SPECIAL FEATURES

September 9, 2002

Consumer Safety Group Warns of New Lethal Danger to Babies: Are Warning Labels for Mommy Next?

An Open Letter to the Consumer Product Safety Commission (CPSC) and the Junior Product Manufacturers Association (JPMA)

By James J. Mckenna Ph.D.
Professor of Biological Anthropology
Director, Mother-Baby Behavioral Sleep Laboratory
University of Notre Dame
James.J.McKenna.25@nd.edu

Background Information:

On May 3, 2002, the U.S. Consumer Product Safety Commission (CPSC) and the Juvenile Products Manufacturers Association (JPMA) launched a national "safety campaign" aimed at warning parents against placing babies in adult beds.

Their joint press release announcing the campaign can be found at http://www.cpsc.gov/cpscpub/prerel/prhtml02/02153.html. There is even a short video produced for the campaign (see http://www.cpsc.gov/vnr/asfroot/babies.asx)

Indeed, the CPSC, a government agency which is supposed to monitor consumer products for safety, has been a very vocal opponent of mother/infant co-sleeping. Back in 1999, the then CSPC Commissioner Ann Brown stated:

Any campaign aimed at reducing infant deaths, such as this one, should be hailed at least for the attempt. But is telling parents that under no circumstances should a child under 2 years of age be placed in an adult bed really in the child’s or the parents best interests? Well, Dr. James McKenna, PhD, from the University of Notre Dame certainly doesn’t think so. He was kind enough to share some of his thoughts with us on the joint campaign of the CPSC and JPMA, as well as the entire issue of co-sleeping in general.

And Dr. McKenna is not alone. Many researchers have demonstrated benefits of cosleeping on both the infant and mother (see references below).

And many others argue that any simplistic public campaign against bedsharing, which fails to differentiate between safe and unsafe conditions, is not appropriate. What the public needs to hear is how to co-sleep safely and under what particular circumstances it should be avoided. It is one thing - a good thing - for parents to learn about "hidden dangers", but it is altogether a different matter to suggest, as the CPSC and JPMA do, that it is the mother herself who constitutes a "hidden danger".

To counteract the CPSC/JPMA simplistic message, the upcoming September-October issue of Mothering Magazine (www.mothering.com) contains 8 original essays, all written by some of the top SIDS and sleep researchers in the world, which argue against the simplistic position taken by these two groups. This issue of Mothering Magazine was organized and edited by Dr. Mckenna. Experts from England, the USA, Australia and New Zealand participated. The authors include: Drs. Peter Fleming, Barry Taylor, Ed Mitchell, Rodney Ford, Barbara Galland, Helen Ball, Martin Platt, David Tipene Leach and others.

What we do know is that mother-infant Co-sleeping is a common infant sleep practice throughout the world and that it is inevitable and inseparable from breastfeeding. Indeed, it is normal and healthy human behavior.

A recent study showed that almost 90% of parents in Korea co-sleep with their children; and it is the cultural norm in Japan and all other Asian countries where infant mortality - especially from SIDS - is extremely low. In some cases, where co-sleeping occurs, SIDS and infant deaths from overlaying are almost unheard of!

The American Academy of Pediatrics is not a big promoter of cosleeping, but they at least are responsible enough to note that bedsharing is only dangerous "under certain conditions" and they provide guidelines for parents to SAFELY co-sleep. In their report entitled "Changing Concepts of Sudden Infant Death Syndrome: Implications for Infant Sleeping Environment and Sleep Position" (available online at http://www.aap.org/policy/re9946.html) they provide the following guidance:

• As an alternative to bed sharing, parents might consider placing the infant's crib near their bed to allow for more convenient breastfeeding and parent contact.
• If a mother chooses to have her infant sleep in her bed to breastfeed, care should be taken to observe the aforementioned recommendations (nonprone sleep position, avoidance of soft surfaces or loose covers, and avoidance of entrapment by moving the bed away from the wall and other furniture and avoiding beds that present entrapment possibilities).
• Adults (other than the parents), children, or other siblings should avoid bed sharing with an infant.
• Parents who choose to bed share with their infant should not smoke or use substances, such as alcohol or drugs, that may impair arousal.

Apparently, the people at the CPSC and JPMA believe that they know better than the AAP; they know better than parents; and they feel that parents are uneducable as to how to bedshare safely.

The AAP notes that the CPSC is "on record as opposing bed sharing", but they maintain that "…there are insufficient data to conclude that bed sharing under carefully controlled conditions is clearly hazardous or clearly safe."

It might also be noted that the CPSC staff who made this recommendation are very few in number, have consulted only researchers who are known for their views AGAINST cosleeping, and have never consulted scholars from the developmental or social sciences who disagree with their views.

