Congressional Testimony on the Child Nutrition Act Reauthorization

Written by Weston A. Price Foundation

2003-Mar-23

Summary of Recommendations

Enhance WIC Program

Encourage breastfeeding over the use of infant formula
Restrict the availability of soy infant formula for WIC mothers; require a doctors prescription
Further upgrade the enhanced food package for breastfeeding WIC mothers to include butter as well as additional milk, cheese, eggs and meat
Upgrade WIC food packets to reflect the latest nutritional thinking that stress high quality foods from four groups which help stem obesity

Encourage Procurement of Local Farm Products For School Food Programs

Continue support for Farm-To-School food programs
Extend and expand Fruit and Vegetable School Pilot Program
Include animal foods in farm procurement programs

Ban Sale of Soft Drinks and Snack Foods in School Vending Machines

Soft drinks contain high levels of sugar or artificial sweeteners, caffeine and phosphoric acid, that contribute to obesity, diabetes and poor bone health in growing children – replace soft drinks with bottled water, milk, low fructose fruit juices
Replace vending-machine snacks with wholesome snacks prepared at the school and sold in school snack bars

Ban Irradiated Foods in USDA's School Lunch Program

Repeal section 4201(b)(3) of the 2002 Farm Bill so that the USDA may prohibit irradiated foods for use in School Lunch Program
Irradiation disrupts the chemical composition of food and creates chemicals called unique radiolytic products that are not naturally occurring in foods and that the Food and Drug Administration (FDA) has never studied for safety

Recommendations for the Reauthorization of the Child Nutrition Act

House Education and Workforce Committee

Submitted by the Weston A. Price Foundation
Sally Fallon, President
July, 2003

Mr. Chairman and the Ranking Minority Member, on behalf of the members and 170 local chapters of the Weston A. Price Foundation, we thank you for the opportunity to submit our recommendations to the House Education and Workforce Committee on the serious health issues facing our children today, particularly the rapidly growing incidence of obesity in American children. The reauthorization of the Child Nutrition Act is a very important step in curbing this unnecessary health risk while enhancing the nutrition and well being of our children.

The Weston A. Price Foundation is a nonprofit, tax-exempt nutrition education organization founded in 1999 to restore nutrient-dense foods to the American diet through education, research and activism. The research of nutrition pioneer Dr. Weston Price, whose studies of isolated non-industrialized peoples established the parameters of human health and determined the optimum characteristics of human diets, serves as the basis of the Foundation's work. Dr. Price's research demonstrated that humans achieve perfect physical form and optimal health generation after generation only when they consume nutrient-dense whole foods and the vital fat-soluble activators, such as vitamins A and D, found exclusively in animal foods.

The Foundation supports a number of movements that contribute to this objective including accurate nutrition instruction, organic farming, pasture feeding of livestock, community-supported farms, honest and informative labeling, prepared parenting and nurturing therapies.

Our recommendations will focus attention on the Women, Infant and Children (WIC) Program and the School Meal Programs.

I. Women, Infant, and Children (WIC) Program

The Congress established the WIC Program in 1972 as a two-year pilot program with permanent authorization in 1974. The stated goal of the program was the prevention of nutritional deficiencies among low-income women and children, deficiencies that threatened their health and led to higher medical costs. WIC offers food programs to improve the diets and well being of low-income pregnant, breastfeeding, and postpartum women and their infants and children up to and including age four. WIC seeks to prevent premature births and low birth weight babies as well as compromised development among babies and young children.

WIC is a $5 billion program serving over seven million women and children. Nearly 50 percent of all infants in the U.S., 25 percent of all children age one to four and 25 percent of all pregnant women participate in the WIC program.

Encourage Breastfeeding Over the Use of Infant Formula

One of the stated purposes of the WIC program is the encouragement of breastfeeding. Unfortunately, this laudable goal has become compromised by the increased availability of free infant formula to WIC mothers. Free infant formula--with a market value of approximately $80 to $90 per month--sends a powerful message to WIC mothers to utilize infant formula, especially to those WIC mothers who work and have less available time to breastfeed.

Between 1989 and 1995, the percentage of WIC mothers breastfeeding in the hospital increased by 36.3 percent, from 34.2 to 46.6 percent, while the percentage for non-WIC mothers breastfeeding in hospital increased by 12.9 percent from 62.9 to 71 percent. The percentage of WIC infants breastfeeding at six months of age increased by 51.2 percent, from 8.4 to 12.7 percent, while for non-WIC infants, the percentage breastfeeding at six months of age was 29.2 percent in 1995, an increase of 22.7 percent from 1989. While the number and percentage of WIC mothers who breastfeed has increased in recent years, breastfeeding in the WIC program still lags behind national averages. Over half of WIC mothers utilize infant formula while in the hospital and about 87 percent use infant formula or other feeding methods when their infants reach six months of age.

