المنتدى العالمي المعني بالأمن الغذائي والتغذية

We welcome the current Draft of the Rome Declaration on Nutrition.  We have a few suggestions for how it could be improved. These are intended to:

- make it clear that production methods need to be acceptable to consumers and take account of social and cultural aspects

- stress the importance of consumer choice over production methods

- give greater emphasis to food marketing not undermining efforts to protect and promote healthy diets

- require cross-cutting food policies

- include a way of monitoring progress

Furthermore, we call on the WHO to initiate work on a Framework Convention to promote and protect healthy diets.

[See specific comments in the attachment, Ed.]

HANDS is working in Pakistan since last 34 years covering most of te development sectors including Health. Nutrition, Livlihood, education etc. Mostly the Private sector in developing countries related to food business have hampered and disrupted the food distribution and accessibility to poor, e.g. Dairy industry.  The commercial market partners must be regulated globally or at National level by individual governments. There is no ethical guidelines are proposed to ensure the rights of poor people. The high population growth and recurrent pregnancies increased the burden on already stressed food insecurity in many developing and under-developed countries. Its recognition is extremely significant as it has many implication on women malnutrition and long continued malnutrition in the children leading to whole life impact. This vicious circle is one of the barrier in achieving sustainable development.

The countries’Food security, Nutritional policies must be integrated with Economic development and Population policies. Economic and Population policies of the government may be added in paragraph 11-12. The framework of Action should be flexible with regional dimensions such as developed countries and developing or poor countries.

HANDS is one of the largest health and development organization in Pakistan. We have experienced that the community mobilization and involvement is the key to success in implementing all government policies and turning it in to Actions. We would support the ICN2 Declaration and would be committed to Framework for Action.  

We regret that the vast majority of our comments on the ICN2 zero draft, submitted during the first e-consultation, have not been incorporated into the revised declaration. While we appreciate the reference to the right to food in the opening paragraph, the overall declaration still fails to be grounded in human rights. No mention is made of nutrition as core element of the human right to adequate food and nutrition and corresponding State obligations to respect, protect and fulfill this right. The elimination of malnutrition is considered to be imperative for “ethical, political, social and economic reasons”, but not because it is a human rights obligation of States. As in the previous draft, there is no acknowledgement or analysis of the systematic violations of human rights, including violations of women’s rights, child rights, and people’s access to natural resources, in which malnutrition is rooted. The detrimental impact of malnutrition on the enjoyment of other human rights is equally not considered. Women’s rights and the essential role of women in food production and nutrition (including through breastfeeding) are also overlooked.

We recommend, in addition to the specific changes outlined below, that reference is made throughout the document to the “right to adequate food and nutrition” to emphasize the links between food and nutrition and the fact that nutrition is a core element of the right to adequate food.

[See specific comments in the attachment, Ed.]

Please find attached my comments.

The Declaration should make strong reference to food and nutrition’s role in environmental degradation and protection. Food has a major impact on the environment. WHO and FAO ought to include that dimension in the Rome Declaration. It should and could reaffirm past UN commitments that health and environment are intimately connected through food and diet. There is a strong tradition in the UN of cross-referencing to wider UN commitments. Rio+20 for example acknowledged the environment.

[See specific comments in the attachment, Ed.]

Tim Lang PhD

Professor of Food Policy

Centre for Food Policy

School of Social Sciences

City University London

Dear Colleagues and Friends,

Greetings!

I am sending the attachment of my comments on Draft of the Rome Declaration on Nutrition.

Best regards,

Golam Sorowor

BAFLF

Hi,

1. The political document does not explicitly support what has been discussed in the Lancet Series on Maternal and Child Nutrition.  It has very little discussion on breastfeeding, and most especially complementary feeding and concerns related to the first 1000 days of life. Thus, effort to address malnutrition during these life stages is limited in this document.   This should be strengthened in the document.
2. There is also a need to integrate related concerns from the post-2015 development agenda and the Scaling Up Nutrition Movement. 
3. The targets set forth in this document must also be in line with the global targets committed for 2025 which states the following:
   
   ~ 40% reduction in the number of children under-five who are stunted
   
   ~ 50% reduction of anemia in women of reproductive age
   
   ~ 30% reduction in low birth weight infants
   
   ~ Nno increase in childhood overweight
   
   ~ increase the rate of exclusive breastfeeding in the first six months up to at least 50%
   
   ~ reduce and maintain childhood wasting to less than 5%
4. We also suggest for the FAO and WHO to develop a mechanism for alert notifications to member countries who joined the ICN2 forum last November 2013 in Rome for recent updates that may be available in the website.  We very much welcome the idea of subscription to the ICN2 forum to keep track of the discussion and the latest documents being released.

Please see the attached document for the [specific, Ed.]comments of the National Nutrition Council - Philippines.

Thank you.

On behalf of the US Council for International Business, I would like to thank the organizers of ICN2 for the opportunity to contribute to this online consultation on the revised draft of the Rome Declaration on Nutrition.  While we greatly support the submission made by IAFN, we would like to offer some additional comments. 

