Vitamin D Recommendations: INFACT’s Appeal to Ujjal Dosanjh


In response to Health Canada finalizing the revision of its vitamin D policy for Canadian infants, INFACT Canada wrote to Health Minister Ujjal Dosanjh. We urged him to reconsider the controversial recommendations that all breastfed infants be given a daily supplement of 400 IU of vitamin D from birth.


Our letter requested that Minister Dosanjh review this controversial vitamin D policy. We invite you to add your voice of concern.


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The Honourable Ujjal Dosanjh                                                     

Minister Responsible for Health Canada

House of Commons

Ottawa, Ontario

K1A 0A6


INFACT Canada’s letter to Mr. Dosanjh




February 21, 2005


The Honourable Ujjal Dosanjh                                                     

Minister Responsible for Health Canada

House of Commons

Ottawa, Ontario

K1A 0A6


Dear Minister:


INFACT Canada, the Infant Feeding Action Coalition, a non-profit membership-based organization that works to promote, support and protect breastfeeding and appropriate infant and young child feeding practices, is urging you to reconsider the controversial recommendations from your department requiring that all breastfed infants be supplemented daily with 400 IU of vitamin D from birth.




Health Canada staff has finalized the revision of its vitamin D policy for Canadian infants.


As part of the revision process of the Health Canada, Canadian Paediatric Society and the Dietitians of Canada, Statement “Nutrition for Healthy Term Infants”, Health Canada requested comment from Canadians on its proposed revised policy. Organizations and individuals involved in breastfeeding and infant and young child nutrition submitted suggestions and recommendations regarding infant feeding practices to ensure the best possible health outcomes, growth and development, including avoiding the risks of an inadequate supply of vitamin D for Canadian children. However, the proposals and recommendations for an approach that includes education and screening for those at risk were ignored.


The recommendations signed by you:


It is recommended that all breastfed, healthy term infants in Canada receive a daily vitamin D supplement of 10µg (400IU).


Supplementation should begin at birth and continue until the infant’s diet includes at least 10µg (400IU) per day of vitamin D from other dietary sources or until the breastfed infant reaches one year of age.



Why this recommendation must be reviewed and reconsidered:



  • the policy is not based on adequate scientific data,

  • there is no scientific data offered that all breastfed infants are at risk,

  • surveys of those at risk identify a population at risk for screening and counseling,

  • there is no evidence offered that the recommendations are safe,

  • alternatives and preventive measures are not included in the recommendations,

  • there is significant conflict of interest in data used and researchers involved.




  1. A public health approach is needed as the vast majority of infants and new mothers receive publicly funded care through the health care system. Screening for those at risk is a viable approach and targets only those who may need interventions rather than a blanket approach, which targets all babies. The vast majority of newborn breastfeeding infants are not at risk for developing vitamin D deficiency and would be needlessly supplemented. The normal source for vitamin D is sunlight. Safe exposure to sunlight to assure normal vitamin D status should be a part of a public health education program. In addition to receiving vitamin D to confer bone health, other benefits are derived from the safe exposure to sunlight such as the prevention of autoimmune diseases, cancers and cardiovascular disease.

Holick MF. Sunlight and vitamin D for bone health and prevention of autoimmune diseases, cancers and cardiovascular disease. Am J Clin Nutr  80: 1678S-16788S, 2004


  1. Exclusive breastfeeding is not a risk factor for vitamin D deficiency. There is no accepted scientific data documenting that ALL breastfeeding infants need supplementary vitamin D at 400IU/day from birth.  Scientific literature on vitamin D adequacy of infants notes that deficiency is rare and only a small minority are at risk. Those at risk are infants born to mothers who do not drink fortified milk during pregnancy and lactation, do not receive vitamin D supplements, have dark skin and do not get exposed to sunlight. Frequently these are recent immigrants from southern countries. It is in these situations that a vitamin D supplement is warranted for newborn and young infants. Preventive measures that are targeted and safe include; the screening for and counseling of mothers to receive vitamin D supplements prenataly and during lactation; education on how to utilize safe exposure to sunlight; and the consumption of vitamin D enriched foods. Insufficient exposure to sunlight of both mother and her infant is the risk factor.

Sills I et al. Vitamin D deficiency rickets. Clin Pediatr 8: 491-493, 1994

Binet A et al. Persistence of vitamin D-deficiency rickets in Toronto in the 1990s. Can J Publ Hlth 87:227-230, 1996


  1. There is insufficient scientific data that a population-based approach of supplementing all infants from birth is safe. Vitamin D is not a vitamin, but a hormone capable of inciting unintended effects (Vieth –1990). No surveillance data on safety for newborns and young infants has been provided by Health Canada to indicate that daily doses over an extended period of time (the recommendation is for one year) do not reach toxic levels. The only assurance of safety that Health Canada provides is “a history of safe use”. It should be noted that orally administered vitamin D is used as an effective rodenticide (Greaves – 1974).