While many individual WIC counselors encourage breastfeeding, the infant formula rebate program provides little incentive to managers of the program. Rebates from formula manufacturers have provided billions of dollars of extra funding to WIC with little Congressional oversight. WIC State agencies are required by law to have competitively bid infant formula rebate contracts with infant formula manufacturers. This means that a WIC State agency agrees to provide one brand of infant formula to its participants and in return receives money back, called a rebate, from the manufacturer for each can of infant formula purchased by WIC participants. As a result, WIC pays the lowest possible price for infant formula. The brand of infant formula provided by WIC varies from State agency to State agency, depending on which company has the rebate contract in a particular State.

In 1988, infant formula rebates provided WIC with $32 million in additional funding. This has grown to $1.5 billion in FY2001, which added 2.1 million participants to the program during that same fiscal year. Up to one-fourth of available funding for the WIC program comes from the infant formula rebate program. The rebate program decreases the monthly average food package cost to infants from the $90 to $27. While the extra funding for the WIC program is surely needed, we wonder whether the rebate program inadvertently undermines the promotion of breastfeeding in the WIC program.

We encourage the USDA to increase its promotion of breastfeeding as research continually shows that breastfeeding is the healthiest way to nurture an infant. This can be done by withholding free samples of infant formula to postpartum mothers in the hospital and by increased health counseling to pregnant and postpartum mothers about the benefits of breastfeeding.

In 1993, the USDA began efforts to enhance the food package breastfeeding mothers to, in part, counter the use of infant formula. In addition to the basic package – Food Package V - for pregnant and breastfeeding mothers (7 gallons milk or 4 pounds cheese, 2 dozen eggs, 36 ounces cereal, 8 liters juice and 1 pound legumes or 18oz. peanut butter), breastfeeding mothers can receive an additional 1 pound cheese, 26 ounces tuna fish, extra juices and peanut butter and 2 pounds carrots under the enhanced food package – Food Package VII. We encourage the USDA to further upgrade the enhanced food package to include butter as well as additional milk, cheese, eggs and meat.

Restrict Availability of Soy Infant Formula

The WIC program offers both milk-based and soy-based infant formula to low-income families throughout the US. An estimated 25 percent of North American bottle-fed babies receive infant formula made from processed soybeans. Use of soy formula in the WIC program closely corresponds to the 25 percent figure, according to the USDA.

Soy promotional material claims that soy provides complete protein that is less allergenic than cows' milk protein. When soy infant formula first became commercially available, manufacturers even promised that soy formula was "better than breast milk."

In fact, there are many toxins in soy infant formula, some that occur naturally in the soybean and some that are added during processing. When an infant consumes soy-based formula as its only food, it receives a very large dose of these toxins. Even in Asia, soy is consumed only in small amounts--ranging from 10 to 60 grams per day--usually as a fermented condiment. Soy was never traditionally used for infant feeding.

Soy-based formulas contain high levels of anti-nutrients that can block mineral absorption and inhibit digestion. They contain very high levels of manganese, which have recently been linked to brain damage and violent behavior in older children and adults who were fed soy formula. Developmental problems are compounded by the fact that these formulas lack both cholesterol and lactose, which are vital to the development of the brain and nervous system.

Most importantly, soy-based formula contains very high levels of phytoestrogens (isoflavones), plant-based estrogens that can cause endocrine disruption, resulting in early maturation and fertility problems in girls and delayed sexual development in boys.

Babies fed soy-based formula have 13,000 to 22,000 times more estrogen compounds in their blood than babies fed milk-based formula. Infants exclusively fed soy formula receive the estrogenic equivalent of at least five birth control pills per day. Almost 15 percent of white girls and 50 percent of African-American girls show signs of puberty, such as breast development and pubic hair, before the age of eight. Some girls are showing sexual development before the age of three. Premature development of girls has been linked to the use of soy formula and exposure to environmental estrogen-mimickers such as PCBs and DDE.

Male infants undergo a "testosterone surge" during the first few months of life, when testosterone levels may be as high as those of an adult male. During this period, baby boys are programmed to express male characteristics after puberty, not only in the development of their sexual organs and other masculine physical traits, but also in setting patterns in the brain characteristic of male behavior. In animals, soy feeding indicates that phytoestrogens in soy are powerful endocrine disrupters. A recent study involving marmoset monkeys found that soy feeding in infancy prohibits this testosterone surge. Rats exposed to soy isoflavones at very low doses in utero and as infants have smaller testes than normal and exhibit inhibited sexual behavior.

Soy is not a healthy alternative for infants unable to tolerate milk-based formula. Often babies grow normally on soy formula with the problems appearing only later, at the onset of puberty. Some of the problems reported anecdotally in children who were brought up on soy formula include extreme emotional behavior, learning difficulties, asthma, immune system problems, irritable bowel syndrome, depression, early development in girls and disrupted sexual development boys.

Often soy-based formula is automatically given to African American mothers on the premise that African American infants are lactose intolerant. This is a fallacy. African American infants are no more prone to lactose intolerance than the children of other races. Virtually all babies produce the enzyme lactase for digesting lactose, the sugar in milk, as human milk is very high in lactose.

