Recommendations: INFACT’s Appeal to Ujjal Dosanjh
In response to Health
Canada finalizing the revision of its vitamin D policy for Canadian infants,
INFACT Canada wrote to Health Minister Ujjal Dosanjh. We urged him to reconsider
the controversial recommendations that all breastfed infants be given a daily
supplement of 400 IU of vitamin D from birth.
Our letter requested that
Minister Dosanjh review this controversial vitamin D policy. We invite you to
add your voice of concern.
Write (no postage required)
The Honourable Ujjal
Minister Responsible for
House of Commons
INFACT Canada’s letter to
February 21, 2005
Honourable Ujjal Dosanjh
Minister Responsible for Health Canada
INFACT Canada, the Infant
Feeding Action Coalition, a non-profit membership-based organization that works
to promote, support and protect breastfeeding and appropriate infant and young
child feeding practices, is urging you to reconsider the controversial
recommendations from your department requiring that all breastfed infants be
supplemented daily with 400 IU of vitamin D from birth.
Health Canada staff has
finalized the revision of its vitamin D policy for Canadian infants.
As part of the revision
process of the Health Canada, Canadian Paediatric Society and the Dietitians of
Canada, Statement “Nutrition for Healthy Term Infants”, Health Canada requested
comment from Canadians on its proposed revised policy. Organizations and
individuals involved in breastfeeding and infant and young child nutrition
submitted suggestions and recommendations regarding infant feeding practices to
ensure the best possible health outcomes, growth and development, including
avoiding the risks of an inadequate supply of vitamin D for Canadian children.
However, the proposals and recommendations for an approach that includes
education and screening for those at risk were ignored.
signed by you:
It is recommended that all
breastfed, healthy term infants in Canada receive a daily vitamin D supplement
of 10µg (400IU).
Supplementation should begin
at birth and continue until the infant’s diet includes at least 10µg (400IU) per
day of vitamin D from other dietary sources or until the breastfed infant
reaches one year of age.
recommendation must be reviewed and reconsidered:
policy is not based on adequate scientific data,
there is no scientific data offered that all breastfed infants are at risk,
surveys of those at risk identify a population at risk for screening and
there is no evidence offered that the recommendations are safe,
alternatives and preventive measures are not included in the recommendations,
there is significant conflict of interest in data used and researchers
public health approach is needed as the vast majority of infants and new
mothers receive publicly funded care through the health care system. Screening
for those at risk is a viable approach and targets only those who may need
interventions rather than a blanket approach, which targets all babies. The
vast majority of newborn breastfeeding infants are not at risk for developing
vitamin D deficiency and would be needlessly supplemented. The normal source
for vitamin D is sunlight. Safe exposure to sunlight to assure normal vitamin
D status should be a part of a public health education program. In addition to
receiving vitamin D to confer bone health, other benefits are derived from the
safe exposure to sunlight such as the prevention of autoimmune diseases,
cancers and cardiovascular disease.
Holick MF. Sunlight and
vitamin D for bone health and prevention of autoimmune diseases, cancers and
cardiovascular disease. Am J Clin Nutr 80: 1678S-16788S, 2004
Exclusive breastfeeding is not a risk factor for vitamin D deficiency. There
is no accepted scientific data documenting that ALL breastfeeding infants need
supplementary vitamin D at 400IU/day from birth. Scientific literature on
vitamin D adequacy of infants notes that deficiency is rare and only a small
minority are at risk. Those at risk are infants born to mothers who do not
drink fortified milk during pregnancy and lactation, do not receive vitamin D
supplements, have dark skin and do not get exposed to sunlight. Frequently
these are recent immigrants from southern countries. It is in these situations
that a vitamin D supplement is warranted for newborn and young infants.
Preventive measures that are targeted and safe include; the screening for and
counseling of mothers to receive vitamin D supplements prenataly and during
lactation; education on how to utilize safe exposure to sunlight; and the
consumption of vitamin D enriched foods. Insufficient exposure to sunlight of
both mother and her infant is the risk factor.
Sills I et al. Vitamin D
deficiency rickets. Clin Pediatr 8: 491-493, 1994
Binet A et al. Persistence
of vitamin D-deficiency rickets in Toronto in the 1990s. Can J Publ Hlth
There is insufficient scientific data that a population-based approach of
supplementing all infants from birth is safe. Vitamin D is not a vitamin, but
a hormone capable of inciting unintended effects (Vieth –1990). No
surveillance data on safety for newborns and young infants has been provided
by Health Canada to indicate that daily doses over an extended period of time
(the recommendation is for one year) do not reach toxic levels. The only
assurance of safety that Health Canada provides is “a history of safe use”. It
should be noted that orally administered vitamin D is used as an effective
rodenticide (Greaves – 1974).