Are the CPSC and JPMA at odds over the co-sleeping issue?

It appears that the AAP has a distinctly different position from that of the CPSC, and respects the rights of parents to choose for themselves, while helping them do so safely. Moreover, the AAP finds itself in a very precarious position as regards how to support bedsharing, as increasingly new studies show that not only are their widespread benefits for babies, but for mothers who breast feed intensely and frequently. In 1997 an AAP committee on breast feeding recommended that breastfeeding should be supported enthusiastically by the AAP and ALL steps that help mothers sustain their breast feeding should be encouraged.

The question that needs to be addressed is whether or not the CPSC and the JPMA are in agreement with each other and with the AAP on the issue.

The press release which was issued May 3, appeared to be clearly issued joint by the CSPC and JPMA. After all, not only is the press release entitled "CPSC, JPMA Launch Campaign About the Hidden Hazards of Placing Babies in Adult Beds", but representatives from both groups are listed as contacts as well.

Yet, if you read the official JPMA position statement below very carefully, you will see that they seem to "officially" take a much different stance.

For example, while the JPMA statement gives the very reasonable advise that:

The CPSC/JPMA press release lays out their firm stance clearly in black and white:

It is this issue that Dr. James J. Mckenna Ph.D. of the University of Notre Dame addresses in his "open letter" to the JPMA, which follows the position statement below.

Open Letter to the Consumer Product Safety Commission (CPSC) and the Junior Product Manufacturers Association (JPMA)

By James J. McKenna, PhD (James.J.McKenna.25@nd.edu)

Thank you for sending me the JPMA’s position statement on co-sleeping (see below) and I look forward to a reply from your organization regarding concerns of the diverse constituencies, including scientists, that I represent, and the populations of parents and infants that will be most affected by the recent high-profile campaign.

Who Co-sleeps and Why? The people I encounter in my sleep laboratory while studying sleeping arrangements in relationship to maternal health include many lactating mothers who find that bed-sharing facilitates breast feeding and promotes enhanced social interactions and bonding between mothers and their babies. Bedsharing is viewed as a special type of childcare that not only permits mothers to get more sleep (as well as their babies) but to maintain their milk supply, as bedsharing stimulates the infant to breast feed more frequently and for longer periods of time. Bedsharing also provides opportunities for mothers to nurture and protect their infants, to feel close, and to be better able to strengthen and augment their intimate social relationship, which is enhanced by the nighttime interaction and communication. A mother sleeping in close proximity to her baby reduces infant crying. In addition, in some cases, for which my recent studies provide documentation, sleeping on the same surface with a baby has permitted some mothers, at least in their own opinions, to have saved their infants lives during a choking episode, and/or permitted them to detect - in their minds - some other potentially life threatening situation. For working mothers who spend time away from their babies, of which there are many, bedsharing time is considered precious and some compensation for lost daytime with their babies. Many mothers have educated themselves about where the "hidden dangers" lie in the bedsharing context, and they are able to take steps to optimize safety. This ought to relieve some in your organization who may feel that previous to the release of your message, parents were unaware of the "hidden" potential dangers. Below are some of these "hidden dangers" that exist when bedsharing, which the JPMA and CPSC have chosen to ignore and NOT warn parents of:

• Parent who has consumed alcohol
• Parent who is obese
• Parent taking certain medications
• Heavy comforter or blankets on the bed
• Sleeping on sofa bed

And it is important for you to know that in the minds of most parents, the idea that because some potential danger CAN exist, it does not mean that it MUST exist–or that it ALWAYS exists, or that the dangers or hazards cannot be mediated, eliminated or reduced significantly. These parents will and do decide on their own, when presented with the correct information, to reduce the risk factors associated with bedsharing, just as some parents will choose to reduce the risks associated with infant sleeping in cribs, by doing things like getting a firm mattress and avoiding putting soft bedding materials in the crib.