Although an online consultation will solicit some input, we would like to suggest that the FAO and the WHO create a more targeted approach to engaging with stakeholders, including the private sector. We recommend a formal consultation  with stakeholders, including the private sector, to have a more robust and complete discussion on these important issues related to nutrition.

In general, we believe the outcome document should reflect that the private sector can contribute in the area of nutrition through its innovative products, its science and technology know-how, as well as good production and management practices, which can be increasingly harnessed through effective partnerships with research institutions, farmers, policy-makers, and civil society.

In addition, we believe that advancing health and nutrition requires a multi-stakeholder approach that reflects the complexities of the issues.  For this reason, we believe that ICN2 should include participation from civil society as well as the private sector. There is no quick or simple solution to addressing nutritional challenges. While we believe that the private sector has a role in producing healthy and nutritious food, it is equally important to address issues that impact the community’s ability to thrive, such as poverty, hunger, gender inequality, water access and sustainable agriculture.  We believe that developing the economy, including promoting women’s role in the economy, is important. The private sector can play a critical role in further strengthening markets, spurring economic growth and improving livelihoods  including nutrition.

We look forward working with the FAO, the WHO and the Civil Society Mechanism to help create the environment for building trust as we seek to demonstrate the effective value of leveraging our capabilities in these partnerships to address the nutritional challenges ahead.

Thank you.

This draft is a welcome improvement on the zero version, with much greater recognition of the multi-sectoral nature and impact of undernutrition. Many thanks to all colleagues who worked on it. We'd like to see this improved balance reflected more in paras 12 a to j, which still focus mainly on the food system. 

2.     Specific comments on the paragraphs related to the multiple threats that malnutrition poses to sustainable development (paragraphs 4-10).

Para 2. It will be important to mention WHA 2025 nutrition targets here. I recognise the sensitivities you outline regarding FAO’s mandate; a clear reference to these would point the system in the same direction.

We welcome paragraph 4’s emphasis on nutrition’s widespread impact on society, including the impact on human potential.

We welcome para 5, bullet 2: recognition of poverty as a major factor in undernutrition.

We welcome para 8: recognition of impact of climate change.

4.     Specific comments in the appropriate fields relating to these commitments (paragraph 13):

Commitment d): encourage and facilitate contributions by all stakeholders in society and promote collaboration within and across countries, including North-South, South-South and triangular cooperation;

We recommend a commitment to multisectoral coordination here, in the spirit of para 11b. Suggest adding a reference to this in point 13d.

Commitment f): adopt and implement a Framework for Action that should be used to monitor progress in achieving targets and fulfilling commitments;

WHA targets should also be referenced under para 13f, to avoid duplication of existing targets

Commitment g): integrate the objectives of the Framework for Action into the post-2015 development agenda including a possible global goal on food security and nutrition.

5.     We would also appreciate your vision on policies, programmes and investment that might help translate such commitments into action.

Domestic budgets must be increased and made more nutrition sensitive in order to tackle the challenge of undernutrition.

Governments and other actors can leverage existing platforms to deliver nutrition outcomes, for example community health workers and agricultural extension workers. This is critical to securing better nutrition for all.

We’d like to see a much greater focus on livestock and fish promotion for increased animal source protein.  This is a neglected area of debate in the undernutrition debate.

All actors must place greater emphasis on pregnant and lactating women, in order to target the crucial first 1000 days from conception to the age of 2.

Thank you to the organizers of ICN2 for the efforts to plan and prepare for the event in November 2014, and for the opportunity to comment on the Rome Declaration on Nutrition document. It is critical for ICN2 to focus on a singular objective, to gain commitment and outline actions needed to reshape the global food system to improve people’s nutrition, and agree on a guiding principle that agriculture and food policies must first do no harm.

We applaud the inclusion of malnutrition in all its forms and believe that it is of paramount importance to not only treat and prevent the occurrence of malnutrition but also build sustainable food systems to ensure long-term impact. Moreover, it will be key to approach malnutrition in a comprehensive manner by demonstrating the linkages of nutrition with other relevant sectors of development including agriculture, health, water, sanitation, hygiene (WASH), gender equality, female empowerment, and governance.

We urge the following additions to the document:

A.      Paragraph 5: Under bullet point one: “Year-around access to sufficient food, adequate both in quantity and quality, affordable and culturally acceptable, is a key determinant; compounded and often aggravated, in a vicious cycle, by non-potable water, poor sanitation and hygiene, food borne and parasitic infections, and ingestion of harmful levels of chemical contaminants due to unsafe food supplies;” we suggest adding the bolded “and hygiene” above, as it is critical for water, sanitation and hygiene to be addressed together. 

