August 30, 2006
Dr. Patricia Ann Daniels
Director, Supplemental Food Programs Division
Food and Nutrition Service, USDA
3101 Park Center Drive, Room 528
Alexandria, VA 22302
Re: Proposed Rule: Revisions in WIC Food Packages
The WIC Program was conceived to safeguard the health of low-income women, infants and children up to age 5, who are at nutritional risk by providing nutritious foods to supplement their diets. A 1990 review showed that women who participated in the program during their pregnancies benefited greatly compared to women who did not.
In the same year, the 1990 World Summit for Children made infant and child nutrition its highest priority. Motivated by the devastating impact of iodine deficiency on the physical and mental retardation of children, UNICEF, WHO and several other organizations made a commitment to eliminate this problem through universal salt iodization.
In the United States, since 1924, the most consistent and reliable source of iodine intake has been table salt. This public health intervention was not the result of government legislation, but rather a commitment on the part of the salt industry to make iodized salt available to consumers, at no additional cost. In fact, few public health interventions have produced the extraordinary degree of success and public benefit as the iodization of table salt.
Over the last 30 years, however, the National Health and Nutrition Examination Surveys (NHANES) have demonstrated a dramatic drop in iodine consumption. The median urinary iodine excretion in adults declined from 320 μg per liter in 1971-1974 to 145 μg per liter in 1988-1994 and 168 μg per liter in 2001-2002. Even more disturbing, in pregnant women, the frequency of moderate iodine deficiency (considered to be a level of urinary iodine excretion less than 50 μg per liter) jumped from 1 percent in1971-1974 to 7 percent in both the 1988-1994 and 2001-2002 surveys, . While the current levels are not low enough to declare a public health emergency, the continuing trend is a matter of great concern.
While consumer table salt is iodized, commercial food grade salt used in the food industry is not (unless specifically requested). The drop in iodine consumption that is evident from the NHANES data reflects the decreasing trend in meals eaten within the home over the last 30 years. When data on the number of meals consumed within the home is plotted against the decrease in urinary iodine output two perfectly parallel lines result. As the meals eaten within the home have been replaced by meals eaten away from home, a replacement of iodized table salt with non-iodized salt has occurred.
As WHO has so often stated, iodine deficiency at critical stages of development in fetal life and early childhood remains the world's single most important and preventable cause of mental retardation. It is therefore worthy of the highest consideration in the WIC program – not only with reference to the supplemental foods consumed by pregnant women and children, but also to the nutritional information given to mothers. Yet, the word iodine and its contribution to childhood nutrition does not appear anywhere in the proposed revision of WIC Food Packages.
Faced with the evidence of decreased iodine consumption and a knowledge of the vital importance of iodine to fetal and early childhood nutrition, I believe that it would be prudent to recommend the use of iodized salt in all foods endorsed for WIC food packages. It is also very important to make certain that pregnant women and mothers be aware of the importance of using salt that is iodized when preparing foods.
I hope that you will give the above recommendations you serious and positive consideration.
Sincerely,
Morton Satin
Director, Technical and Regulatory Affairs
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