcohol consumption, particularly when the absolute risk related to certain health outcomes is very small. This applies to all aspects of life including driving, playing sports and engaging in other lifestyle choices. Some people are risk adverse when it comes to health, others not so much. The anti-alcohol advocates assume in their calculations that almost any level of increased risk is unacceptable even if it is very minimal. They also mostly ignore the proven health benefits of certain levels of consumption on heart disease … and completely ignore the health benefits of consumption that is related to social interaction and community. 

It remains a fact (which is inconvenient to the anti-alcohol folks) that if you look at all-cause mortality … in other words, general life expectancy … that people who consume in moderation are on average, likely to live longer than those who abstain completely (as well as longer than heavy drinkers). Life insurance calculations do not penalize people who drink for a reason … there is simply no basis to conclude that moderate drinkers will have shorter lives. As a result, I will continue to drink wine in moderation, as I have for the past few decades and as civilized society has for thousands of years.

Reason #1 is here: Only Pay Attention to Good Science

Reason #2 – Don’t Listen to Biased Sources

There continues to be a great deal of media coverage of anti-alcohol advocates who claim that there is “no safe level” of alcohol consumption. This series of blog posts provides 3 reasons why I will continue to ignore these assertions.

Reason #2 – Don’t Listen to Biased Sources

The second reason that I am not paying much attention to the anti-alcohol advocates is that I generally only give credence to scientists and other experts that I believe are looking at the issues with a proper unbiased perspective and who are neutral. In other words, I pay attention to who is making the claims and what their motivations might be. I need to trust the source. I think that much of the work coming from the anti-alcohol camp is not neutral science … rather it is advocacy cloaked in scientific language. Most of the anti-alcohol crowd derive from one of two camps: they are either public health professionals or are academics whose research interests are devoted to anti-alcohol work.

In terms of the public health group, I believe that for the most part, this group is well-intentioned but often becomes misguided. On many contemporary public policy issues, public health has focused their analysis far too narrowly, often using a metric of mortality reduction related to a single disease without considering the wider effects on society or even on properly targeting the actual problem. In addition, they have sometimes demonstrated a propensity to not provide the whole truth if they believe that a “white lie” will accomplish their policy objectives. The World Health Organization has become, sadly, a prime example of this.

The results can be problematic … as was demonstrated during Covid regarding the contradictory messaging regarding the effectiveness of masks.  In my home province of British Columbia, this approach also caused serious political repercussions when a “harm reduction” policy of drug decriminalization was accepted at the behest of public health. This resulted in rampant social disorder, out-of-control public drug use and continued increases in overdose deaths. The province had to reverse the policy to stem the damage.

Many of these same experts have also advocated for various anti-alcohol policies such as hefty tax increases and sales restrictions, arguing that an overall reduction in alcohol consumption will reduce alcohol-related harms. That blunt and over-reaching approach rarely works as Scotland recently discovered when increases to its minimum alcohol pricing had little to no effect on problem drinkers (while increasing the costs for everyone else). See Minimum Pricing, Miserable Results.

The reality is that simple solutions to complex problems rarely work … and that if you want to actually reduce alcohol-related harms, you should target the people who are drinking too much … not those who are drinking wine in moderation with dinner.  

In terms of the other group of academics, I also don’t believe that most of them are truly neutral. Decades of scientific analysis has shown that moderate alcohol consumption is either fine or confers some small health benefits. Some recent studies have argued that the earlier work was wrong and that there is “no safe level” of alcohol consumption. However, the science behind such a change in conclusions is dubious at best and probably wrong. See Has the WHO lost its way regarding alcohol? 

Many of the proponents of these claims have built careers on anti-alcohol advocacy and are enjoying a moment in the sun, supported by unquestioning media. I believe that it is appropriate to question whether someone who gains all or nearly all of their income from anti-alcohol research is ideologically biased. Some of these folks also have long established connections and working relationships with avowed temperance organizations such as Movendi (formerly the International Order of Good Templars) which requires a lifetime pledge of abstinence to be a member. It’s a bit like asking your vegan cousin to organize the food choices for the family picnic … don’t be surprised when there are no meat options.

