I just sent this submission to the NHMRC. 
Submissions close tomorrow. Other Aussies might also like to tell them what they think.
Karleen Gribble
Australia

Dear Sir/Madam

I am writing to express my concern at the recommendations outlined in the NHMRC's Australian Alcohol Guidelines for Low-Risk Drinking draft paper with regards breastfeeding women. I will briefly outline my concerns below.

1. The recommendations are the same for pregnant and breastfeeding women and the way in which the recommendations are couched suggests that the risk of drinking while breastfeeding is the same as drinking while pregnant. The recommendations consistantly refer to "pregnant and breastfeeding women" as if the risk is the same. This is clearly not the case. There is an abundance of evidence that alcohol consumption during pregnancy carries a high level of risk and has the potential for serious consequences for the unborn child. However, there is very little evidence of any harmful effects of moderate drinking on breastfeeding infants and young children. There is also a large difference in level of exposure between situations where mothers are drinking during pregnancy or while breastfeeding and the recommendations do not make this clear. The recommendations thus, have the potential to mislead individuals and have unintended consequences. Mothers who seek information on alcohol consumption while breastfeeding from their health provider or drug information lines will be told that moderate consumption is safe. The American Academy of Pediatrics categorises alcohol as a drug that is approved by use in breastfeeding women and the most commonly used text on drugs and breastfeeding categorises alcohol consumption during pregnancy as Category D- stating that there is positive evidence of risk and consumption during breastfeeding as L3- moderately safe . Mothers may conclude that since NHMRC has overstated the case with regards alcohol consumption during breastfeeding that they have done similarly in relation to alcohol consumption while pregnant.  The level of exposure to alcohol and the impact of that exposure on the child if mothers consume alcohol while pregnant is very, very different to that if mothers consume alcohol with breastfeeding. The recommendations should make this clear and separate recommendations and discussion of the recommendations of consumption of alcohol while pregnant or while breastfeeding into two distinct sections. It is completely inappropriate for them to be presented together.

2. The recommendations do not include any discussion of how to reduce the exposure of infants and young children to alcohol in breastmilk. It is impossible for a pregnant woman to reduce her baby's exposure to alcohol if she drinks but it is entirely possible for a breastfeeding woman to reduce or even eliminate her infant's exposure. The recommendations should include a discussion of how to minimise exposure to alcohol while breastfeeding as well as a discussion of the vulnerability of children to the small amount of alcohol that may be contained within breastmilk if a mother has consumed alcohol (for instance that the potential risk is greater with a 2 week old baby than an 18 month old toddler).

3. The recommendations do not include a discussion of relative risk of cessation of breastfeeding or use of infant formula if a mother has consumed alcohol. I am very concerned that the NHMRC recommendations will lead to breastfeeding women "playing it safe" and using infant formula if they have consumed alcohol believing that this is the less risky option. As previously stated, there is very little evidence of harm caused to breastfeeding infants by their mothers consuming moderate amounts of alcohol however, there is an abundance of evidence that cessation of breastfeeding or use of infant formula (even in small amounts) has a host of negative effects on infants. The recommendations need to make it clear that in all but the most extreme of cases the safest option to infants is for mothers to continue breastfeeding and not to use infant formula if they have consumed alcohol. 

Regards

Karleen Gribble

Dr Karleen D Gribble BRurSc PhD
Adjunct Research Fellow
School of Nursing
University of Western Sydney






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