B.      Under “A vision for global action to end all forms of malnutrition” section:

a.       Please include a point that specifically states that this will endorse and commit to actions to meet all of the 2012 World Health Assembly (WHA) nutrition targets.

b.      Thank you for recognizing that women and children have specific needs, however, under point (a) when you state: “the elimination of malnutrition in all its forms is an imperative for ethical, political, social and economic reasons, paying particular attention to the special needs of children, women, elderly and disabled people,” please add the line: “especially during the 1,000 day window of opportunity from a woman’s pregnancy to her child’s second birthday.” The consequences of malnutrition during the critical 1,000 day “window of opportunity” from a woman’s pregnancy to her child’s second birthday are largely irreversible, and can cause long-lasting damage. Maternal nutrition and support are therefore crucial to break the intergenerational cycle of malnutrition and build the foundations of healthy individuals and societies.

C.      Under the “Recognize that” section:

a.       We suggest adding a point that reads: “Recognize that a framework for collective commitment, action and results is needed to reshape the global food system to improve people’s nutrition, particularly that of women and young children during the critical 1,000 day window from pregnancy to age 2.”

D.      Under the “Commitment to action” section:

a.       It is critical to make the commitments to action list more specific and ambitious. We suggest the following commitments be added to the list:

·         Accelerate progress to achieve the 2012 World Health Assembly nutrition targets at national levels.

·         Governments and donors commit to, and ensure implementation of a long-term, adequately resourced, equitably delivered national minimum package of direct nutrition interventions.

·         All countries establish (or enshrine, if already established) a multi-sectoral coordination mechanism for nutrition to ensure that policy decisions are owned by all relevant ministries and have domestic budget lines for nutrition; as well as appoint a government nutrition focal point who is responsible for ensuring that the country’s nutrition efforts effectively engage the whole of government and external stakeholders.

·         All countries expand their target nutrition group to include women and children in the 1,000 day window from pregnancy to age 2.

·         Nutrition is integrated into national social protection policies for young children, pregnant women, and breastfeeding and lactating mothers.

We would also appreciate your vision on policies, programmes and investment that might help translate such commitments into action.

We recommend the following:

·         Normative guidance from FAO/WHO on how agriculture programs, investments and policies can deliver greater nutrition impact and nutrition-centered approaches to agricultural production. Reframe the food debate around the consumer, including education around healthy consumption, affordability and preparation.

·         Support and strengthen the Scaling Up Nutrition (SUN) movement.

·         Develop long-term funding and technical assistance provision options for countries and communities to address malnutrition, looking to HIV/AIDS, education and other models.

·         Build a nutrition data revolution, measuring and understanding what people eat and increasing the quality and quantity of nutrition outcome data and analysis. For example, a new partnership with Gallup could expand their voices of the hungry survey, including Save the Children's cost of the diet survey which evaluates the costs of a nutritious diet in a local context and the extent to which households can afford it. This could be included in official statistics collection, or MICS and DHS surveys, and be expanded via partnerships with telecommunications firms to collect data on production and consumption.

·         Level the playing field: agriculture has been focused on producing certain crops (e.g. staples like cereals), which help to grow the economy, but this has led to a neglect of nutritious foods. Most agricultural policies are biased to staple foods; we need to let “healthier” foods become more competitive and accessible.

·         Increase control by women of key resources such as land and microfinance–with the idea that women would more likely grow and distribute more nutritious food.

·         Governments generally have agricultural policies not “food” policies (e.g. looking at nutrition enhancing efforts within food chains). There are no incentives for this; so we need to focus more on developing food policies, keeping in mind that the private sector is a big player in this arena.

·         Education – change the understanding among consumers so that they are more nutrition conscious and create demand. 

·         Partnerships with multilateral institutions, NGOs and businesses on nutrition and breastfeeding behavior change communication. 

·         Develop examples of best practice of food and nutrition strategies at a country level which focus on increasing the value proposition for export markets, while focusing on improving access to nutritious food among poor and marginalized groups. This should focus on pre-empting and responding to the challenge of non-communicable diseases, as well as looking at the challenges of increased populations, volatility, etc.

Thank you for providing an opportunity to comment on this important document. 

The document does mention the need for multisectoral action to address malnutrition (both under and over nutrition) but from paragraph 12 down, including the section on commitments to action, the text only makes reference to food as the area of focus in preventing malnutrition. The document could be strengthened by including actions in health and other sectors such as water, sanitation and hygiene promotion. Also, the formulation of the first commitment to action (a) leaves out micronutrient deficiency (where food and food fortification, including biofortification, has a key role to play) and does not mention adolescents as a target group and there is no reference to the 1000 day window). There is very little mentioning on the role of the private sector and research institutions and UNICEF, WFP and REACH are not mentioned as key actors in supporting governments in developing, implementing and monitoring their national nutrition plans (point 14 under commitments to action). The SUN movement is also not mentioned.

In short, I believe the document could gain from better reflecting that food security is necessary but not sufficient for nutrition security.

Disclaimer: The comment above is an expression of my personnel views and should not be seen as an expression of the view of UNICEF.