Babies who are allergic to milk can be given a commercially available formula of hydrolyzed protein or one based on meat. We suggest that USDA encourage the development of meat-based infant formulas for the small numbers of infants who are truly allergic to milk-based formula.

A summary of problems caused by soy is as follows:

High levels of phytic acid in soy reduce assimilation of calcium, magnesium, copper, iron and zinc. Phytic acid in soy is not neutralized by ordinary preparation methods such as soaking, sprouting and long, slow cooking. High phytate diets have caused growth problems in children.
Trypsin inhibitors in soy interfere with protein digestion and may cause pancreatic disorders. In test animals soy containing trypsin inhibitors caused stunted growth.
Soy phytoestrogens disrupt endocrine function and have the potential to cause infertility and to promote breast cancer in adult women.
Soy phytoestrogens are potent antithyroid agents that cause hypothyroidism and may cause thyroid cancer. In infants, consumption of soy formula has been linked to autoimmune thyroid disease.
Vitamin B12 analogs in soy are not absorbed and actually increase the body's requirement for B12.
Soy foods increase the body's requirement for vitamin D. Toxic synthetic vitamin D2 is added to soy milk.
Fragile proteins are over-denatured during high temperature processing to make soy protein isolate and textured vegetable protein.
Processing of soy protein results in the formation of toxic lysinoalanine and highly carcinogenic nitrosamines.
Free glutamic acid or MSG, a potent neurotoxin, is formed during soy food processing and additional amounts are added to many soy foods.
Soy foods contain high levels of aluminum which is toxic to the nervous system and the kidneys.
Soy infant formula contains no cholesterol, a substance vital to the development of the brain and nervous system.

In other countries, official recommendations about soy have included warnings about overuse or side effects:

The Australian College of Pediatrics recommends that soy formula not be indiscriminately used, noting that the routine use of soy may result in side effects.
The New Zealand Ministry of Health recommends routine assessment of thyroid function in infants on soy formula.
A Canadian Government Committee recommends the restriction of soy-based formula to infants who "cannot be fed dairy-based products for healthy, cultural or religious reasons, including galactosemia or a vegan lifestyle."
The Food Safety Authority of Ireland does not recommend the routine use of soy-based formula in infants.
The Swiss Federal /Commission on Food recommends the "use of soya bean products as baby foods should be made very restrictive" and allowed only in a few medical conditions (lactose intolerance, galactosemia and cow's milk allergy).
The United Kingdom Department of Health states that cow's milk formulas are preferable for most bottle-fed babies and that infant formula manufacturers should investigate ways to reduce the levels of phytoestrogens in soy-based infant formulas.
The UK Working Group of the Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment COT) recently stated that "there is cause for concern about the use of soy-based infant formula. Additionally, there is neither substantive medical need for, nor health benefit arising from, the use of soy-based infant formula." (2003)

We recommend that the Congress to restrict the availability of soy infant formula in the WIC Program. Soy infant formula should be available to WIC mothers only through a doctor's prescription (see attached amendment).

In addition, processed foods based on soy should carry a warning to consumers about possible endocrine disruption and thyroid problems.

Redesign WIC Food Packages to Help Counter Overweight and Obesity

Obesity is on the rise in America, especially among disadvantaged groups. African-American and Mexican-American children are twice as likely as non-Hispanic white children to have a body mass index of more than 25, the definition of overweight. In the last three decades, the number of overweight young Americans has tripled, with no sign the trend is abating. According to the Surgeon Generals' 2001 report on obesity, 13 percent of children and adolescents were overweight in 1999.

WIC food packages were originally designed to help stave off hunger among its participants. The current prevalence of overweight and obesity among WIC participants now requires that WIC food packages be redesigned to help curb this health issue.

WIC food packages are established by the USDA through regulations with the approval of the Institute of Medicine of the National Academies, which develops Recommended Daily Allowance (RDA) and the new Dietary Reference Intakes (DRI) for nutrients. The current WIC food package is under review and revisions will be released in early 2005, according to the USDA. Concurrently, the USDA is revising its Dietary Guidelines and Food Pyramid with expected release of new guidelines in 2005. WIC food packages must conform to the requirements of USDA's Dietary Guidelines and Food Pyramid.

The current USDA Dietary Guidelines and Food Pyramid recommends a diet based largely on grains in the form of bread, crackers, paste, rice, etc., with small amounts of meat, dairy and fats and oils. In fact, the current Guidelines strongly favor a low-fat, high-carbohydrate diet. The current Guidelines stipulate that total fats should make up 30 percent or less of total calories, with saturated fats contributing to 10 percent or less of total calories. Carbohydrates should comprise between 45 to 65 percent of food intake by calories. These guidelines have been criticized as contributing to the epidemic of obesity in America, due to high levels of carbohydrates, particularly high glycemic index refined carbohydrates such as white flour and white rice.