Reputable studies and institutions continue to publish studies that provide balanced analysis and continue to show certain benefits from moderate consumption. These are reviewed nicely in this excellent article by Dr. Laura Catena, a physician who is also a winemaker. There is also a good analysis by Dr. Ken Mukamal from Harvard here: Is Alcohol Good or Bad for You? Yes. As such, I recommend being careful who you listen to on these issues – and consider tuning out if you suspect that the “scientist” is someone who is motivated by anti-alcohol bias and/or is someone whose career has been defined by that type of work.

Who should you trust? An accomplished researcher from Harvard and an experienced physician? Or a social science professor with a long history of anti-alcohol work? I know who has my trust and confidence. As a result, I will continue to drink wine in moderation, as I have for the past few decades and as civilized society has for thousands of years.

Reason #1 is here: Only Pay Attention to Good Science

Reason #3 is here: Make Your Own Choices

There continues to be a great deal of media coverage of anti-alcohol advocates who claim that there is “no safe level” of alcohol consumption. This series of blog posts provides 3 reasons why I will continue to ignore these assertions.

Reason #1 – Only Pay Attention to Good Science

I studied the history and philosophy of science as an undergraduate. While I have great respect for scientists and their accomplishments over the centuries, I am also keenly aware of what can go wrong. Science often has an aura of both truth and infallibility, which is perpetuated by the media. In reality, science and its conclusions are only as good as the scientific method that is used for any particular analysis. Unfortunately, some science is either poorly done or extremely difficult to do … and the conclusions are often dubious or incorrect. 

The science behind the “no safe level” alcohol claims is part of a branch of science known as “nutritional epidemiology”. It is based on observations of the lifestyles and health of people which are almost always compiled from questionnaires (i.e. data which can be inherently unreliable due to inaccurate responses and/or bias). This branch of science has serious structural issues which should prevent sweeping conclusions or, at the very least, any conclusions should be subject to extensive caveats and warnings. 

John Ioannidis is a professor at Stanford University and an acknowledged expert on the validity of scientific studies and conclusions. In 2018, he wrote that “the emerging picture of nutritional epidemiology is difficult to reconcile with good scientific principles. The field needs radical reform.” There is a good analysis of the overarching problems in this book by Stuart Ritchie: Science Fictions: How Fraud, Bias, Negligence and Hype Undermine the Search for Truth (at p.164 onward). And there is more specific analysis regarding the “no safe level” claim in this fine article by David Morrison: Has the WHO lost its way regarding alcohol?  

For further background on the science related to alcohol and health, you might want to take a look at these recent books: The Very Good News About Wine by Tony Edwards and Wine & Health by Richard Baxter, MD.

At a most basic level, and after carefully looking at all the evidence, I do not believe that there is any reliable scientific evidence that the moderate consumption of alcohol poses any significant risk to most individuals … and I am strongly of the view that the “no safe level” conclusion has almost zero scientific merit. As such, I will continue to drink wine in moderation, as I have for the past few decades and as civilized society has for thousands of years.

Reason #2 – Don’t Listen to Biased Sources

Reason #3 is here: Make Your Own Choices

In mid-September, AIDV Canada will be holding a webinar that focuses on the regulatory and business processes related to importing grapes between BC and Washington state.

Speakers will discuss their experiences to date which can offer a roadmap for winery and vineyard operators and their advisors on both sides of the Canada-US border. Such a roadmap is not specific to Washington State and British Columbia, but rather can be adapted for future cross-border (bi-directional) sale of grapes or juice between North American wine regions.

Further information and registration information is here: AIDV September Webinar on Importing Grapes/Juice

The 2024 AIDV Canada wine law conference and annual general meeting will be held in Toronto on April 24th. There are options for in-person and virtual attendance. There is a great line-up of speakers covering essential topics such as interprovincial trade barriers, regulatory updates and the effects of Quebec’s language laws on labelling and marketing. If you are able to attend in-person, there will also be a lunch and wine tasting. Full details and registration information is here.

I have been involved professionally in the BC wine industry since 2008. Since that time, the industry has grown exponentially and has enjoyed considerable international recognition. While there have been some bumps and challenges along the way, the intervening years have generally been “golden” years of growth and expansion. Unfortunately, and mostly due to Mother Nature, the good times have come to an abrupt end. The industry is now in a state of crisis beyond anything that I could contemplate. I am gravely worried about the near future and almost as concerned about the longer term. Here’s why.

