Thank you Laura for bringing Trulacta to our attention. I don’t know anything about them other than what I saw on their website. Their website does beg a few questions for me.



1. Re: sourcing the milk - Their wording is very careful and vague, as is most marketing material.

a. safely and ethically sourced - resonates with HMBANA’s mission statement that refers to evidence based best practice and ethically sourced milk. They do not include the part of HMBANA’s mission about equitably distributed.

b. They refer to reputable milk bank partners - that’s pretty vague. It cannot be HMBANA milk banks because Trulacta assures that their “milk bank partners must be able to demonstrate that donors are always compensated for their excess milk.” HMBANA does not pay its donors. They do not say where the milk does come from.

c. They are also addressing concerns that have been raised about other for profit human milk product companies. “Trulacta regularly reviews its milk bank partners’ donor policies and procedure to ensure that donors are treated fairly.”

d. I do not know where they source their milk, it could be from other companies, or they could have set up their own “milk bank partners”. I expect that if they set up their own milk donation partner groups they would say so on their website so folks could donate.

e. The fact that they aren’t clear about where they milk is sourced is some reason for concern.



2. re: the science

a. If you look at the science<https://www.trulacta.com/pages/the-science> page on their website, you learn that their process is proprietary, i.e. how they do what they do is not public. They are entitled to that, it’s done in business all the time, but a little more information than it kills pathogens without pasteurizing would be helpful.

b. They have multiple certifications from FDA, related to good manufacturing practices (GMP). GMP refers to safety of the processing, does not address the quality or benefits of the content, rather that it is produced safely and you’re not likely to find contaminants or foreign objects in the pills. It is not clear how they are categorized by FDA, presumably they are a food supplement, in which case FDA does not oversee or validate nutritional claims of the product. This is true of all the vitamin supplements sold in the US.

c. The page on clinical research<https://www.trulacta.com/pages/clinical-research> has many topics and components of human milk. Each reference that is clickable links to the same review article “Human milk composition: nutrients and bioactive factors,” a 2013 review article, available public access. No direct links to the many articles they are referencing. Clinical research based on one review article is not very strong research program.

d. What is missing from their research section is any research on:

how does consuming the milk elements in pill form impact its effectiveness?

how are these components impacted by whatever processes they use to extract them from the milk and put them in the pill form?

what do we know about how human milk in any form and pill form in particular impact adults?

I’m sure researchers, biologists and dieticians have other questions, these are the first ones that occurred to me.

e. Of course, it is possible, and even likely that human milk can have positive effects for adults in come circumstances, maybe even as a general supplement. But I don’t see indication of that on their website. To my knowledge there is very little research on impact of human milk on adults. I can imagine it has benefits, but also risks. It is nutrition/immuno protection and support/ growth factors for rapidly growing infants with immature GI and immune systems, not made for adult consumption.



I don’t know if this answers any of your questions, I hope it raises some questions.  The website is a piece of marketing, not science. It should be read that way.



Naomi









------------------------------------------

Naomi Bar-Yam Ph.D.

Director  Emerita

Mothers' Milk Bank Northeast



Past President

Human Milk Banking Association of North America



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cell: 617-599-2902

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@MMBNorthEast

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