On Your Commitment To Individual Parental Rights "to choose" In your position statement (see below) you claim to support "individual privacy rights" and "the ability to bond with a child, as parents deem appropriate". However, are you at all concerned that the draconian recommendation made jointly by the JPMA and CPSC makes no distinctions between safe and unsafe adult bed situations or safe and unsafe co-sleeping conditions? Or are you at all concerned that parents are confronting an increasingly hostile social, legal, medical and cultural environment which make it difficult for them to exercise their right to choose to bond or socialize with their babies at night by bedsharing? In Michigan, some health administrators are advocating passing laws that make co-sleeping in the form of bedsharing, illegal! Moreover, professional support and/or safety information will likely become much more scarce as many institutions are becoming fearful to support any form of co-sleeping (or to publish positive articles about it) as they are afraid of legal actions potentially taken against anyone that says it is "OK" to co-sleep. Are you aware that many mothers — possibly millions - are finding it difficult to make that very parental decision your organization states it supports? Mothers are finding that their choice of co-sleeping, increasingly evokes negative judgments by those less informed. And it may get even worse than just sneers and disapproving looks. In one state, Michigan, some health professionals are pushing for legislation that could mean that to co-sleep with your baby would be considered tantamount to child abuse and neglect - and should therefore be dealt with by the police and child protective services. Are you aware of the extent to which your unqualified message is adding to the charge that co-sleeping parents must be irresponsible parents, since the CPSC has determined that unquestionably all co-sleeping is deadly? At very least it is difficult at the moment for parents to take advantage of their own rights - their personal right to choose to sleep with their babies in an adult bed - personal rights your statement above indicates you support. The specific question that I pose to you is this: How your organization claim on one hand to support a parents right to co-sleep, while simultaneously recommending that the baby should never be placed on, or in, a bed - the very structure on which American parents co-sleep? Surely you don’t mean that parents should co-sleep on a couch or sofa as this is even more dangerous. Or, is it that they should best sleep on the floor? Or better yet, maybe a hammock?

What Is And Is Not Dangerous? In light of your official position statement, can we expect some further clarification, acknowledging that while it is very dangerous to place babies to sleep unattended on a bed, the functional "landscape" (i.e. the outcomes associated with bed sleeping) can change quite distinctly, toward the positive, potentially toward protection, when mothers share their bed? Of course when I say "share a bed" I mean as practiced by the Japanese and other bedsharing cultures where breast feeding and mother-infant-co-sleeping occur in tandem, where infant deaths continue to decline (according to the Japanese Ministry of Health Reports) and are the lowest in the world. Further supporting this is the fact that the recent task force on childcare from the SIDS Global Task Force concluded their study of sleeping arrangements with the following quote:

They too conclude that it is not the practice of bedsharing per se that explains this difference but how bedsharing is done. They state: "Interaction with smoking may help explain this paradox but further study is needed to understand the exact methods and complexity of bedsharing both between and within cultures". Does it concern you at all that many of the cultures in the world that have high co-sleeping and bedsharing rates have the lowest SIDS rates and infant mortality rates? Wouldn’t we expect, following your statements, that all bedsharing is dangerous, irrespective of other factors, so all these cultures should have high infant death rates? Are you of the opinion, perhaps, that while parents from other cultures are intelligent enough to construct safe bedsharing environments, our citizens are not? Obviously, bedsharing is dangerous when adult co-sleeping partners are drunk, desensitized by drugs, extremely obese, or are indifferent to the presence of an infant - or where furniture is dangerous or is used dangerously. But the question your organization continues to refuse to answer is: Should bedsharing under the most dangerous conditions and circumstances as occurs in many impoverished urban settings be used to characterize the conditions within which all forms of co-sleeping occur? Is your organization and the CPSC suggesting to the public that we can expect the same negative outcomes across diverse bedsharing circumstances and conditions; that co-sleeping occurring within socially chaotic households, such as among sixteen year old, non-breast feeding, unsupported teen mothers attempting to hold their lives together on less than 18,000 dollars per year, will be the same as those outcomes associated with the older, more educated, more financially stable, non-smoking, breast feeding La Leche League mother? Is it legitimate to infer universal principles of bedsharing outcome from high risk populations where the overwhelming majority of "bedsharing deaths" are emerging and apply these principles to populations where neither the number of infant deaths from co-sleeping or the social and physical conditions are anywhere near comparable and, indeed, are significantly lower? Surely, you must agree that the form, function and outcome of bedsharing is very different when a more financially stable and well educated parent bedshares to better breast feed. Or, does your organization and the CPSC disagree with this common sense view?

What Is Being Heard By Your Message And What It Means To Parents: The Indiana Example Unfortunately, the public message your organization is pushing is being interpreted and applied quite differently than what your official co-sleeping statement suggests is acceptable. I have heard your campaign announced or described by pediatricians and those who will be giving advice to parents. While I do not question completely your sincerity, surely you cannot think that even though you do not use directly the inflammatory language against mothers and infants sleeping together that was used two years ago to an unsympathetic press core, that people, and especially health professionals, are not "filling in the blanks." Indeed, as you have joined forces with the Consumer Product Safety Commission, the public and health agencies can only interpret this campaign in view of Ex-Commissioner's Ann Brown's now infamous 1999 words:

Let me give you a perfect example of how the CPSC/JPMA has negatively impacted parents.