Pediatrician clinicians have noted a number of years ago that children put onto a low fat and low cholesterol diets failed to grow properly. When researchers prominently associated with the American Heart Association fed children lower fat diets and measured some of the health markers they consider important predictors of heart disease, they learned that these lower fat diets were causing the very problems they wanted to prevent. The children whose genes would normally have been producing the desirable form of low density lipoproteins - light fluffy LDL - started to make the dangerous form of LDL - small dense LDL's.

The USDA has called for proposals to make changes to the Food Pyramid recommendations.

The most likely candidate is a food pyramid recommend by Dr. Walter Willett of Harvard University. His version calls for a diet based on a combination of whole grains and vegetable oils (olive, canola, soy, corn, etc.), with the same strictures on animal foods and saturated fats as found in the current guidelines.

Dr. Willett's proposed guidelines are likely to further the trend to obesity and disease. With the exception of olive oil (which is rarely used in processed foods), commercial vegetable oils contain free radicals and dangerous breakdown products that cause heart disease, cancer, inflammation and aging, as well as increased obesity. In the young, diets based on vegetable oils depress learning and cause growth problems. Furthermore, these oils are often partially hydrogenated and contain dangerous trans fatty acids. Over 30 years of research has shown that consumption of trans fatty acids from partially hydrogenated vegetable oils and fats have many adverse heath effects such as heart disease, cancer, diabetes, immunity issues, reproduction and lactation, and obesity. Trans fatty acids are typically found in processed foods that utilize partially hydrogenated vegetable oils.

We recommend that the Food Pyramid concept should be abandoned. The USDA should return to a plan that stresses high quality foods from four basic groups. The use of processed and highly sugared foods should be strongly discouraged, especially those foods that contain high fructose corn syrup.

In addition, USDA should discontinue the unscientific opposition to animal fats. Animal fats are stable, do not easily develop free radicals, and contain nutrients that are vital for good health. Children, in particular, need high levels of quality animal fats to achieve optimal physical and neurological development.

The Weston A. Price Foundation urges the USDA as well as the Congress to revise the dietary guidelines as follows:

Everyday, eat high quality, unprocessed foods from each of the following four groups:
1. Animal foods: meat, fish, eggs and whole milk products
2. Grains and legumes: whole grain baked goods, breakfast porridges, beans
3. Fruits and Vegetables: preferably fresh or frozen
4. Fats and Oils: unprocessed monounsaturated and saturated fats including olive oil, peanut oil, butter and other animal fats, palm oil and coconut oil.
Eat sparingly: sweets, white flour products, processed foods, polyunsaturated vegetable oils, partially hydrogenated oils and fried foods.

We believe that by following our recommendations to the dietary guidelines and modifying WIC food packages to conform to these recommendations, overweight and obesity, as well as many other health problems, will dramatically decrease in the country.

II. Revisions to the School Meal Programs

The USDA manages a number of nutrition programs for our nation's children, including the School Lunch, School Breakfast, Special Milk, Summer Food Service and the Child and Adult Care Programs. Over 30 million of our nation's children particpate in these various programs. We urge the Congress to at least maintain current funding levels for these very important programs, while revising several of the program offerings as follows:

Encourage Procurement of Local Farm Products for School Food Programs
According to latest statistics, less than 13 percent of school-age children eat the recommended amount of fruit. On any given day, 45 percent of children do not eat any fruit and 20 percent eat less than one serving of vegetables. Overall, only 15 percent of our children eat the USDA-recommended five servings a day of fruits and vegetables.

The American School Food Service Association estimates that 30 percent of the nation's 23,000 public schools sell fast food. In an increasing number of schools, the food service department is contracting out lunch to fast food chains such as McDonalds, Domino's or Taco Bell.

However, a growing number of food service departments at schools across the U.S. have been joining forces with parents, teachers, community activists, and farmers to create new opportunities for healthy student lunch offerings while simultaneously supporting small farmers within their region. These Farm-to-School programs usually include the following:

Salad bars purchased from farmers' market fruits and vegetables
Recipes integrating appropriate seasonal, regionally grown produce
Farmer cooperatives supplying produce directly to school districts
Farmers selling produce directly to schools using programs sponsored by the USDA and the Department of Defense

Farm-to-School programs help ameliorate this situation by promoting the procurement and availability of locally grown fruits and vegetables. At least 68 school districts around the country currently operate farm-to-school programs with many more planning to do so in 2003.

We are encouraged by early reports on the wide spread acceptance of the Fresh Fruit and Vegetable Pilot Project authorized by the 2002 Farm Bill. The USDA launched the pilot in the summer of 2002 in four midwestern states and the Zuni Nation. Participating schools, which numbered 106, reported dramatic increase in consumption of fruits and vegetables by students and, most interestingly, a dramatic drop in the use of vending machines. We encourage the Congress and the USDA to extend and expand the Fresh Fruit and Vegetable Pilot Project to the entire country.