If you have not heard, the interior wine regions of BC experienced a deep freeze in December 2022. Generally, temperatures dropped below a danger zone for vines for about 42 hours. The resulting effect was primary bud loss of over 50% and vine death of about 30% for planted vineyards. This resulted in a dramatic reduction in the 2023 crop as well as a need to replant those affected vines that had died completely.  It generally takes 3 years for replanted vines to start producing in sufficient quantity and quality. 

On its own, this was a calamitous event as it seriously affects the economics of wine production. There will be a lag before the financial consequences kick in as it takes time between harvest (in the fall of a particular year) and the time when the wine is ready to be sold. This lag will vary between wineries and particular wine styles but is often about 1-2 years for white wines and 2-3 years for red wines. For example, as a result of the reduced 2023 crop, wineries could have about 50% less white wine to sell in 2024-2025 and 50% less red wine in 2025-2026. They would also have to pay for the unexpected cost of replanting vineyards which runs about $50,000 an acre … and wait for those new vines to start producing useable grapes.

Sadly, things have become much worse. In January 2024, another deep freeze hit which was worse than the first one (see this excellent presentation by Dr. Ben-Min Chang if you want the details). This time temperatures dropped further into the danger zone and for longer … for 57 hours. Initial assessments have catalogued primary bud loss at 90-100% with wide-ranging secondary and tertiary bud loss as well which will affect the next year. The extent of vine death is harder to measure until the weather gets warmer but it will be worse than the first freeze and could be extensive.  Cumulatively, this likely means the following:

• More than 50% crop loss for 2023 
• Close to 100% crop loss for 2024
• Additional significant crop loss for 2025 due to tertiary bud damage
• Additional significant crop losses for 2025-2027 due to vine death

It is hard to catalogue the extent of the consequences of the above for the wine industry and connected businesses, such as growers, workers, retailers and restaurants, but here are some possible effects assuming that no external assistance is available and that wineries do not take proactive remediation measures:

• Extreme contraction in availability of VQA and 100% BC wine during the affected years.
• Significant reduction in revenue for wineries and growers over the affected years.
• Significant losses on the financial statements of almost all wineries and growers – most would be deep in the red over the affected years.
• Layoffs and widespread cost-cutting.
• Many wineries going out of business and/or for sale.
• Inevitable loss of market share for BC wine to imports. 
• Further reduction in vineyard real estate values and winery business values. 

There will also be “knock-on” effects for others in the supply chain. For example, some retailers are either legally restricted to selling only BC wine or have chosen to do so. For those retailers, there will be much less wine to sell.  Many will be forced to start selling other wines if they are legally able to do so. Similarly, some restaurants have created wine lists that are predominantly BC. Again, they will be forced to re-think and to start selling other wines.

It is my view that only the most well-capitalized wineries would be able to survive this tumultuous period without taking drastic proactive measures. I just don’t see how most small to medium sized wineries can survive such significant losses of revenue over such a protracted length of time. I am aware that there are efforts underway to form an industry-wide request for government assistance … and I am aware that government has indicated a general willingness to help. Nevertheless, individual wineries may wish to consider if some of the following proactive steps may be desirable:

• For commercial wineries, import juice or grapes from elsewhere in order to have product to sell (albeit not 100% BC product). 
• For land based wineries, consider converting to commercial categorization so that you can do the above. Conversion may not be as onerous as you believe, contact me if you need advice.
• Advocate for temporary changes to the LDB’s land-based winery rules to allow some form of the above without losing land-based status.
• Ensure that any labelling of non-BC product is not misleading and compliant with federal labelling rules.
• Unify around a request for government assistance. Government will be more likely to act if the industry can provide options that have consensus or near-consensus.

I note that the Walla Walla region in WA state has experienced devastating freeze events from time to time, particularly in 1996 and 2004. This has resulted in some of its storied producers sourcing grapes from outside the appellation (and even from outside the state). See this news story for details and this resulting “Appellation American” wine from prominent producer, Leonetti Cellars.I note that the above applies to the interior wine regions of BC. Coastal wine producing areas thankfully escaped the extreme temperatures. As such, wineries in these regions will be able to continue business pretty much as normal (likely with increased demand for 100% BC product). Regrettably, it will likely take years before the interior wine producing regions can recover fully from these tragic climate induced events.

