Dear Ms Thewliss MP,

I Support You is an online community of parents who are passionate about using our personal and professional experiences to describe and improve infant feeding culture.  We write to you with regards to your bill of 16th November 2016.  It is important to note that we absolutely agree that all parents are entitled to clear, accurate, impartial and safe advice on infant feeding, infant feeding products and safe preparation. However, we are concerned that this bill ignores the diversity of parents and families today, and in doing so fosters an environment of inequality and silence around formula feeding. Secondly, formula is already a highly tested and regulated product and so replicating existing laws and bodies is a waste of resources that could be better spent on areas that we know will improve infant feeding culture within the UK.

We all expect the food we consume to be safe. We would like to hope that the standard of that food is monitored and that the advertising that tries to encourage us to buy it is accurate; should that not be the case, we would hope that the companies involved would be punished for misleading us.

There are currently five separate independent agencies involved in the regulation of infant feeding products, their efficacy and their advertising.  Excluding the World Health Organisation (WHO), these are the Food Standards Agency (FSA), European Food Standards Agency (EUSA), Scientific Committee for Food (SCF), Department of Health (DofH) and the Trading Standards Authority.  These five bodies are collectively responsible for controlling the level of pesticides found in products, guarding against contaminants, micro-organisms and checking packaging. They check claims made by companies and enforce the existing laws that already prevent marketing of infant formula milks intended as breastmilk substitutes.  This makes your claim that [T]here is no independent verification of formula composition or of claims somewhat confusing in its inaccuracy.  Trading Standards enforce these existing laws with help of the existing punishments of fines and imprisonment for any person found to be making erroneous claims.  Given these points we can say with certainty that infant feeding products are extremely safe and it would seem that this bill wastes precious resources on replicating pre-existing laws and agencies.

We expect parents to have access to information so that they can make informed choices about how they feed the most vulnerable and precious people in our society: babies and young children.

This is something that I’m sure that we can all absolutely agree on, however, this must apply equally to all infant feeding.  As we all know, when infant feeding goes wrong a baby’s vulnerability means that wrong can be catastrophic and it can happen very fast. Information gained by The Guardian newspaper in 2012 demonstrated that NHS lawyers had set aside the staggering figure of £235.4million to compensate families who have children left with complications from hypoglycemia, just one complication, after they received unsafe breastfeeding advice and serious failings in care during the first few days of their lives.

Currently breastfeeding leaflets are set out in such a way as claims are sometimes misleading and often unsupported or false. The omission of references for sources of claims makes it difficult to critique them directly.  However, it is not controversial to state that claims such as a reduction in the incidence of cardiovascular disease, type 2 diabetes and obesity are not currently supported by randomised control trials or sibling studies.  It appears that most claims laid out in NHS literature are based on observational studies which are confounded by the fact that breastfed babies differ from non-breastfed babies in terms of maternal education and IQ and socio-economic environment. In addition to misleading parents on the proven benefits of breastfeeding, much of the literature given to new mothers includes information that minimises breastfeeding difficulty.  The NHS erroneously claim that almost all women are physically able to breastfeed and pain during breastfeeding means your baby is incorrectly positioned where the reality is that there are many reasons that this could be the case and professional help could be required. 

Notwithstanding how troubling it is that our National Health Service are making claims that are thus far unsubstantiated in the scientific literature, failing to address the real reasons that account for health outcomes for British babies is an act of harm. The proposed bill further contributes to the avoidance of tackling the issues that research shows does affect health outcomes.

We expect our health professionals to be knowledgeable, and we expect them to be able to give impartial advice on foods from a position of expertise.

We have heard time and time again that parents cannot find or access the comprehensive and unbiased information on infant feeding that they deserve.  To give some perspective, 80% of women initiate breastfeeding in days following the birth of their child, by six weeks this figure has fallen to 55% and by six months this figure sits at 1%.  Alarmingly, 80% of the women who stop breastfeeding do so unwillingly and with serious regret.  Even more alarmingly, when we speak to parents who have switched to using formula milk for whatever reason feel that they cannot get advice on formula or safe formula preparation from health care providers and worse, they come away with feelings of guilt and shame.  This is not acceptable, especially given that we see time and time again that parents are desperate for Mother-Centred, face to face, non-judgmental and predictable support.  Surely our resources would be better spent on creating and supporting schemes that could meet these requirements instead of replicating existing laws and bodies?

Many parents will never be able to exclusively breastfeed their children and they certainly understand their individual reasons for this, it is completely unnecessary to patronise them by making the assumption that their infant feeding choice is influenced by the presence of shields, crowns and cute animals.  These parents could be those who try desperately to breastfeed but cannot, but they also include adoptive parents, those with mental health concerns or medical conditions requiring medication incompatible with breastfeeding, trans women, women who have undergone breast surgery, women with insufficient glandular tissue, survivors of rape and sexual abuse for whom breastfeeding may be triggers, those suffering or recovering from eating disorders or body dysmorphia who may find changes to their bodies painful and triggering.  Some parents may struggle with literacy or have English as a second language.  These parents absolutely deserve our respect and to be treated with compassion and empathy, they should be filled with the confidence they need to start on their infant feeding journey.  Treating formula boxes in the same way as we currently treat cigarettes and tobacco products sends an abysmal message to these people.

Given the disproportionate prevalence of bottle feeding in less affluent areas, the poorest families in our society are losing out the most. The Government should act to protect their interests […]

We agree that those who are able to breastfeed have usually overcome several hurdles before they even get to the starting line. They are people who have good health, higher levels of education, professional jobs, live in more affluent parts of the UK, are thirty plus, in stable relationships, entitled to maternity leave and much more. This bill does nothing to address the societal and structural inequalities that these families face but is punitive and patronising to parents who are making a sound and safe decision for their children based on their personal circumstances. In Glasgow, 34.1% of families live in poverty and struggle to receive the correct nutrition.  Infant formula milks and associated follow on milks provide the full RDA of Iron and Vitamin D and as food bills rise, incomes stagnate or fall and families suffer, for many ensuring their child has a follow on milk is their most effective way of getting these essential nutrients into their children’s diets with no food waste.  Indeed there are many parents who do not live in poverty who come to the same conclusion as is their right. Painting these milks with the broad brush of unnecessary shows a lack of regard for the myriad of personal reasons that people may choose to offer these products.

Moving from the hypothetical and statistical we invite you to read the stories from parents who have been kind enough to share their experiences on our blog.  These wonderful families and our own are what lead us to believe that policies which promote and enable equality in an increasingly diverse world, respect scientific process and distribution of information and respect parental choice should be our goal. This means that no single feeding method should be promoted over another, a woman’s bodily autonomy and family circumstances should be respected, health care providers must be properly trained to give appropriate, safe and non-judgmental advice and infant feeding products should not be singled out for treatment that undermines safety and parental confidence.

We would like to close by acknowledging that we believe that we are all coming to this from the same place, and that is that we need to treat parents with respect, empathy and kindness. We feel that while it is disappointing that your inquiry was launched after the proposal of this bill and that the consultation on which it was built was so poorly conducted and received such little analysis, there is perhaps a salvageable opportunity to make progress towards keeping our babies safe and well fed and act to improve the current feeding environment.  

We ask that you reconsider the potentially harmful and punitive elements of this proposed bill as identified in this letter and through parent testimony, and that you divert funds earmarked for replicating existing laws and bodies to actions that could improve maternity. 

Kind Regards

I Support You Movement.