We suggest that Fresh Fruit and Vegetable Pilot Project include animal foods (meats, eggs and dairy products) as well as fruits and vegetables. It is vitally important for children to have access to hormone-free meats from cattle not raised in confinement or on factory farms, free range chickens and eggs and dairy products from cows that are not fed antibiotics and raised in confinement. The program should also be used to discourage the use of industrially created processed foods in children's diets.

In addition, soy milk is not a healthy option to cow's milk. Consumption of high levels of soy milk is associated with thyroid problems and endocrine disruption. The USDA should not reimburse schools that decide to offer soy milk as well as cow's milk.

Encouraging the growth of farm-to-school programs would go a long way to help stem the growth of obesity and other health problems in our nation's children.

Ban Sale of Soft Drinks and Processed Snack Foods in School Vending Machines

The Weston A. Price Foundation encourages the Congress to call for a ban on the sale of soft drinks and snack foods in school vending machines. Soft drinks contain high levels of sugar or artificial sweeteners, caffeine and phosphoric acid that contribute to obesity, diabetes and poor bone health in growing children. One can of soda contains approximately 10 teaspoons of sugar, 150 calories, 30 to 55 mg. of caffeine, and is loaded with artificial food colors and sulphites. Aspartame is used as a sugar substitute in diet soda. There are over 92 different health side effects associated with aspartame consumption including brain tumors, birth defects, diabetes, emotional disorders and epilepsy/seizures. Further, when aspartame is stored for long periods of time or kept in warm areas it changes to methanol, an alcohol that converts to formaldehyde and formic acid, which are known carcinogens.

Studies have linked soda to osteoporosis, obesity, tooth decay and heart disease. Despite this, soda accounts for more than one-quarter of all drinks consumed in the United States.

Teenagers and children, who many soft drinks are marketed toward, are among the largest consumers. In the past 10 years, soft drink consumption among children has almost doubled in the United States. Teenage boys now drink, on average, three or more cans of soda per day, and 10 percent drink seven or more cans a day. The average for teenage girls is more than two cans a day, and 10 percent drink more than five cans a day.

School districts, hungry for funds for extra-curricular programs, have signed "pouring" contracts with soft drink corporations, giving these corporations the ability to both sell and promote their products at the schools. There are an estimated 20,000 vending machines in schools nationwide, according to the National Automatic Merchandising Association. These machines generated an estimated $750 million for schools in 1997, based on figures from the trade journal Vending Times. Many schools have expressed a reluctance to give up such contracts without other sources of funding made readily available.

The USDA collected data on vending machines in schools and reported the following statistics:

88 percent of high schools, 61 percent of middle schools and 14 percent of elementary schools have food or beverage vending machines for student use.
34 percent of high schools and 15 percent of middle schools permit students to use school vending machines at any time, and 6 percent of elementary schools allow students to use vending machines during lunch.

Nationwide, school districts decreased the amount of milk they bought by nearly 30 percent between 1985 and 1997. During the same period, they increased their purchases of soft drinks by 1,100 percent. The soda industry responded to this and other trends by increasing U.S. production from 22 to 41 gallons per person a year between 1970 and 1997.

To counter this trend, seventy-six proposed bills in 28 states have attempted to restrict or ban the sale of carbonated soft drinks in schools. Only one, in California, passed, but it has not been enacted because the law also has requirements for school lunch funding that have not been fulfilled. Among the bills just being written or introduced are ones that would stop the sale of soft drinks in school vending machines, put restrictions on the kinds of snack foods that can be offered, require fast-food restaurants to put nutrient information on food packages, and allocate funds for bike and walking paths.

Snack foods sold in vending machines provide little food value and contain trans fatty acids, which can contribute to heart disease, cancer and many other diseases. We urge the replacement of vending-machine snacks with wholesome snacks prepared at the school and sold in school snack bars. Such snacks should include fruit, cheese, peanut butter, sandwiches, nuts and trail mix, cookies made with wholesome ingredients, and popcorn.

Schools that have replaced soft drinks and processed snack foods with water and fruits and vegetables have found high acceptance among students with little or no attendant loss in revenues.

Ban Irradiated Foods in the School Lunch Program

The Weston A. Price Foundation strongly encourages the Congress to repeal section 4201(b)(3) of the 2002 Farm Bill so that the USDA may prohibit irradiated for use in School Lunch Program. Recently, the USDA issued a statement that school districts may purchase irradiated meats under the auspices of the School Lunch Program. Guidelines are to be published in the fall of 2003 outlining the purchase process, which is not mandatory. The Foundation is actively working with its members to educate school districts and PTA's about the detrimental health effects of irradiated foods.

We believe that irradiated food has not been proven safe, particularly for children. Irradiation disrupts the chemical composition of food and creates chemicals called unique radiolytic products that are not naturally occurring in foods and that the Food and Drug Administration (FDA) has never studied for safety.

Irradiation destroys vitamins, essential fatty acids and other nutrients in food. Research has revealed a wide range of health issues in animals given irradiated foods including genetic damage, organ malfunctions, stillbirths, premature death, a rare form of cancer, low weight gain and vitamin deficiencies.