Vieth R. The mechanisms of vitamin D toxicity. Bone and Mineral 11: 267-272, 1990 (Note: toxicity studies conducted by Vieth have all been done with adult subjects. The current policy will in effect be a mass uncontrolled trial)

Greaves JH. Some properties of calciferol as a rodenticide. J Hygiene 73: 341-351, 1974


  1. There are no warnings given in the Health Canada recommendation on the risks of overdosing on vitamin D. Given the patterns of infant feeding during the first year of life of Canadian infants, no warnings are made regarding the need to cease using the supplements when mixed feedings of breast and formula occur or when mothers wean and begin to use breastmilk substitutes exclusively. Infants risk being double dosed to receive 800 IU of vitamin D daily without these warnings. 


  1.  Low-income mothers are the least likely to breastfeed their infants as demographics of infant feeding practices demonstrate (unpublished surveys by Halton – 2002; York Region – 2004 Public Health). It is however low-income mothers who have the most to gain by exclusively breastfeeding their infants from birth. These mothers may be deterred from breastfeeding their infants because of the high cost of the vitamin D supplements. The need to buy an expensive product may augment other reasons to deter low-income mothers from breastfeeding. 


  1. Participants of the policy review committee selected by Health Canada have competing interests. Members of the review committee or the organizations they represent receive direct benefits from the industry that manufactures the vitamin D drops.  The Canadian Paediatric Society Surveillance - 2003 project, on which the policy recommendation is based is in part funded by Mead Johnson, the makers of the D-Vi-Sol vitamin D supplements. It is these supplements all breastfed infants are to consume daily from birth for the first year of life. Moreover, one of the co-investigators (Dr. S. Zlotkin) of the vitamin D surveillance study is a long-time research consultant with Mead Johnson. It is critical that these questionable practices in setting infant and young child feeding policies be investigated by Health Canada.


  1. Canada’s public health policy on infant and young child feeding is to support and promote breastfeeding from birth to two years and beyond. The vitamin D recommendation for all breastfed infants is in conflict with the breastfeeding policy. The manufacturer of vitamin D drops is also a manufacturer of infant formulas, which are marketed to compete with breastfeeding. The manufacturer uses the need for vitamin D to undermine a new mother’s confidence in her breastmilk by promoting the nutritional “inadequacy” of breastmilk and the completeness of infant formulas in parenting magazines and other marketing devises.  This potential conflict between the two policies should be investigated by Health Canada.



  1.  The likely undermining harm to breastfeeding initiation and duration rates as a result of the vitamin D recommendations, may translate into increased health risks for infants and young children that will be far greater than the possible risks associated with vitamin D deficiency. It is critical that your department weigh the consequences of advocating vitamin D on breastfeeding rates and the ill-effects caused by its undermining impact on mothers. The human health trade-offs need to be made evident in the policy statement.  The Canadian Paediatric survey noted 69 cases of nutritional rickets in children to the age of 18 years of age over an 18 month time period (CPSP - 2003). No mortality was reported to be associated with these cases. In contrast a recent study estimates that every year in Canada we can anticipate that 72 infants will die (excluding neonatal deaths) because they are artificially fed. In addition, infants and young children who are not breastfed suffer increased infectious diseases (respiratory, otitis media, gastrointestinal, chronic and autoimmune diseases such as type 1 diabetes, allergies and in the longer-term cardio vascular disease.

Chen A, Rogan WJ. Breastfeeding and the risk of postneonatal death in the United States. Padiatr 113:e435-e439, 2004

Fewtrell MS. The long-term benefits of having been breastfed. Current Paediatr. 14: 97-103, 2004


Why does such a controversial policy have priority from Health Canada when other less costly and more effective guidelines or recommendations to improve infant and young child nutrition are available such as:

·         active support and funding for baby-friendly initiatives in the community and in hospitals,

·         active promotion of breastfeeding as a national priority,

·         meaningful implementation of the International Code of Marketing of Breast-Milk Substitutes and subsequent relevant Resolutions of the World Health Assembly. The International Code and resolutions restrict the marketing of infant formulas, complementary foods, bottles and teats in order to protect breastfeeding and remove commercial interference, including pecuniary conflicts of interest, from infant and young child feeding decisions. 


The primary beneficiaries of this policy will not be Canada’s infants, but the very same industry that violates Canada’s Food and Drugs regulations and Industry Canada’s Competition Act with misleading labelling and claims and violates the World Health Organization’s rules on the marketing of infant formulas.


We respectively request your urgent action to review this controversial vitamin D policy.   In the best interest of all mothers, infants and parents we urge you to institute science-based infant feeding recommendations, based on public health principles and free from conflict of interest and to include the involvement of a wide spectrum of Canadian participants working in infant and young child feeding.




Elisabeth Sterken, BSc,MSc, nutritionist

Director, INFACT Canada



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