As the holiday season approaches, most wine lovers will look forward to socializing with friends and family in the days ahead. For many of us, these valuable social interactions will include a glass of wine. Such gatherings have been part of civilization for thousands of years. They provide pleasure and community connection which is vital for individual well-being. Nevertheless, many of us may be thinking twice about drinking during the holidays, even in moderation, due to the recent efforts of anti-alcohol advocates who claim that there is “no safe level” of consumption and that “alcohol causes cancer”.

Such statements are wild exaggerations of reality. Here are some reasons why you should ignore the fear-mongering and carry on enjoying a drink in moderation if you choose to do so. Firstly, the science related to safe levels of consumption has not changed. Hundreds of studies, and decades of scientific research, have consistently shown that those who drink in moderation live about as long (or even slightly longer) than those who don’t drink at all. The reality is that moderate drinking provides some cardiovascular benefits while slightly increasing the risk of certain cancers, some of which are very rare (see this article with comments from physician and winemaker, Laura Catena). For most people, there is little or no effect on overall health and mortality. Unbiased science continues to demonstrate this including work done in the past couple of years.

The claims related to cancer are also exaggerated and simplistic. In reality, nearly all cancers (96%) are not caused by alcohol. Of the 4% that are, most of these are related to drinking in excess. Indeed, if you want to confirm this … ask someone whose business revolves around life expectancy … the life insurance business. These folks will lose a lot of money if they get this wrong. There’s a reason that life insurance premiums are higher if you are a smoker … because there is a direct causal link between smoking and a shorter life. However, life insurance premiums are not higher if you are a moderate drinker … because, in actual fact, responsible drinking has very little to no effect on average life expectancy. You can see this for yourself if you play with the life expectancy calculator created by Sun Life Insurance. For example, smoking will shorten life expectancy by about 5 years or so. Moderate drinking will either have no effect or slightly increase life expectancy

Yes, those who choose to drink should do so responsibly and in moderation. But wine lovers should not worry about having a social drink while they mingle over the holidays. We all know family and friends who have safely consumed in moderation for decades and lived to a healthy old age. Now more than ever, it is important to enjoy the benefits of friendship and social interaction … and, if you want to have a glass of wine while doing so … don\’t let those who have built their careers on anti-alcohol advocacy scare you from enjoying yourself. Happy Holidays.

The mainstream and industry media continues to report that Canada’s “low risk drinking guidelines” have changed and that they have been reduced to “two drinks per week”. If true, this would be a dramatic reduction from the previous guidelines which were 15 drinks per week for men and 10 drinks per week for women.

Many stories have reported this, a few of them are here: Wine Spectator, Wine Enthusiast, and NY Times.

However, the stories are NOT correct. Canada\’s drinking guidelines have NOT changed and remain the same as they were in 2011. The official guidelines, from Health Canada (a federal government agency) are still located here and are unchanged: Health Canada Low Risk Drinking Guidelines.

Unfortunately, what has happened is that an advisory group has recommended that Health Canada lower the guidelines. Health Canada has neither accepted nor rejected that recommendation. I note that the title of the report containing the recommendations (“Canada’s Guidance on Alcohol and Health”) is misleading as it implies that Health Canada has already accepted the recommendations when it has not.

The group that I lead believes that these recommendations are flawed and should not be adopted. There is more information on our web site located here (Canadian Assoc. for Responsible Drinkers) including our analysis of why the recommendations contained in the report are flawed.

The Canadian Alliance for Responsible Drinking (CARD) has officially launched to provide sensible information on alcohol & health issues. CARD\’s mission is to provide unbiased information and education that encourages responsible consumption and reduces harmful consumption. It’s an important objective during a time when exaggerated claims are circulating and when Canadians are likely confused about conflicting information from various levels of government. I am the Executive Director of the informal alliance which includes concerned citizens and businesses. There’s a short launch message located here that explains what we’re about. CARD’s web site is now live and provides plenty of information and resources on these topics. I hope that it will prove to be useful and will enable you to make smart and informed decisions about alcohol consumption.