There is a lack of research into the long-term health effects experienced by children who are exposed to toxic chemicals in foods. The only controlled study of children, published in 1975 in the American Journal of Clinical Nutrition, found that a diet of irradiated food had mutagenic effects. Studies on children have not been done since, primarily for ethical reasons because of the dangers seen in early studies.

New research from Europe on alkylcyclobutanones, one class of unique chemicals created during the irradiation process, has further indicated the need for caution. The FDA and the USDA have never publicly addressed this new toxicity information. Yet, these European studies establish that substances unique to irradiated foods cause cellular and genetic damage and promote colon tumor formation in rats.

In addition, irradiation merely masks problems in meat processing that result in contaminated meat. Poor sanitation and improper slaughter and processing practices in meat and poultry plants must be corrected, otherwise all consumers remain at risk. It is a mistake to accept food irradiation as a solution to food contamination problems within the industry.

Lastly, the USDA does not require that parents, students or teachers be informed that school meals have included food that has been irradiated. Parental right–to-know is of essence to an informed society.

Do not subject our children to unproven technologies. They do not deserve to be guinea pigs for the irradiation industry.

~~~~~~~~~~~~~~~~~~~~~~~~

The Weston A. Price Foundation thanks you for the opportunity to present our recommendations on the reauthorization of the Child Nutrition Act. The Congress has an incredible opportunity to help stem the tide of obesity in this country while improving the nutrition and health of our children.

If you have any further questions, please contact Sally Fallon at info (at) westonaprice.org or by phone at 202-363-4394. Our very informative and educational website can be found at www.westonaprice.org.

WESTON A. PRICE FOUNDATION
PMB 106-380, 4200 WISCONSIN AVENUE, NW WASHINGTON, DC 20016
(202) 363-4394
WEBSITE: www.WestonAPrice.org
EMAIL: info (at) westonaprice.org

Amendment to the Child Nutrition Act of 1966, as amended

Restrict the Availability of Soy Infant Formula to Mothers with Infants Participating in the WIC Program

Amendment:

Section 17(f)(12) of the Child Nutrition Act of 1966 is amended by adding at the end of the paragraph the following sentence, "Soy infant formula shall be made available to infants of non-breastfeeding mothers only by prescription from physicians as defined in section (17)(b)(3)."

Rationale:

The WIC program offers both milk-based and soy-based infant formula to non-breastfeeding mothers of infants. An estimated 25 percent of North American bottle-fed babies receive infant formula made from processed soybeans. Use of soy formula in the WIC program closely corresponds to the 25 percent figure, according to the USDA.

There are many toxins in soy infant formula, some that occur naturally in the soybean and some that are added during processing. When an infant consumes soy-based formula as its only food, it receives a very large dose of these toxins. Even in Asia, soy is consumed only in small amounts--ranging from 10 to 60 grams per day--usually as a fermented condiment. Soy was never traditionally used for infant feeding.

Six countries including Canada, the U.K and Australia have issued official recommendations about soy that included warnings about overuse or side effects.

Babies who are allergic to milk can be given a commercially available formula of hydrolyzed protein or one based on meat.

There is no added cost associated with this amendment. The WIC program provides for physician review of medical cases.

School Children Require Whole Milk for Optimal Development

Reduced Fat Milks Compromise Human Development

The milk of all mammals contains high levels of fat. Nature does not make mistakes; mammalian milk contains fat because young animals and young humans need this fat to develop and grow properly.
The butterfat in milk contains vital fat-soluble vitamins needed for the utilization of the protein and minerals in the water fraction of the milk. Butterfat in milk works synergistically with the protein and minerals in milk.
Butterfat provides glycosphingolipids that aid digestion¹ and CLA that helps prevent cancer and obesity.²
Obesity is an ever increasing problem in our young people. Farmers know that the best way to fatten pigs is to give them skim milk--pigs fed whole milk do not get fat. The metabolism of the pig is very similar to the metabolism of the human. Giving whole milk to our children will help prevent obesity.
The rationale for giving children lowfat milk is that this measure will help prevent heart disease in the future. However, there is absolutely no evidence that heart disease can be prevented by denying important fats to growing children. In fact, in a recent study, children on lowfat diets produced the most atherogenic fraction of cholesterol (small, dense LDL-cholesterol). The study indicated that lower-fat diets cause the very problems such diets are supposed to prevent.³
Children on lowfat diets exhibit growth problems and failure to thrive.⁴
Certain types of special fatty acids in butterfat (EPA, DHA and AA) are vital to the proper development and functioning of the brain and nervous system.⁵