In my very own State of Indiana, the ability of health professionals to provide scientifically up-to-date information to parents has been seriously impaired. A professionally developed brochure summarizing safe sleep environments for infants, was developed and specifically designed to reach as many people as possible who differ greatly in their caregiving choices. But many parents have been prevented from receiving this important information, thanks in large part to the current CPSC/JPMA campaign, I suspect.

On May 19 the Indiana Evansville Courier and Press ran a story entitled: "Brochure for Safe Sleeping Babies Not Distributed Here". The story reported that our "safe infant sleep" brochure, produced over a six-month period by eleven health professionals, including myself, which was being distributed throughout the state, was "being pulled from two hospitals" by two doctors acting on their own. Upon hearing the CPSC/JPMA report on the dangers of placing an infant in an adult bed, the physicians banned the new brochures, arguing that the CPSC has determined that no form of bedsharing is safe. The two physicians reported that the message on the brochure gave a "mixed message" and any parent could think that "it is OK to bedshare under certain circumstances’. This inference by a parent was simply unacceptable to the two physicians.

The brochure itself attempts to be inclusive to diverse parents who likely will encounter many different sleeping arrangement - and makes no assertion that bedsharing is beneficial - only that some parents choose to bedshare, especially breast feeding mothers. What is pointed out on the brochure are the steps one can take to maximize besharing safety, as well as situations where bedsharing should be avoided.

Indeed, the purpose of the brochure committee was to only present to parents information that was strictly "evidence-based". But the two physicians were, nonetheless, able to enforce their own uninformed judgment about what was scientifically accurate, and had no trouble enforcing their own personal beliefs that no safety information on bedsharing should be available to parents. Essentially, these physicians were able to deny parents who choose to place their infants in cribs as much safety information as they were able to deny bedsharing parents safety information and, indeed, they suggest that parents have no right to even make that choice in the first place.

The ad-hoc committee of professionals which produced this "safe infant sleep" brochure (of which I was a member) did not advocate bedsharing. If anything, the brochure over-represented the potential dangers of bedsharing when not practiced as safely as possible.

On the brochure, the following comment is made: "Some breast feeding mothers choose to bring their baby to bed with them". The brochure states that the safest known way to arrange sleep for a baby is to put the crib or bassinet or co-sleeper next to the bed, within arms reach of the mother.  

The committee that wrote the pamphlet demanded of itself scientific preciseness, and proof that every phrase and word was legitimate and based on scientific evidence. The brochure was respectful of diverse family and cultural beliefs and practices.

In addition to myself, the committee consisted of the following people: a nationally recognized neonatologist, a pediatrician with expertise in sleep medicine (who opposes any form of bedsharing), a lactation consultant (sympathetic to safe co-sleeping and breast feeding mothers), a SIDS researcher (who pioneered physiological studies of bedsharing, and sympathetic and protective of informed parental choice), the State Maternal Health Coordinator, a SIDS Alliance representative (also opposed to any kind of co-sleeping), and experts from the Indiana Perinatal Network, which involves infant fetal and infant mortality review professionals.

All members put aside their own personal preferences and produced a pamphlet that above all else is accurate, inclusive, teaches safety, and recognizes that parents make choices ultimately to suit their own needs, beliefs, feelings and emotions.

In the end, however, these two hospitals used the authoritative absoluteness of the CPSC/JPMA message to eliminate the brochure. We are now facing the possibility that our efforts will be utterly negated.

How Organizations Who Promote BreastFeeding and Co-sleeping View Your Intents and Define Your Campaign

The current activities of your organization (JPMA) are viewed by many of us involved in infancy/sleep/SIDS/lactation/co-sleeping research as participating in a follow-up campaign to what was begun in 1999 by the Consumer Product Safety Commission - but a follow-up involving more public outreach AND with lessons learned.

And what are the lessons learned? In 1999 the CPSC was practically excoriated by the press, by making the mistake of stating that mother-infant "co-sleeping" was always deadly and dangerous and should always be avoided; and at the time the CPSC implied that it should NOT be a parental choice, informed or not. The new approach, I also suspect, which tenaciously clings to the same goals, is: don't mention bedsharing--don't mention "co-sleeping", don't mention "sleeping with baby"...but go after the instrument or structure that permits mother-infant bedsharing - the bed.

This essentially amounts to taking away any support or assistance that bedsharing parents may seek. In addition, it communicate to the health professionals/coroners, pathologists/pediatric residents-pediatricians, that any co-sleeping situation is lethal and any parent that wants to co-sleep must be ignorant, out of their minds, or irresponsible.

Now, in one way the new strategy is an improvement over the previous campaign of the CSPC. The mother’s body is not being publicly and explicitly represented as it was the last time as no more responsive to her infant than the inert mattress on which a mother sleeps - giant wooden rolling pins, in other words. Nevertheless, the ideology and the assumptions remain - only the wording has changed.

