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Infant Feeding Guidelines for Health Workers submission

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Clinical Midwife Consultant and IBCLC
E. Submission


Submission for feedback on the draft  NHMRC Infant Feeding Guidelines

The time allowed from release of the guidelines to closing date for submissions has been insufficient to allow for institutions to formulate informed and meaningful  feedback on this very large and influential document. I request an extension to make a detailed and considered submission and include feedback from the other experts in my workplace of RPA Women and Babies who have concurred with me over the short time for feedback.

Overall the document is sound but it would be improved if breastfeeding was recognised as the biological norm in the language throughout for example; rather than the benefits of breastfeeding the risks of formula feeding.

Some initial feedback is as follows:

  • The term "nursing" should be replaced with breastfeeding through the document. This is inconsistent as often the document has the term breastfeeding and then in other places has "nursing"
  • There are some outdated terms for example

a) Page 54 refers to milk sinuses which have been proved not to exist in 2005, Ramsay DT, Kent JC, Owens RA, Hartman PE. Ultrasound imaging of the lactating breast redefined with ultrasound imaging. Journal of Anatomy 2005; 206: 525-34

b) Page 56 refers to foremilk and hindmilk which is a term which is outdated. The more correct expression is "the slower the milk flows the higher the fat content"

  • The recommendation of starting "spoon feeds" - solids requires more time to respond. However, in brief - 6 months exclusive breastfeeding and then with the introduction of solids or family foods  to continue breastfeeding for up to 2 years and beyond are the recommendations of the WHO and also the NSW Ministry of Health Breastfeeding policy. As stated in the draft guidelines there is grade B evidence for exclusive breastfeeding to 6 months for both developed and developing countries. There is evidence to suggest that lowering the recommended age of the introduction of solids  that a higher percentage of babies have solids introduced earlier than the recommendations of 17 weeks (Cattaneo et al ,2011 "ESPGHAN's 2008 recommendation for early introduction of complementary foods: how good is the evidence?" Maternal and Child Nutrition DOI:10.1111/j.1740-8709.2011.00363.x)
  • The use of the word spoon foods instead of family foods suggests that soft finger family foods are not an option
  • Where is the evidence for 12 months breastfeeding rather than two years?
  • Where is the evidence for removing the recommendation in the previous guidelines for written consent from the mother before supplementing her baby with formula? Instead this has been watered down to "agreement" on page 7. In addition the template  forms for consent for supplementing with which were widey used have been removed.
  • An omission is any recommendations around the use of donated pasteurised  human milk for at risk infants

Again I request an extension in time to give more considered evidenced based feedback to these guidelines.

Page reviewed: 14 December, 2012