In a recent study, almost 150 girls, ages 8 to 10 years, were put on lowfat diets to reduce their elevated cholesterol levels. After five years, the average estrogen and progesterone levels were almost one-third lower compared to girls on diets containing normal amounts of fats. Lowfat diets thus inhibit the production of hormones vital for reproduction.⁶

REFERENCES

Koopman, J S, et al, American Journal of Public Health, 1984, 74:12:1371-1373.
Belury, M A, Nutr Rev, April 1995, 53:(4)83-89; Kelly, M L, et al, Journal of Dairy Science, Jun 1998, 81(6):1630-6.
American Journal of Clinical Nutrition 2000, 71:1611-1616
Smith, M M, and F Lifshitz, Pediatrics, Mar 1994, 93:3:438-443.
Preventive Medicine, Mar-Apr 1998, 27(2); 189-94; The Lancet, 1998, 352:688-91; "Good Fats Help Children's Behavioral Problems," Let's Live, September 1997, 45.
Journal of the National Cancer Institute, January 15, 2003.

Lactose Intolerance in Infants

Lactose intolerance is defined as the inability to break down or digest lactose, the sugar found in mammalian milk, due to the absence of the enzyme lactase. Lactose is a disaccharide that is split by the enzyme lactase into two simple sugars, galactose and glucose. The galactose component is very important for the development of the brain and nervous system. (Sucrose, another disaccharide, breaks down into glucose and fructose, and does not provide galactose.)

In societies that do not consume milk or milk products, lactose intolerance occurs frequently in the adult population. However, virtually all infants produce lactase in the gut so that they can digest their mother's milk. Human milk contains higher levels of lactose than that of other mammals because of higher requirements for galactose in the development of the more advanced human nervous system and brain.

The more expensive infant formulas contain lactose. The less expensive formulas, particularly those based on soy protein, contain sucrose rather than lactose. Sucrose is less expensive than lactose and helps formula makers keep their costs down.

The WIC (Women, Infants and Children) program distributes infant formula to low-income families throughout the US. In general, soy-based formula is given to African American mothers on the theory that African American infants are lactose intolerant. This is a fallacy. African American infants are no more prone to lactose intolerance than the children of other races.

Although true lactose intolerance is extremely rare in infants, many babies have difficulty digesting commercial formulas--both those based on milk and those based on soy. This could be due to a true allergy to a specific protein in the milk or the soy, or it could be due to a sensitivity to one of the many additives in these formulas, Carrageenan used in liquid formulas, for example, is very difficult to digest and can cause reactions often misdiagnosed as "allergies" or "lactose intolerance."

Children who react badly to milk-based formula are often given soy-based formula instead. This is a grave mistake as soy-based formulas contain high levels of anti-nutrients that can block mineral absorption and inhibit digestion. Soy based formulas lack both cholesterol and lactose, which are vital to the development of the brain and nervous system. Soy-based formula contains very high levels of phytoestrogens (isoflavones) that can cause endocrine disruption, resulting in early maturation and fertility problems in girls and delayed sexual development in boys. And soy-based formulas have very high levels of manganese which have recently been linked to brain damage and violent behavior in older children and adults who were fed soy formula.

There are a number of choices available to babies who do poorly on regular milk-based infant formula. An excellent formula can be made with a dry milk-based formula (lacking carrageenan) with the addition of egg yolk and cod liver oil. (See recipe below.) One dry formulation contains hydrolyzed proteins that are easier for babies to digest. Gerbers formerly made a meat-based formula. Formula companies should be encouraged to provide meat-based formulas once again. Finally, some parents have reported excellent results using homemade formulas following recipes given in books on infant feeding published in the 1930s and 1940s. These whole foods homemade formulas are based on whole unprocessed or cultured milk; or on liver and broth.

Of course, breast milk from healthy, well-nourished mothers is the ideal food for babies. The WIC program should encourage breast feeding while also making appropriate infant formulas available.

Saturated Fats Are Beneficial, Not Harmful

Saturated fats (or, more properly, saturated fatty acids) occur in large amounts in animal fats such as butter, lard (pig fat) and beef tallow, and in tropical oils such as coconut oil and palm oil. Fats containing high levels of saturated fatty acids tend to be solid at room temperature.
Saturated fatty acids are said to cause cancer, heart disease and obesity. Yet these diseases were rare at the turn of the century when consumption of saturated fats was much higher than it is today. The likely culprits for these conditions are polyunsaturated fatty acids and trans fats, which came into widespread use after WWII.¹
As saturated fats are stable, they do not become rancid easily, do not call upon the body's reserves of antioxidants, do not initiate cancer, do not irritate the artery walls.
