I thought some of you might want to look at what I wrote to the FDA. The
inaccuracy about Heinz having better labels came from a consumer affairs
person at the supermarket. I really should have checked first. Oh, well,
can't be perfect.
Rachael Hamlet
Mom to Hannah (6/14/92), bf advocate
And Radical BF Lawyer Mom from Hell
Falls Church, VA
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J. Rachael Hamlet, Esq.
Telephone (703) 903-8876
2026 Peach Orchard Drive
Apt. T1
Falls Church, VA 22043
July 27, 1995
Food and Drug Administration
200 C Street, SW
Washington, DC 20204
Attn: Nan Rainey
Re: Labeling of Juices and Other Foods for Infants
Dear Ms. Rainey:
As a mother, and as an attorney concerned with food safety issues, I am
writing to complain about the labeling of juices and other foods for infants.
As an illustration, I have enclosed a copy of a label from White House brand
apple juice. Please note the drawing of a baby bottle with the words "GOOD
FOR BABY TOO!" written on it.
The FDA itself, in its consumer publications, as well as the American Academy
of Pediatrics and other entities concerned with the health of infants,
recommend only breastmilk or approved infant formula for the first six months
of life. I am very concerned that parents could interpret this label as
encouragement to use apple juice to replace one or even more daily feedings
of breastmilk or formula in a young baby. Because apple juice provides only
the most minimal of nutrients (other than sugar), and babies' nutritional
needs are very great and very complex, regularly replacing breastmilk or
formula with apple juice could cause great harm to babies. An infant whose
diet contained a substantial amount of juice instead of breastmilk or formula
could end up seriously malnourished, as well as suffering from
gastrointestinal distress
In addition, baby food companies, such as Gerber and Beech-Nut, market juices
and other foods for infants in a manner quite similar to the enclosed label.
I have heard that Heinz is an exception: they do include information on
their labels about foods other than breastmilk or formula being inappropriate
for younger babies. I believe that Heinz has demonstrated that more
responsible labeling is feasible. [Since mailing this, I have learned that
Heinz is no exception, after all.]
As I am sure you are aware, the United States has signed the World Health
Organization's Code for the Marketing of Breastmilk Substitutes, which
expressly prohibits this kind of labeling. While no enabling legislation has
yet been enacted by Congress, existing laws permit the FDA to regulate
labeling of foods in order to protect the health of infants.
I would like to know if the FDA has any regulations in place regarding the
labeling of foods as being appropriate for consumption by infants. If yes, I
would like to know what those regulations are. I would also like to know
what mechanisms are in place for enforcing such regulations. If no such
regulations exist, I would like to know why not, and what mechanisms exist
for enacting such regulations.
Please feel free to contact me at the above address and phone if you need
more information from me. I can also recommend that you contact Barbara
Heiser, RN, IBCLC, of the National Alliance for Breastfeeding Activism, at
(410) 995-3726, and Karlyn Sturmer of Action for Corporate Accountability, at
(203) 787-0061.
Sincerely,
J. Rachael Hamlet, Esq.
cc: National Fruit Products Company, Gerber, Beech-Nut, Heinz
Center for Science in the Public Interest
National Alliance for Breastfeeding Advocacy
Action for Corporate Accountability
encl.
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