Already, I have been asked to provide written perspective on the implications and meaning of your statement to parents, and asked to present several Pediatric Grand Round lectures explaining how co-sleeping can be a positive thing.

Along those lines, may I ask, since it is labeled a "Co-sleeping statement" what exactly do you mean by "co-sleeping"? Is bedsharing included? Do you support the rights of parents to solve the problems associated with potential bedsharing hazards — in the same way that you support the rights and needs of parents who choose to place their infants in cribs?

I take it, from the JPMA official position statement (see below), that your organization does. And if so, are your colleagues working on making and constructing baby friendly and baby-safe--adult beds?

Mind you, this is not about me or anyone who studies co-sleeping in the form of bedsharing being upset about safety information being presented to parents. On the contrary, as is true in my own work, safety information and qualifications are primary and essential. There can never be too much information given, just a problem of too little, and how the information is delivered, and for what purpose, and what is inferred from it. It is not about "irresponsible" people (the description often used to describe me or those that support parental rights to choose to bedshare) vs the "responsible" people (JPMA and CPSC).

Rather, my worry is about what is NOT being said and the selective nature of the information being presented to parents. I am concerned about the many parents who get "excluded" - who cannot afford cribs or those who choose, in an informed way, not to use them. These people may be afraid to seek safety information because they "bedshare"; and while your position statement sounds "middle-of-the -road"...is it, really? Certainly the press release issued jointly from the CPSC and JPMA is not!

And where do you expect poor babies, whose parents do not have cribs--are going to sleep? Do you realize that some parents will sleep on couches now because of your message - and that this alone could lead to more deaths, as this has been shown to greatly increase the risk to the baby?

What the press "blitz" indicates is that beds are dangerous and since Americans usually sleep on beds, the only safe place for an infant to sleep is still in a crib. It suggests that this is true, regardless of whether a mother is present or not and regardless of whether or not she is breastfeeding and knows how to construct a safe bedsharing environment.

And, after all, is it not the case that the CPSC actually believes that there is not such thing as a "safe bedsharing environment" except (perhaps) for Commissioner Mary Sheila Gall (based or her past statements)? And, is it not your organization joining hands with CSPC specifically to promote crib sleeping, and information about cribs only?

If it is truly a safe sleep campaign you offer, then by all rights you should be considering not what you expect or want people to do, but what they ACTUALLY do and this includes choosing various forms of co-sleeping.

Co-sleeping(Side-By-Side) Saves Lives - Your Campaign Doesn’t

Just for the record, years ago at an International SIDS Meeting, my colleagues and I presented a compromise perspective-- which until recently was ignored and dismissed. This was to promote a form of co-sleeping that is COMPLETELY safe...and less controversial. That is, we proposed that at very least the infant should sleep next to a caregiver, but on a different surface, And while this kind of statement is appropriate for a general public health recommendation, at the same time, we did not believe and nor do we now that all bedsharing should be recommended against, and that only unsafe bedsharing should be recommended against. In no way do we believe that it is scientifically or morally appropriate to suggest that a mother’s body (when sober) is an inherent threat to her co-sleeping infant - as your organization and the CPSC prefer to see it.

We argued at the time, and still do, that infants sleeping in cribs, next to their mother's beds, permitting sensory exchanges between mother and infant alike, is a legitimate and important form of mother/infant co-sleeping. We proposed that this type of co-sleeping - you might even call it "same room co-sleeping" increases the infants survival chances, a hypothesis that has been verified by two epidemiological studies, one conducted in New Zealand, and one conducted in England.

Co-sleeping is thus not limited to bedsharing at all, but as I proposed in the literature years ago, should be conceptualized as a generic and diverse "class" of sleeping arrangements (one form of which is bedsharing). And like crib sleeping, bedsharing can praticed in such a way to be either safe or dangerous.

Thus, there is no fixed risk factor associated with bedsharing, because it is not a coherent behavior, but it is diverse and composed of many different behaviors and characteristics, requiring each to be examined independently as to its role in creating safety or danger. Hence, what explains different bedsharing outcomes are these diverse "factors".

Using this way of thinking, I suggest that we conceptualize bedsharing in terms of a continuum of outcomes ranging from positive to negative. We could use this type of reasoning to understand why different countries and regions, and different groups and sub-groups that bedshare, are divided between groups with low infant deaths and high infant deaths (as they fall for various reasons on each side of the continuum).

For example, the presence of certain positive factors such as: breast feeding, absence of drugs and alcohol use, absence of maternal smoking (pre and post pregnancy), and knowledge of safety issues, can lead to increased infant benefits, protection, and safety.

Meanwhile, the presence of other factors in the bedsharing context, such as smoking, drug use, chaotic households, alcohol use, prone sleeping, and excessive blanketing, can on the other hand create increased infant deaths.