Vieth R. The mechanisms of
vitamin D toxicity. Bone and Mineral 11: 267-272, 1990 (Note: toxicity studies
conducted by Vieth have all been done with adult subjects. The current policy
will in effect be a mass uncontrolled trial)
Greaves JH. Some properties
of calciferol as a rodenticide. J Hygiene 73: 341-351, 1974
There are no warnings given in the Health Canada recommendation on the risks
of overdosing on vitamin D. Given the patterns of infant feeding during the
first year of life of Canadian infants, no warnings are made regarding the
need to cease using the supplements when mixed feedings of breast and formula
occur or when mothers wean and begin to use breastmilk substitutes
exclusively. Infants risk being double dosed to receive 800 IU of vitamin D
daily without these warnings.
mothers are the least likely to breastfeed their infants as demographics of
infant feeding practices demonstrate (unpublished surveys by Halton – 2002;
York Region – 2004 Public Health). It is however low-income mothers who have
the most to gain by exclusively breastfeeding their infants from birth. These
mothers may be deterred from breastfeeding their infants because of the high
cost of the vitamin D supplements. The need to buy an expensive product may
augment other reasons to deter low-income mothers from breastfeeding.
Participants of the policy review committee selected by Health Canada have
competing interests. Members of the review committee or the organizations they
represent receive direct benefits from the industry that manufactures the
vitamin D drops. The Canadian Paediatric Society Surveillance - 2003 project,
on which the policy recommendation is based is in part funded by Mead Johnson,
the makers of the D-Vi-Sol vitamin D supplements. It is these supplements all
breastfed infants are to consume daily from birth for the first year of life.
Moreover, one of the co-investigators (Dr. S. Zlotkin) of the vitamin D
surveillance study is a long-time research consultant with Mead Johnson. It is
critical that these questionable practices in setting infant and young child
feeding policies be investigated by Health Canada.
Canada’s public health policy on infant and young child feeding is to support
and promote breastfeeding from birth to two years and beyond. The vitamin D
recommendation for all breastfed infants is in conflict with the breastfeeding
policy. The manufacturer of vitamin D drops is also a manufacturer of
infant formulas, which are marketed to compete with breastfeeding. The
manufacturer uses the need for vitamin D to undermine a new mother’s
confidence in her breastmilk by promoting the nutritional “inadequacy” of
breastmilk and the completeness of infant formulas in parenting magazines and
other marketing devises. This potential conflict between the two policies
should be investigated by Health Canada.
likely undermining harm to breastfeeding initiation and duration rates as a
result of the vitamin D recommendations, may translate into increased health
risks for infants and young children that will be far greater than the
possible risks associated with vitamin D deficiency. It is critical that your
department weigh the consequences of advocating vitamin D on breastfeeding
rates and the ill-effects caused by its undermining impact on mothers. The
human health trade-offs need to be made evident in the policy statement. The
Canadian Paediatric survey noted 69 cases of nutritional rickets in children
to the age of 18 years of age over an 18 month time period (CPSP - 2003). No
mortality was reported to be associated with these cases. In contrast a recent
study estimates that every year in Canada we can anticipate that 72 infants
will die (excluding neonatal deaths) because they are artificially fed. In
addition, infants and young children who are not breastfed suffer increased
infectious diseases (respiratory, otitis media, gastrointestinal, chronic and
autoimmune diseases such as type 1 diabetes, allergies and in the longer-term
cardio vascular disease.
Chen A, Rogan WJ.
Breastfeeding and the risk of postneonatal death in the United States. Padiatr
Fewtrell MS. The long-term
benefits of having been breastfed. Current Paediatr. 14: 97-103, 2004
Why does such a
controversial policy have priority from Health Canada when other less costly and
more effective guidelines or recommendations to improve infant and young child
nutrition are available such as:
and funding for baby-friendly initiatives in the community and in hospitals,
promotion of breastfeeding as a national priority,
implementation of the International Code of Marketing of Breast-Milk Substitutes
and subsequent relevant Resolutions of the World Health Assembly. The
International Code and resolutions restrict the marketing of infant formulas,
complementary foods, bottles and teats in order to protect breastfeeding and
remove commercial interference, including pecuniary conflicts of interest, from
infant and young child feeding decisions.
The primary beneficiaries of
this policy will not be Canada’s infants, but the very same industry that
violates Canada’s Food and Drugs regulations and Industry Canada’s Competition
Act with misleading labelling and claims and violates the World Health
Organization’s rules on the marketing of infant formulas.
We respectively request your
urgent action to review this controversial vitamin D policy. In the best
interest of all mothers, infants and parents we urge you to institute
science-based infant feeding recommendations, based on public health principles
and free from conflict of interest and to include the involvement of a wide
spectrum of Canadian participants working in infant and young child feeding.
Elisabeth Sterken, BSc,MSc, nutritionist
Director, INFACT Canada
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