The 3 Minute Activist
Independent Women's Forum (June 10, 2020).

To: Mike Leavitt (Secretary Health and Human Services) Office off Health and Human Services Barbara Cubin Office of the Inspector General at the Department of Health and Human Services Louise Filkins (Independent Women's Forum) I am writing to ask you please to support efforts that promote breastfeeding and limit the misleading advertisement of formula (for example WHO resolution EB115.R12). The American Association of Pediatrics (AAP) recognizes the pressing need for all infants to be breastfed exclusively for six months and after that for as long as desired. Mothers working outside the home often do just that. (All mothers are working mothers.) Breastfeeding sets women and families free: saves hard earned income, saves precious time, allows easy travel, gives better health to the mother and child, and allows the mother and child free to be spontaneous. (For a more complete list of the way breastfeeding aids mothers see 101 reasons to breastfeed: http://www.promom.org/101/index.html) Resolutions like EB115.R12 are especially needed to offset obstacles to initiation and continuation of breastfeeding including "media portrayal of bottle feeding as normative; commercial promotion of infant formula through distribution of hospital discharge packs, coupons for free or discounted formula, and some television and general magazine advertising; misinformation; and lack of guidance and encouragement from health care professionals." (AAP: http://aappolicy.aappublications.org/cgi/content/full/pediatrics;115/2/496) People opposing the WHO resolution erroneously argue that: 1) EB115.R12 will ban formula. Not true. It will ban irresponsible, misleading, dangerous advertisement and promotion of formula. (Read EB115.R12: http://www.who.int/gb/ebwha/pdf_files/EB115/B115_R12-en.pdf). For those women are truly unable to, simply choose not to breastfeed or who do not have access to expressed breastmilk, EB115.R12 does NOT ban the production, sale and use of formula. 2) EB115.R12 will repress women (women working outside the home). Not true. Breastfeeding is compatible with full time work outside the home. Women who continue to breastfeed after returning to work miss less time because of baby-related illnesses and have shorter absences when they do miss work, compared with women who do not breastfeed. Working mothers who continue nursing also have higher morale and, perhaps most interesting, tend to return to work earlier from maternity leave, presumably because they are less concerned about the effect of their return on the nursing relationship. 3) Formula is safe. True and not true. Formula is better that cows milk, sugar water, etc. But formula is much more dangerous than breastmilk. Many research articles support forumla as unsafe when compared to breastfeeding. The AAP states formula fed infants have higher risks for infectious diseases, death, obesity, diabetes, etc. In addition, postneonatal infant mortality rates in the United States are reduced by 21% in breastfed infants. Mothers that do not breastfeed are more likely to have breast cancer, osteoporosis and other serious health problems. (For the complete AAP statement see: http://aappolicy.aappublications.org/cgi/content/full/pediatrics;115/2/496 ) In addition, there are direct concerns about the safety of powdered formula especially for preterm, low birth weight or immunocompromised infants with regards to intrinsic contamination of powdered formula with E. sakazakii and Salmonella. (http://pediatrics.aappublications.org/cgi/content/extract/110/4/833 and FAO/WHO Expert Meeting on E. sakazakii and other Microorganisms in Powdered Infant Formula: Meeting Report. Microbiological Risk Assessment Series No. 6, 2004, p. 37.) 4) EB115.R12 is offensive to adoptive mothers. Not true. Adoptive mothers can and do choose to breastfeed! Breastfeeding is very empowering to adoptive mothers. Many lactation consultants have specialties in helping adoptive mothers. (http://www.adoption.org/adopt/breastfeeding-adoption.php) 5) Mothers with mastitis and plugged ducts cannot breastfeed. Absurd! The cure for mastitis and plugged ducts is more nursing! (http://www.lalecheleague.org/FAQ/mastitis.html) 6) EB115.R12 is inconsistent in regards to HIV positive women breastfeeding. HIV is a complicated issue. There is risk with nursing while HIV positive, but this needs to be weighed against the real risks of formula feeding! The AAP states: "In the United States, mothers who are infected with human immunodeficiency virus (HIV) have been advised not to breastfeed their infants. In developing areas of the world with populations at increased risk of other infectious diseases and nutritional deficiencies resulting in increased infant death rates, the mortality risks associated with artificial feeding may outweigh the possible risks of acquiring HIV infection. One study in Africa detailed in 2 reports found that exclusive breastfeeding for the first 3 to 6 months after birth by HIV-infected mothers did not increase the risk of HIV transmission to the infant, whereas infants who received mixed feedings (breastfeeding with other foods or milks) had a higher rate of HIV infection compared with infants who were exclusively formula-fed." (http://aappolicy.aappublications.org/cgi/content/full/pediatrics;115/2/496) 7) EB115.R12 will cause formula to carry warning labels. This one is true! EB115.R12 requests the commission "to urgently complete work currently under way on addressing the risk of microbiological contamination of powdered infant formula and establish appropriate microbiological criteria or standards related to E. sakazakii and other relevant microorganisms in powdered infant formula; and to provide guidance on safe handling and explore the necessity of adding warning messages on product packaging." Formula SHOULD carry warning labels akin to those of cigarettes and liquor. Even medications like insulin carry warning labels with risks spelled out! A party separate from the formula manufacturers needs to get the truth to the public. The labels could state the risks with formula feeding compared to breastfeeding and the risks of formula compared to cows milk or other starch milks to be completely clear. Formula labels could even display the preference for nutrition sources as: breastfeeding, expressed breastmilk, breastmilk from a milk-bank, formula. The warnings should state the risks of preparing and using formula not consistent with directions. In summary: When mothers do not breastfeed, or only do so partially, there is a legitimate need for infant formula and for suitable ingredients from which to prepare it; all these products should accordingly be made accessible to those who need them through commercial or non-commercial distribution systems; and they should NOT be marketed or distributed in ways that may interfere with the protection and promotion of breastfeeding. The fact is that resolution EB115.R12 simply limits formula from being marketed and requires warning labels. THAT'S ALL. So how is that offensive to anyone? NO one is telling anyone not to formula-feed -- in fact, no mother is being limited in any way -- rather, companies that have been making billions off of lies are being limited, and the truth is being more widely dispersed to consumers. Please support women's freedom to make their own educated decisions.
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