We now have the scientific evidence showing that under normal circumstances, mothers are exquisitely designed to awaken to care for the needs of her infant, and that they do so, even in the deepest stages of her sleep (Mosko, et al, 1997).

Co-sleeping vs. Bedsharing and Factors vs. Practice

The term "co-sleeping" refers to situations in which the sleeping mother remains in close enough proximity to her infant that each are able to detect, monitor, and respond to the sensory signals or cues of the other. It is hardly a radical concept or practice. Co-sleeping does not require the mother and infant share the same sleep surface. At the time I proposed conceptualizing co-sleeping as a generic concept into which various "taxa’ or forms need to be differentiated, not only did the CPSC think this was not a distinction worth making, but that the word "co-sleeping" itself was simply too dangerous a term, as it implied that some kind of nighttime body contact (between the mother an infant) might or should occur.

But the new epidemiology from New Zealand and Great Britain suggests that "co-sleeping" defined in terms of proximate, but separate, surface co-sleeping by a committed adult care-giver and an infant saves infant lives. Infants are two to four times less likely to die of SIDS, and this protective effect is not generalized when siblings share a room, only when mother does. Moreover, 92% of the 2,178 infant deaths reported by the CPSC in 1999 suffocated outside the company of a responsible adult caregiver (see Drago and Dannenberg)!

With these data in mind, at very least let me suggest that the JPMA should be arguing to the public that if babies sleep in cribs, they should never be left sleeping in a crib in a room by itself! Cribs should be placed close to a supervising, responsible adult.

Why not add this to your message and make it complete and scientifically accurate? Suggest to parents that they may wish to drag their cribs from the infant's bedroom and place them adjacent to the parents bed, or as close to the bed as is possible. Babies should not be isolated for naps, either. My professional opinion is that bassinets and cribs should all be on wheels, and able to be rolled around to wherever the caregiver happens to be. The CPSC database supports this recommendation, as does all of the SIDS epidemiology.

In sum, room-sharing with an infant is a form of co-sleeping, but if and only if, a responsible and committed adult care-giver is in the room. This is a fact that could have, but was not, shared by the CPSC and the JPMA, which illustrates the selective nature of their safety campaign.

Another concern is breastfeeding. A recent survey of over 10,000 mothers in the East and Midwest US by NICHD found that breastfeeding mothers are more than three times more likely to bedshare than are non-breast feeding mothers. And, yet, there was no evidence of increased risk to these infants of unexpected death, as would have been predicted by the simplistic message being presented by the CPSC.

As I have mentioned above, the NICHD researchers found that breast feeding bedsharing mothers differed in how they bedshared compared with non-breast feeding bedsharers. This finding corroborates the importance of "factors" in determining positive or negative outcomes for infants while bedsharing and shows that if mothers bedshare to breast feed, the outcomes are much more positive. Given that breast feeding is becoming more prevalent and breast feeding promotes bedsharing, co-sleeping will likely increase, rather than decrease, in the next few years, regardless of your campaign.

Your organization (JPMA) could stand to profit mightily by commencing research into and design of safe cosleeping pieces of furniture, like Doug Tharlsson's Arms Reach Co-sleeper or the Nursing Cradle by Teresa Winkler and others. This is the next wave of baby furniture.

Full, Not Partial Information, Freedom of Opinion and Choice, and Access to Information

My main professional objection and most serious worry over what has occurred with your press release (and accompanying media buzz) and with the subsequent public comments made by the CPSC Acting Commissioner, is that your organization (JPMA) and the CPSC, do not provide a context for an open educational opportunity and exchange, for the hundreds of thousands of parents - maybe millions - in our country who sleep with their infants or young children.

If you really care whether or not parents believe that you support their rights to choose to sleep with their infant, why would you not state this somewhere in your press release? Moreover, since your goal is to promote safety for all, why not promote knowledge about what social and physical conditions undermine safe bedsharing, rather than simply suggesting that a baby should never be placed on or in an adult bed when the parent is present? Contrary to what most of the CPSC staff argues, "safe" bedsharing is not an oxymoron.

You may be surprised to learn, but many parents will not be, that not only is it possible to construct safe bedsharing environments, but on some occasions, bedsharing is at least being perceived by some parents as having been the reason their infant lived! I am preparing for publication a paper in which we describe at least 30 instances in which a mother describes how, by having their her sleeping with them in bed, they detected a breathing "crisis" and were able to respond almost immediately. It is hard to know if their inferences are correct, of course, but amongst these 30 parents, they strongly believe that they saved their infants lives by bedsharing.

