5th December 2012
Infant Feeding Guidelines for Health Workers
Senior Project Officer
Strategic Partnerships Section
NHMRC GPO Box 1421
CANBERRA ACT 2601
Via email: dietaryguidelines@nhmrc.gov.au
Dear Sir/Madam
We have reviewed elements of the Draft Infant Feeding Guidelines for Health Workers, and offer the
following comments for consideration. Our comments relate to various draft recommendations and
statements regarding different plant based foods.
Sanitarium as an organisation actively promotes a minimally processed or unprocessed plant based diet
(predominantly from vegetables, fruits, grains, legumes, nuts and seeds) as the ideal way to eat for optimal
health, as well as environmental sustainability, and there is significant scientific research to support this
approach. While Sanitarium also promotes the specific benefits of a lacto-ovo vegetarian style of eating,
our position at the population level is to encourage people to consume more plant-based foods, with a
corresponding reduction in animal-based foods. It is not to advocate for all Australian’s to adopt a
vegetarian diet.
Specific comments on the draft infant feeding guidelines
1. Recommendation – ‘Soy (except soy formula where specifically indicated), rice and other cereal
beverages are inappropriate alternatives to breast milk, formula or pasteurised whole cow’s milk in the
first two years of life’ (page 8).
While Sanitarium agrees that soy beverages are inappropriate alternatives to breast milk or infant
formula in the first 12 months of life, we question the draft recommendation that fortified soy
beverages are an inappropriate alternative to whole cow’s milk in the first two years of life. It is
unclear from the background literature review why soy beverages were considered inappropriate as an
alternative to whole cow’s milk by the authors, however we offer the follow comments to suggest that
fortified soy beverages are appropriate alternatives to whole cow’s milk after 12 months of age.
Nutritionally, most fortified soy beverages contain equivalent amounts of protein, calcium, vitamin
B12, phosphorus and riboflavin to whole dairy milk, as shown in the table below.
Australian Health & Nutrition Association Limited ABN 63 096 452 872 trading as Sanitarium Health & Wellbeing Company
1 Sanitarium Drive Berkeley Vale NSW 2261, Postal: Locked Bag 7, Central Coast Mail Centre, NSW 2252 Australia
T +61 2 4348 7777 W www.sanitarium.com.au
Nutrient Per 100mL
Energy (kJ)
Protein (g)
Fat (g)
Carbohydrate (g)
Sugars (g)
Calcium (mg)
Magnesium (mg)
Phosphorus (mg)
Potassium (mg)
Sodium (mg)
Zinc (mg)
Riboflavin (mg)
Niacin (mg)
Retinol (ug)
Vitamin B12 (ug)
Soy beverage, regular fat, Soy beverage, regular
Cow’s milk, regular
unflavoured, added Ca,
fat, unflavoured, added
fat
vitamins
calcium
293
260
254
3.5
4.2
3.8
3.5
2.8
2.8
6.3
4.8
4.8
6.3
2.7
2.7
107
119
119
10
22
22
92
71
71
142
198
198
37
45
45
0.35
0.16
0.16
0.218
0.424
0.031
0.26
0
0
50
124
7
0.6
0.9
N/A
Table 1. Nutritional profile of whole milk and various soy beverages, NUTTAB 2010
The suitability of fortified soy milk as a primary beverage for healthy growing infants over one year has
been recognised by the American Dietetic Association in their recent position statement on vegetarian
diets. In that they state ‘commercial, full-fat, fortified soymilk, or cow’s milk can be used as a primary
beverage starting at age 1 year or older for a child who is growing normally and is eating a variety of
foods’i.
The quality of soy protein has been rated as of a high quality, complete in nature and easily digestibleii.
In addition, studies of vegetarian eating patterns demonstrate that protein combining is not necessary,
as long as energy intake is adequate and a variety of plant foods are consumediii. Further,
recommended amino acid intakes for children aged 1 year and older are the same as those for adultsiv.
Sanitarium supports the recommendation that rice and other cereal-based beverages should not
replace whole dairy milk until after two years of age, due to the lower protein, energy and fortification
levels.
2. Special infant formulas
In relation to the naturally occurring isoflavone content of soy based infant formula, Sanitarium notes
that the infant guidelines accurately report that there are no clear clinical or scientific evidence to
support the position that these compounds are harmful, although there are no long term studies that
conclusively document the products safety in infants.
We wish to advise you of the recent publication of the National Institute of Environmental Health
Sciences report on the potential reproductive and developmental aspects of soy infant formula. Under
the National Toxicology Program (NTP), an expert panel was convened, comprising a 14 member panel
of government and non government scientists, to review the potential development effects of soy
based infant formula, incorporating more recent data. The updated conclusions of both the expert
panel and the NTP, was that there is minimal concern for adverse effects on development in infants
who consume soy infant formulav. This report provides further reassurance as to the safety of soy
based infant formulas for those infants unable to receive breast milk, or who for cultural, religious or
medical reasons, are unable to consume cow’s milk based infant formula.
3. Introducing spoon (solid foods) – practical aspects
While we do not have any comments in relation to the timing of foods recommended in Table IX.1 Developmental stages and examples of foods, Sanitarium strongly recommends that guidance on the
appropriate age of introducing legumes be included. There is an increasing interest in eating plant
based foods, and nutritionally, legumes provide a healthy balance of fibre, vitamins, minerals and
phytochemicals. Emerging evidence also demonstrates that eating legumes could contribute to a
reduced risk of chronic disease in later life. It is our belief that healthy eating practices need to be
encouraged early in life, and therefore, the omission of a specific inclusion of legumes is, in our
opinion, a significant oversight.
Foods such as tofu and cooked, dried lentils and peas and even baked beans, can be either easily
mashed or pureed and included in meals for infants.
Sanitarium suggests adding a specific recommendation to include legumes alongside
recommendations for animal based foods for both around 6 months and 8-12 months, as
‘well-cooked pureed liver, meat, poultry, or tofu, lentils and other peas/beans’ would be an
appropriate inclusion for the list of foods that can be included from around 6 months, and
‘Well-cooked fish, minced liver, meat, mashed tofu, lentils and other peas/beans’ would be an
appropriate inclusion for the list of foods that could be included from 8-12 months.
I hope that these comments are useful in revising the infant feeding guidelines. If you have any
questions, please do not hesitate to contact me at trish.guy@sanitarium.com.au
With kind regards
Trish Guy, APD
Corporate Nutrition Manager
Sanitarium Health & Wellbeing Company
i
American Dietetic Association, Position Paper of the American Dietetic Association: Vegetarian Diets, J Am Diet Assoc
2009;109:1266-1282.
ii
Rand WM, Pellett PL, Young VR. Meta-anlaysis of nitrogen balance studies for estimating protein requirements in
healthy adults. Am J Clin Nutr 2001;77:109-127
iii
American Dietetic Association, as above.
iv
Institute of Medicine, Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol,
Protein and Amino Acids, National Academies Press, Washington, D.C. 2005.
v
McCarver G et al, NTP-CERHR expert panel report on the developmental toxicity of soy infant formula, Birth Defects
Res B Dev Reprod Toxicol, 2011;Oct;(92(5):421-468.