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Thursday, April 14, 2011

AIM submission to Health Canada on Infant Nutrition

A group of mothers on Facebook have formed the Association of Informed Mothers - AIM. This group was initially created to write a submission to Health Canada in response to their draft document "Nutrition for Healty Term Infants: birth to 6 months". This document will replace the current Canadian Guidelines that are in place, and while they have made some excelent changes, some areas of the draft document were very poorly worded, or incorrect. The following is AIM's submission to Health Canada and we would like to invite everyone who agrees with our document to sign your name to the bottom of it as an interested member of the public. If you wish to have your name added to the submission please  go to the facebook note HERE  and comment with your name, city and province. this document will only be open for signatures till 9pm this evening. so please feel free to share it out on your groups etc to spread the word!

A huge thank you to all the moms who poured their heart and soul into this document!


The Association of Informed Mothers (hereafter called AIM) is a stakeholder group of mothers who support and advocate for mothers' rights to make fully informed choices for the health and well-being of both themselves and their families. To do this, mothers need access to information that is in the spirit of full disclosure and is provided free of influence by organizations, third parties, or persons that hold a conflict of interest. It is AIM's belief that Health Canada is responsible to provide information to the citizens of Canada that comply with these points.

AIM fully supports INFACT Canada's submission to Health Canada's Committee reviewing the guidelines for "Nutrition for Healthy Term Infants". AIM strongly believes that INFACT Canada's submission is of great value to the Health Canada Committee, as the information it provides is accurate, does not create a conflict of interest and is well researched. (A copy of INFACT Canada's submission is included at the end of this document).

AIM also fully supports UNICEF's submission to the Health Canada Committee. Health Canada has agreed to follow the World Health Organization's (WHO) infant feeding recommendations, and therefore any statement made by Health Canada should be aligned with UNICEF's submission (A copy of UNICEF's submission is included at the end of this document).

The following is a list of AIM's key concerns with Health Canada's draft document "Nutrition for Healthy Term Infants - birth to six months". AIM has specified a list of changes to be made to the document. These changes are required for the draft document, in order to provide the information parents need to make fully informed decisions for their family.

1. The language of the Health Canada draft document needs to be changed to reflect the normalcy of breastfeeding. Statements such as "the benefits of breastfeeding" should be changed to "risks of artificial feeding methods" or "the importance of breastfeeding". Breastfeeding is the biological norm for all human children, referring to its outcome as "benefits" implies it is outside and/or above the norm. For further information of the use of language and its effects on normalizing breastfeeding, please refer to the article "Watch your Language", written by Diane Weissinger, Journal of Human Lactation, Vol. 12, No. 1, 1996.

2. It is legally and ethically advisable for Health Canada to omit statement #5: "Commercial infant formulas are the only acceptable alternative to breastmilk." from these guidelines. To make such statements is unethical, inadvisable, and untrue. The inclusion of statement 5 directly contradicts Health Canada's acknowledgement and public acceptance of the WHO Infant feeding guidelines, which state that "For those few health situations where infants cannot, or should not, be breastfed, the choice of the best alternative – expressed breast milk from an infant’s own mother, breast milk from a healthy wet-nurse or a human-milk bank, or a breast-milk substitute fed with a cup,which is a safer method than a feeding bottle and teat – depending on individual circumstances."

Statement #5 is also contrary to UNICEF's recommendations for infant feeding, and undermines the use of donated and banked breastmilk. 

Currently, several provinces are researching the creation of milk banks, and the Canadian Paediatric Society is calling for the development of milk banks across Canada. The use of donor milk, whether through formal or informal channels, is vitally important to the health of infants whose mothers are not able to exclusively breastfeed, and is fully supported by WHO. It is the recommendation of AIM that Health Canada develop guidelines to address the use of donor milk, outlining the risks and benefits of using donor milk vs infant formula, and provide the information necessary for parents to make fully informed decisions about feeding their infants.

3. Health Canada should remove all sections in the draft document that discuss the use of artificial breastmilk substitutes. Those sections addressing commercial infant formulas should be made into a separate document or included in an appendix on the use of artificial feeding methods and products. Full disclosure of information about the risks of using commercial infant formulas and safe feeding methods is imperative in order for parents to be fully informed when making infant feeding decisions. By placing nutritional information about infant formulas side by side with breastfeeding, Health Canada is creating the false impression that they are equal and interchangeable methods for feeding infants. This is untrue, misleading, and does not meet the principle of full disclosure, nor does it give parents the proper information upon which to base their decisions. 

4. We submit that Health Canada should make its stance clear by making an official statement affirming that Canada is both a signatory to, and is compliant with, the World Health Organization International Code of Marketing Breastmilk Substitutes and subsequent resolutions. 

