Australian National Breastfeeding Strategy 2010-2015

3.7 Other complex issues

Page last updated: 15 July 2010

Numerous other complex issues are associated with the breastfeeding environment in Australia. These issues, all of which were examined in The Best Start inquiry, include human milk banks, growth charts, and the marketing of infant formula (HoR 2007). These issues remain on the Australian National Breastfeeding Strategy agenda but do not lend themselves to immediate solutions. The governance structure for the Australian National Breastfeeding Strategy, outlined in Chapter 5, identifies the need for these issues to be thoroughly addressed in the implementation plan.

Human milk banks and associated regulatory issues

A human milk bank is a service that collects, screens, processes, and distributes donated human milk, primarily for sick and premature babies who cannot be breastfed (HoR 2007).

Human breast milk sharing both informally and on a more organised basis was a known practice in Australian maternity wards since the 1940s. In the 1980s, concern about the spread of HIV led to the discontinuation of milk banks in Australia. Human milk banking re-emerged in Australia in 2006. Facilities currently exist at King Edward Memorial Hospital in Western Australia and on the Gold Coast in Queensland. It is understood that milk banks are under consideration in other jurisdictions.

It is important that milk banks are well managed, with good risk management and quality control. Existing Australian milk banks are known to have done significant work on establishing quality management processes. However, there is no specific Australian regulatory framework for human milk banks. At the Australian Government level human breast milk is regarded as a food rather than a therapeutic good. However variations between state and territory legislation such as food laws and human tissue acts create regulatory uncertainty.

As part of its response to The Best Start inquiry, the Australian Government acknowledged the need for risk management and quality control for human milk banks and, in the context of developing an Australian National Breastfeeding Strategy, undertook to work with states and territories to consider the evidence, quality assurance and regulatory issues, including the existing best practice guidelines developed by the PREM Bank at King Edward Memorial Hospital in Perth. This work will be progressed under the implementation plan and governance arrangements for the Australian National Breastfeeding Strategy.

Growth charts

Growth charts are widely used as a clinical and research tool to assess nutritional status and the general health and wellbeing of infants, children, and adolescents (HoR 2007). There is concern from breastfeeding advocates about the current growth charts being used in Australia. Often exclusively breastfed infants do not put on weight at the same rate or level as formula fed infants and they may appear to be ‘underweight’ when in fact the growth rate is healthy for an exclusively breastfed baby.

Debate exists over the best growth charts to use. Some states and territories use the 2000 US Centre for Disease Control growth charts recommended by the NHMRC 2003 Clinical Practice Guidelines for the Management of Overweight and Obesity in Children and Adolescents. Some advocates have recommended that Australia adopt WHO standards developed in 2006 based on the breastfed child as the biological norm for growth and development. There is concern amongst some experts that the WHO growth charts represent an optimal growth pattern, and a heavier weight than the current charts, which could lead to unnecessary supplementation of some infants.

The Best Start inquiry recommended that Australian Health Ministers decide on a standard infant growth chart to be used in all states and territories (HoR 2007). In the Australian Government’s response to the inquiry, it was agreed in principle that infant growth charts will be considered as part of the Australian Government’s review of the Dietary Guidelines for Children and Adolescents in Australia incorporating the Infant Feeding Guidelines for Health Workers; and that the Australian Government will subsequently consult with state and territory governments about the merits of adopting a single, evidence based population level reference for use as a growth monitoring tool, and the need for appropriate education and explanatory materials to ensure growth charts are interpreted appropriately.

The merits of adopting a single, evidence-based population level reference for use as a growth monitoring tool will require significant state and territory and stakeholder consultation. This work will be included in the implementation plan for the Australian National Breastfeeding Strategy.

The marketing of infant formula in Australia

Australia currently has several measures in place to implement the WHO Code:
  • The Marketing in Australia of Infant Formulas: Manufacturers and Importers Agreement (MAIF Agreement), a voluntary, self-regulatory code of conduct between manufacturers and importers of infant formula in Australia. All major manufacturers and importers of infant formula are parties to the MAIF Agreement. Compliance with the agreement is monitored by the Advisory Panel on the Marketing in Australia of Infant Formula (APMAIF), a non-statutory panel appointed by the Australian Government.
  • Mandatory labelling and composition provisions for infant formula, consistent with Article 9 of the WHO Code, contained in the Australia New Zealand Food Standards Code (FSANZ).
  • The NHMRC Dietary Guidelines for Children and Adolescents in Australia incorporating the Infant Feeding Guidelines for Health Workers include guidance for health workers on interpreting the WHO Code in Australia.
With respect to these measures, it is important to note that:
  • The Australian Competition and Consumer Commission’s authorisation of the MAIF Agreement will expire on 31 December 2015 (ACCC 2007). This will allow scope for a review of the MAIF Agreement prior to any re-authorisation which may be sought at that time.
  • Following a recent public consultation process, a draft policy guideline for the regulation of infant formula products will be considered by the Food Regulation Standing Committee and is expected to be considered by the Australia and New Zealand Food Regulation Ministerial Council in the first half of 2010.
  • The Australian Dietary Guidelines, including the Infant Feeding Guidelines for Health Workers, are currently under review with release expected in 2011.
The Best Start inquiry recommended the Australian Government adopt in full the WHO’s International Code of Marketing of Breast-milk Substitutes and subsequent WHA resolutions (HoR 2007). The Australian Government’s response to the inquiry noted the recommendation and stated that the Australian Government would consider Australia’s response to the WHO Code in the context of developing an Australian National Breastfeeding Strategy. This will be progressed under the implementation plan and governance arrangements for the Australian National Breastfeeding Strategy and with respect to the development of the infant formula policy guidelines and revision of the Infant Feeding Guidelines for Health Workers.