Are you are aware that the grim bedsharing death statistics cited by the CPSC are inflated because they emerge from a "dustbin" category of deaths? These statistics encompass any death that does not occur in a crib, such as those that occur on couches or sofas, on recliners or rocking chairs, and also include infants left alone on adult beds (not bedsharing in a functional sense). In addition, the data includes babies overlaid by drunk or drug-using parents and those overlaid by other children.

I believe that parents would be very interested in knowing that the overwhelming number of these deaths were not simply accidental overlays, by sober, safety-conscious adult caregivers. The CPSC obscures these facts, and these facts are not presented as "factors" that can actually account for the death, as opposed to simply "bedsharing".

I believe that the CPSC "database" is not what it is represented to be and a double standard is being used to assess the causes of infant deaths: one standard is used to assess causes of crib deaths, while another standard is used to assess causes of bed deaths. For example, crib deaths are analyzed in terms of what it is was about the characteristics of crib or use of the crib that caused the infant to die, such as how the baby was positioned in the crib, or how the babies head was covered, or how the baby slept on a soft crib mattress, or slept prone in the crib.

The point is, that neither crib sleeping nor solitary sleep is said to have CAUSED the death. In contrast, when a baby dies on an adult bed, with or without the parent in the bed, even if the baby was lying prone, face down, and regardless of whether the baby was placed on a pillow (highly dangerous), "bedsharing" is said to have been the cause. Yet the "factors" associated with the bedsharing are ignored.

In other words, every death of an infant in a bed, regardless of circumstances, is said to "prove" that bedsharing is inherently deadly, while every death of an infant in a crib is an "accident" or a "tragedy" - while the crib, or "solitary crib sleeping", is not said to be the "cause".

Finally, the CPSC needs to realize that there is no one place where babies sleep. Several studies show that even when families own a crib, babies can spend a good part of their time in bed with the parents, usually for breast feeding, but sometimes just because it just calms the baby and the parents can get more sleep. In a recent study, my students and I conducted via the Internet, of the 300 families we interviewed extensively, the vast majority owned cribs and initially intended to use them, but ended up bedsharing for at least part or most of the night.

We all need to be open to the fact that both crib sleeping and bedsharing can be either dangerous or safe practices, depending on many factors. We need to appreciate the diversity of legitimate choices parents have a right to make, and realize that choices about sleeping arrangements should be based on full disclosure of information, not selective disclosure, as the CPSC campaign engages in.

Working with diverse professional and parental constituencies, your organization (JPMA) could have produced a more effective and inclusive campaign. It could have helped to initiate what could have been a truly unprecedented successful approach to this question of where infants should sleep.

Instead, as in 1999, the narrow "one-size-must-fit-all" CPSC perspective prevails, reflecting the views of a minority of scientists and health workers and completely excluding the opinions of other professionals, with just as much if not more knowledge of the issue.

Even worse, millions of parents who will choose to sleep with their children are prevented from finding safety information about the practice and from being validated for their choice. All this for only doing what nature designed us to do - to sleep close to our infants and children.

To "co-sleep" a powerful human behavior that simply will not and should not go away, regardless of any public disinformation campaigns from the CPSC or the JPMA.

Sincerely,

James J.McKenna, PhD

References

1. McKenna J. Cultural influences on infant sleep biology and the science that studies it: toward a more inclusive paradigm. In Sleep and Breating in Children: A Developmental Approach (2000). Eds. Loughlin GM. Carroll JL. Marcus CL Marcel Dekker Inc: New York, 99-130.

2. Mosko S, Richard C, McKenna JJ, Drummond S. Infant sleep architecture during bedsharing with infant and possible implications for SIDS Sleep 1996 19:677-684

3. Mosko S, Richard C, and McKenna JJ. Infant arousals during mother-infant bedsharing; implications for infant sleep and SIDS research. Pediatrics. 1997; 100; 5: 841-849.

4. Young J, Fleming PJ. Reducing the risks of SIDS: The role of the pediatrician. Paediatrics Today. 1998; 6 (2):41-48.

5. McKenna JJ, Mosko S, Dungy C, and McAninch P Sleep and arousal patterns of co-sleeping human mothers/infant pairs: A preliminary physiological study with implications for the study of Sudden Infant Death Syndrome (SIDS). Amer J Phys Anthrop 1990; 83:331-347.

