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Baby Milk Action response to Department of Health Questions regarding commercial involvement in Start 4 Life  October 2010

 What would your criteria be for supporting the inclusion of an organisation as a Start4Life partner?

 In addition to the submission made on behalf of the Baby Feeding Law Group and the Breastfeeding Manifesto Coalition Baby Milk Action would like to make some additional comments regarding the consultation about Private Sector involvement with Start for Life.

The questions posed need to be rephrased. Baby Milk Action is not comfortable with being seen as supporting partnership with any for-profit company on any government health education scheme, especially on Start4Life. Our position has, from the start, been that the involvement of commercial companies in education schemes risks undue commercial influence of the messages being conveyed, increasing the likelihood that parents receive conflicting messages which are known to undermine the DH public health line.  We cannot stress enough the importance of  all governments taking seriously their responsibilities and obligations under the Global Strategy for Infant and Young Child Nutrition to provide truly objective, evidence-based information and support to parents.

The UK Coalition Programme for Government acknowledges the need to “take action to protect children from excessive commercialisation” and specifically to “crack down on irresponsible advertising and marketing, especially to children” an aim we fully support, but which we fear will be undermined if inappropriate partnerships are formed.  Indeed, in relation to corporations and NGOs or public health bodies we feel that the term ‘partnership’ is inappropriate and misleading -  ‘sponsorship’ or ‘interactions with the private sector’ would be better!

We recognise that the Government is anxious to address the financial deficit, but we feel strongly that this should not be used as an excuse to boost markets or reduce essential regulation at the expense of child health. If Start4Life is serious about addressing inequalities and reaching more disadvantaged mothers the DH should not be conveying messages that imply that good parenting requires the purchase of any particular product - and especially not unnecessary and potentially harmful ones.   The risks of inappropriate partnerships in the infant feeding arena far outweigh the financial benefits. As the National Institute for Clinical Excellence found -  a modest increase in breastfeeding rates would bring substantial savings. For example:

·        about 17,000 cases of otitis media would be avoided -  saving £509,000.

·       almost 3900 cases of gastroenteritis would be avoided -  saving of £2.6 million

·       over 1500 cases of asthma would be avoided - saving of £2.6 million 

If the DH has to seek alternative funding for its public health campaigns, it should first explore approaches used by other countries – raising revenue from sales tax of alcohol, tobacco, alcohol and junk food specifically for health education and protection.  Its been estimated that in the US a 1penny per ounce tax on sodas would raise about $150 bn and save health costs of at least $50 bn over a decade. The Thai Sin Tax on alcohol and tobacco already raises $100m per year for ThaiHealth Promotion.  

 Alternatively,  it could explore Trusts and Foundations – although this in itself has risks and is an abdication of its responsibilities under the GS.  It would be important to ensure that any such bodies  are not owned or in partnership with any of the companies excluded in Question 1 of the BMC/BFLG submission.  

 Only when all these avenues are exhausted should the DH consider taking funding from private companies. Although individual employees often have philanthropic motives, corporations themselves have a fiduciary duty to their shareholders to maximize profits, so will have multiple motives for becoming involved in such schemes. The DH link will inevitably be used to influence public aspirations, gain public trust and reposition the company in the public eye – diverting attention away from any continuing harmful practices.

 In due course we will be submitting a response to Question 4 about the Breastfeeding Welcome Scheme and this may provide a solution and a way forward for the Government to enlist and highlight the support of a wide range of commercial venues. However it will be vital to ensure that the messages contained in the two existing Start4life leaflets ‘Off to the best start’ and ‘Building Blocks’ and the Breastfeeding Welcome materials are not in any way influenced as a consequence of commercial involvement, nor should the DH integrity be jeopardized through the use of commercial logos etc