Saturated fats actually play many important roles in the body chemistry. Because they are needed in large amounts, the body makes the saturated fats it needs out of carbohydrates when they are not supplied in sufficient amounts in the diet.²
Vitamins A and D, which are vital for proper growth and for protein and mineral assimilation, are found only in mostly saturated animal fats.
Saturated fats enhance the immune system, thereby protecting us against infection and cancer.³
Saturated fats help the body lay down calcium in the bones and help prevent osteoporosis.⁴
Saturated fats provide energy and structural integrity to the cells.⁵ At least 50% of the cell membrane must be saturated fat for the cells to work properly.
Saturated fats protect the liver from alcohol, drugs, pesticides and other poisons.⁶
Saturated fats enhance the body's use of essential fatty acids, which the body needs in small amounts and obtains from whole foods.⁷
Stearic acid, found in beef tallow and butter, has cholesterol-lowering properties and is a preferred food for the heart.⁸
Saturated fats are needed for the kidneys to work properly.⁹
The lung surfactants are composed of saturated fatty acids.¹⁰ The lungs cannot work without adequate amounts of saturated fats.

REFERENCES

Uffe Ravnskov, MD, PhD, The Cholesterol Myths, NewTrends Publishing, Washington, DC, pp217-234.
Mary G. Enig, PhD, Know Your Fats, Bethesda Press, Silver Spring, MD 2000, p 5.
J J Kabara, The Pharmacological Effects of Lipids, J J Kabara, ed, The American Oil Chemists' Society, Champaign, IL, 1978, 1-14; L A Cohen, et al, J Natl Cancer Inst, 1986, 77:43
B A Watkins, et al, "Importance of Vitamin E in Bone Formation and in Chrondrocyte Function" Purdue University, Lafayette, IN, AOCS Proceedings, 1996; B A Watkins, and M F Seifert, "Food Lipids and Bone Health," Food Lipids and Health, R E McDonald and D B Min, eds, Marcel Dekker, Inc. New York, NY, p 101
J F Mead, et al, Lipids: Chemistry, Biochemistry and Nutrition, Plenum Press, 1986, New York
A A Nanji, et al, Gastroenterology, Aug 1995, 109(2):547-54; Y S Cha, and D S Sachan, J Am Coll Nutr, Aug 1994, 13(4):338-43
M L Garg, et al, The FASEB Journal, 1988, 2:(4):A852; R M Oliart Ros, et al, Meeting Abstracts, AOCS Proceedings, May 1998, p 7, Chicago, IL
L D Lawson and F Kummerow, "B-Oxidation of the Coenzyme A Esters of Vaccenic, Elaidic and Petroselaidic Acids by Rat Heart Mitochondria," Lipids, 1979, 14:501-503
Busconi and Denker, Biochem J 1997;328:23
Mary G. Enig, PhD, Know Your Fats, Bethesda Press, Silver Spring, MD 2000, p 31.

Adverse Effects of Excess Polyunsaturated Oils

Polyunsaturated fatty acids occur in small amounts in all foods. Polyunsaturated oils contain large amounts of polyunsaturated fatty acids. Commercial polyunsaturated oils made from corn, soy, safflower and sunflower seeds are new to human diets. The use of these industrially processed oils is 4 fold higher today than it is was in 1900.¹
Polyunsaturated fatty acids are very fragile. When exposed to heat and oxygen, as during industrial processing, they form free radicals and other harmful breakdown products that damage the body in many ways.²
Modern processing destroys the vitamins and antioxidants in vegetable oils, but the pesticides are retained.³ (Seed oils are highly sprayed.)
Polyunsaturated oils cause the formation of black-brown ceroid pigment deposits, a sign of aging.⁴
In animal studies, polyunsaturated oil shorten life-span and increase the possibility of atherosclerosis, cancer and other disease.⁵
Polyunsaturated oils increase the levels of uric acid in the body, a sign of the destruction of protein. An elevated level of uric acid is a heart disease risk factor.⁶
In animals, consumption of excessive polyunsaturates causes cirrhosis of the liver, similar to that caused by excessive alcohol.⁷
Many studies have shown that polyunsaturated oils cause cancer.⁸
Polyunsaturated oils are particularly damaging to the reproductive organs and the lungs.⁹
Polyunsaturated oils depress learning ability, especially under conditions of stress.¹⁰
Polyunsaturated oils given to young animals and impair growth.¹¹
When heated, as in cooking, polyunsaturated oils bond to each other forming polymers, leading to digestive problems (Varnish and shellac are polymers).¹²

REFERENCES

Mary G. Enig, PhD, Know Your Fats, Bethesda Press, Silver Spring, MD, 2000, p 94
Proceedings of the National Academy of Sciences, August 1971.
Unpublished research by the Food and Drug Administration, cited in Edward R. Pinckney, MD, The Cholesterol Controversy, Sherborne Press, 1973, p 53.
Lipid Pigments in Relation to Aging and Dietary Factors," Pigments in Pathology, M Wolman, ed., New York, Academic Press, 1969.
Medical Counterpoint, March, 1969.
W. Stan Wilson, The American Journal of Medicine 51:491; Lancet 2:358, February 15, 1969; Internal Medicine News, November 15, 1971.
Archives of Pathology, 82:596, December, 1966; Modern Medicine, June 14, 1971.
"Nutrition in Relation to Cancer," Advances in Cancer Research, New York, Academic Press, 1953; "Some thoughts on Food and Cancer," Nutrition Today, January, 1972.
A. L. Tappel, Nutrition Today, December, 1967.
Psychological Reports, 29:79, 1971
Journal of Nutrition, 55:577, April 1955; Journal of the American Oil Chemists' Society, 33:630, December 1956; Lipids 1:254, July, 1966.
Journal of Nutrition 60:13, September, 1956.