The Government of Canada is a signatory to the International Code for the Marketing of Artificial Breastmilk Substitutes and as such is required to pass legislation which provides for the enforcement of all provisions of the Code. Health Canada not only has a responsibility to remind all levels of government of this requirement, but also to ensure that all health care and related facilities within Canada are compliant with the Code. To ensure this compliance, Health Canada must immediately inform all physicians, nurses and health care facility administrators of the full range of provisions of the Code. Upon completion of dissemination of this information Health Canada must ensure that all professionals and facilities in Canada meet the requirements of the Code. INFACT can assist in this matter through the provision of information and resources.

On May 21st, 2011 it will be 30 years since Canada and 118 other countries signed the WHO Code, yet the Canadian government continues to refuse to pass legislation to protect and enforce the Code. 

5. The Baby Friendly Hospital Initiative (BFHI) is integral to ensuring mothers and babies are provided with the minimal support and information needed to begin their breastfeeding relationship at birth. The Baby Friendly Hospital Initiative (BFHI) should be fully endorsed by Health Canada. All Canadian hospitals should be informed of all BFHI recommendations and should be striving to attain BFHI status by a set date. BFHI should be recognized by Health Canada as the minimum requirement, not a luxury.

6. The Health Canada draft document should focus on the need for better breastfeeding and lactation education for all medical professionals (doctors, nurses, midwives etc.), and any personnel that come into regular contact with new mothers (social workers, etc). Health Canada should also advise provincial and territorial health policy makers that breastfeeding support and education at these levels are seriously lacking, and that this lack of education negatively impacts the ability of medical professionals to support mother and baby dyads. Health professionals who are unable to provide educated lactation support should be advised that mothers must be referred to professionals that are fully trained, rather than giving misleading and/or inaccurate advice that is detrimental to breastfeeding success.

7. The statement made in the draft document: "4. In Canada, all infants need supplemental vitamin D. " is incorrect and misleading. Health Canada cannot accurately state that ALL infants need to be supplemented with Vitamin D. Instead, AIM recommends that Health Canada set up prenatal maternal testing for Vitamin D levels. If mothers are shown to be deficient in Vitamin D, prenatal supplementation has been shown to optimize vitamin D levels in infants. Canadian mothers are at higher risk of being Vitamin D deficient due to northern latitude and long winters with little sun exposure. Therefore, it is the recommendation of AIM that Canadian mothers be advised by Health Canada to take a Vitamin D supplement along with folic acid to ensure infant health after birth.

8. AIM does not agree with the current American Academy of Paediatrics recommendation that breastfed infants should be supplemented with iron. Breastmilk has been proven to contain adequate iron to support infant health, except in cases of severe maternal anemia. It is AIM's recommendation that Health Canada encourage prenatal testing to address maternal anemia before birth. 

9. The statement by Health Canada in section 2.7: "The impact of cesarean birth on breastfeeding appears to have changed over time. In most cases today, cesarean birth does not impede breastfeeding" is incorrect and needs to be removed. There is no evidence to support this statement, and strong evidence to contradict it. Health Canada needs to set up separate guidelines that examine and make recommendations about medical interventions during pregnancy and childbirth such as chemical inductions, the routine use of IVs, epidurals, invasive testing and pain medications during labour, the use of surgical interventions, such as forceps/vacuum extractions and cesarean sections, and early cord clamping and their effect on maternal and fetal outcomes, with special attention given to breastfeeding initiation and longevity . Perinatal practices are one of the most powerful indicators of long term breastfeeding success and are therefore vitally important considerations.

10. In section 9 the Draft Document states that "9. At six months, infants need complementary foods along with continued breastfeeding to meet their nutrient needs". This statement gives the impression that breastmilk is no longer adequate after 6 months and that it suddenly loses it's ability to nourish an infant at this time. This is inaccurate. It should also be noted that not all infants are ready for or require complementary foods at a set age, i.e. 6 months. A statement that "Infants should not be given complementary foods before 6 months, but after that time introduction solids may begin" would be preferable.

It is the opinion of AIM that the committee responsible for these guidelines is lacking oversight by the public and should include members that are involved in stakeholder groups or members of the general public who are interested in the outcomes of the draft document and Health Canada's new guidelines. 

Currently breastfeeding initiation rates in Canada are excellent. However, by 3-6 months the percentage of mothers exclusively breastfeeding their babies drops radically. This extreme drop in breastfeeding rates directly affects the health and wellbeing of mother-baby dyads and is an accurate indicator of the lack of information and lactation support currently available to families across Canada. It should be noted that the recommendation of exclusive breastfeeding to six months is often undermined or outright ignored by health care professionals who encourage or recommend or demand supplementation with infant formula before the baby has even been released from hospital. Evidence-based information and education provided to parents and health-care professionals is integral to the increase of long-term breastfeeding rates in Canada. As members of AIM, and as mothers, we have a vested interest in increasing breastfeeding information and education available to healthcare providers and families across Canada. We therefore respectfully request that Health Canada review our submission and make the changes necessary to bring Canada in line with the World Health Organization, and to maintain its place as a key player in the forefront of worldwide health.

We thank you for the opportunity to provide our recommendations. We would like to be included as a stakeholder in any future consultation on these or similar guidelines. 

Association of Informed Mothers

Danielle Arnold
Brantford ON