November 14, 1997

Sharon Jones, Chair
Child Day Care Council
730 East Broad Street
Richmond, VA 23219-1849

Re: Proposal 22VAC 15-30-630I

Dear Ms. Jones:

Through an email list of health care professionals interested in issues of
maternal and child health, I have been informed that the Child Day Care
Council of Virginia is considering a change in regulations that will affect
whether or not women can breastfeed their children in child day care
centers.  According to my source: "The council's stated concern is that
space limitations in some day care facilities may not allow for a private
place for a mother to nurse." and "The council has also stated that allowing
a day care provider to prohibit nursing in the facility will not interfere
with breastfeeding and thus will not increase public and private
expenditures on formula and health care for the additional illnesses caused
by the use of formula."

I would like to address each of these concerns.  First, it is not necessary
for a mother to have a private place to breastfeed.  Breastfeeding is the
normal, natural, and healthy way to feed a child.  It is not something that
needs to be hidden — not from the day care providers, not from the other
parents, and certainly not from the children.  I assume that day care
providers routinely feed their charges with bottles and formula in full
sight of the other day care providers, parents, and the children.  Infant
formula is known to be a major health risk for children, and its use —
except in those rare cases of medical necessity  —  is considered by some
health care professionals to be a form of child neglect or abuse.  To say
that it is fine for the other children to see a baby being fed in a way
known to harm the child (formula) but it isn't fine for children to see a
baby being fed the normal, natural, and healthy way (breastfeeding) is
simply ludicrous.  When my youngest son was in day care, I routinely
re-connected with him at 3 p.m. every afternoon by sitting down in the
rocking chair in the center of the room and nursing him.  The other
18-months-old children, who happened to all be boys, would gather around and
watch with interest.  They were learning what breasts are for  —
breastfeeding.  My day care provider did have a quiet room in the back, with
a big comfortable recliner, a soda machine, and a door, where I could go if
I wanted to be alone with my child.  That was a nice bonus, and I did use
that room on two occasions, but I certainly didn't need a private place to
breastfeed my child.  

The second issue, that of allowing a child day care facility to prohibit
breastfeeding on the premises, is, I believe, against the law.  In Texas,
and according to my understanding in Virginia as well, women have the right
to breastfeed their children wherever they have the right to be, themselves.
Thus, if a mother has the right to be at the child day care facility (which
she clearly does), then she has the right to breastfeed her child there, and
the facility can't pass rules that violate the law.  The claim that
prohibiting breastfeeding in various venues will not interfere with
breastfeeding is not supported by any research that I am aware of.  I know
that my child would have been very unhappy if I had put him in his car seat
without breastfeeding him first, after a separation of six hours.  In
addition, I do not find breastfeeding in the car in the parking lot to be a
reasonable alternative.  If women are made to feel that breastfeeding is
disgusting and dirty, then some will undoubtedly choose not to do so.  A
mother should not have to choose her child day care provider based on
whether or not the providers will allow her to breastfeed her child when she
is there.

I see no reason to support these proposed changes to the Virginia child day
care regulations, and hope you will continue to protect and support
breastfeeding — the normal, natural, healthy way for children to be fed and
nurtured and protected against diseases. 


Sincerely,

Katherine A. Dettwyler, Ph.D.
Associate Professor of Anthropology and Nutrition
Texas A&M University
email: [log in to unmask]