6. McKenna JJ, Mosko S, Richard C. Bedsharing promotes breast feeding. Pediatrics. 1997; 100:214-219.

7. McCoy RC, Hunt CL, Lesko SM, et al. Population-based study of bedsharing and breast feeding. Program and Abstract and Press Release Ped Acad Soc Annual Meetings May 5, 2000 Boston, Massachusettes. Blair PS, Fleming PJ, Bensley

8. O'Hara M, Harruff R, Smialek J, Fowler D. Sleep location and infant suffocation: How good is the evidence? Pediatrics. 2000; 105 (4); 915-920

9. Scheidt D: 2000 AAP Grand Rounds, Vol 3 No 1: 1-12).

10. American Academy of Pediatrics. Policy Statement. Breast Feeding and Human Milk.Pediatrics (1997) 100:6,1035-1039.

11. Reite, M., and Field, T., eds. (1985). The Psychobiology of Attachment and Separation. New York: Academic Press.

12. Ball H, Hooker E, Kelly P. Where will baby sleep? Attitudes and practices of new and experienced parents regarding cosleeping with their newborns. Amer Anthrop. 1999; 101(1): 141-151.

13.Rigda, RS, McMillen IC, Buckley P. Bed sharing patterns in a cohort of Australian infants during the first six months after birth. 2000 Journal of Paediatrics and Child Health 36(2): 117-21.

14. Baddock S. Bedsharing Practices of Different Cultural Groups. Program and Abstracts of Sixth International SIDS Conference Auckland, New Zealand. February 8-11, 2000.

15. Fleming PJ, Blair P, Bacon C. et al. Environments of infants during sleep and the risk of the sudden infant death syndrome: results of 1993-1995 case control study for confidential inquiry into stillbirths and deaths in infancy. Bri Med Jour. 1996; 313:191-195.

16. Blair PS, Fleming PJ, Bensley D., et al. Where should babies sleep---alone or with parents? Factors influencing the risk of SIDS in the CESDI Study. Br Med J. 1999; 319: 1457-1462.

17. McKenna JJ Mosko S. (2001) Mother-infant cosleeping with breast feeding as adaptation not pathology: toward a new scientific beginning point. In Sudden Infant Death Syndrome: Problems, Puzzles and Paradoxes. Eds. RByard and HKrous.

JPMA Official Position Statement

JPMA firmly supports individual privacy rights. This includes the ability to bond with a child, as parents deem appropriate. JPMA reminds parents a baby should never be left unattended or alone in an adult bed. Our concern is that infants may face serious, hidden hazards if they are left to sleep on adult beds. These hazards include: entrapment between the bed and wall or another object, entrapment in the foot or headboard, and suffocation in pillows and adult bedding. These hazards are believed to be responsible for more than two thirds of the deaths that the Consumer Product Safety Commission (CPSC) cited. We want parents to be aware of them.

JPMA is a not-for-profit Association that undertakes a variety of public service initiatives. It is often difficult to reach new parents and caregivers with meaningful safety information. JPMA has always been willing and eager to help deliver important safety messages and if we can help promote messages, which the government wants to get out as a public health and safety service, we do so.

During the JPMA International Juvenile Products Show in Dallas, Texas, we provided the CPSC an opportunity to reach these targeted audiences with important safety messages. We believe it is beneficial to provide such safety information. Our intention is not to interfere with responsible parenting practices or the intensely personal relationship between parent and child.

Books about co-sleeping

Good Nights by Dr. Jay Gordon, (July 2002) - Puts your concerns about the family bed to rest with fun and easy-to-use guidance on safety, coping with criticism, and even keeping the spark in your marriage (albeit outside the bedroom). With warmth and humor, Dr. Jay Gordon, a nationally recognized pediatrician who has endorsed the family bed for decades, and Maria Goodavage, a former USA Today staff writer with training in sleep research, give you everything you'll need in order to thrive - and at times, simply survive - with the family bed. - http://www.amazon.com/exec/obidos/ASIN/0312275188/

Nighttime Parenting: How to Get Your Baby and Child to Sleep by William Sears - Renowned pediatrician Dr. William Sears helps you find a solution to your baby's sleepless nights. Directed at lessening night-waking and increasing your ability to cope, this understanding guide offers comprehensive, caring advice on: where your baby should sleep, what foods help children sleep, nighttime fathering, tips for single parents, getting children to bed without a struggle, and much more.

For More Information:

For Additional Cosleeping information from Jim McKenna, PhD - http://www.naturalchild.org/james_mckenna/index.html

Safe Cosleeping by Jay Gordon, MD - http://www.drjaygordon.com/ap/cosleeping.htm

The Safety of Babies by Peggy O’Meara - http://www.mothering.com/editorials/editorial113.shtml

The Benefits of Co-Sleeping by Jennifer Cobrun - http://www.breastfeeding.com/reading_room/co_slepping.html

Co-Sleeping: Another Way to Promote Infant Health by Jennifer Coburn - http://www.parentingweb.com/ap/sleep_health.htm

Co-sleeping in light of U.S. Consumer Reports by Mary Paliescheskey - http://members.tripod.com/doula/MMnews1.html#Need