The programme provides concrete guidelines and steps forward in the Decade of Action on Nutrition. Yet, it may profit from a more proactive policy-oriented focus.
· The work programme is comprehensive and: a) provides a summary of the state of affairs on global malnutrition; b) distinguishes the various forms of malnutrition (undernutrition, vitamin & mineral deficiency, overweight/obesity, diet-related non-communicable diseases), c) identifies the international framework of agreements that prioritizes nutrition, d) identifies aims, added value, guidelines, actions areas, means of implementation and accountability elements.
· Actions areas and means of implementation constitute a sizable part of the substantive parts of the programme. It would be important to include or make reference to relevant experiences of nutrition programmes and actions, to set a more grounded context under which aims and action areas of the Nutrition Decade can occur.
· With regard to the background section, please note:
· The CRPD requires State Parties to “prevent discriminatory denial of…food and fluids on the basis of disability” [CRPD 25(f)]
· The CRPD requires State Parties to “take appropriate steps to safeguard and promote the realization of […the right to adequate food…] without discrimination on the basis of disability” [CRPD 28]
· The 2030 Agenda recognizes that 80% of persons with disabilities live in poverty (at para. 23)
· Children with disabilities are at higher risk for malnutrition. A strong bilateral relationship exists between malnutrition and disability. The WHO report “Developmental Difficulties in Early Childhood” (2012) notes that Countries with high levels of malnutrition and nutrient deficiency often also report higher rates of disability and developmental delays. http://www.who.int/maternal_child_adolescent/documents/development_difficulties_early_childhood/en/
· The UNICEF report: “Stronger Together Nutrition-Disability Links and Synergies Briefing Note” highlights that maternal and early childhood malnutrition lead to the development of disabling conditions and that the children with disabilities are at higher risk for experiencing malnutrition. https://www.unicef.org/disabilities/files/Stronger-Together_Nutrition_Disability_Groce_Challenger_Kerac.pdf
· Action Area 3 (on social protection and nutrition education): Stigma surrounding disability may result in children with disabilities being given less nutritious or smaller quantities of food, or intentionally not fed at all, with families rationalising that limited resources should be devoted to children who have a greater chance of surviving and contributing to the household. In order to be fully effective nutrition education must include elements to combat disability stigma. (UNICEF report “Stronger Together Nutrition-Disability Links and Synergies Briefing Note” (2011) pg. 8)
· Action area 4 (on trade and investment) cites general yet relevant policy tools such as taxation, subsidies for health foods, removal of subsidies to unhealthy foods and supply-side incentives. It would be good that such rich identification be also complemented with analysis in this and other action areas.
· Action area 5 (Safe and support environments for nutrition at all ages):
· The places where food and water are obtained must be accessible to all. Community based health and nutrition services must be provided in buildings that are accessible.
· Child nutrition programmes should take into account that children with disabilities are less likely to attend school than children who do not have disabilities. Thus programmes designed to function only through school settings may not adequately reach children with disabilities. (UNICEF report “Stronger Together Nutrition-Disability Links and Synergies Briefing Note (2011) pg. 6)
· Action area 6 (Review, strengthen and promote nutrition governance and accountability): It would be useful to take into account the observations on institutions and linkages to SDG2, that was considered in session 3 of the expert group meeting held in Vienna in preparation for HLPF 2017 on readying institutions and policies for integrated approaches to implementation of the 2030 Agenda (with FAO, WHO and UNICEF in attendance, among others). (available at http://workspace.unpan.org/sites/Internet/Documents/Report%20Vienna%20meeting%20FINAL.docx.pdf
· Table 1 is a great contribution to the identification of concrete areas of potential collaboration among governments and other relevant stakeholders in terms of means of implementation (p.14).
· It would also be important to allude to the linkages between agricultural sustainable policies and complementary policies in the industry and services sectors. For example, the provision of "incentives for local and small farmers and SMEs" (p.14) would be more effective if industrial and environmental policies were part of a national development strategy that prioritizes sustainable agriculture by strengthening capacities for a) seeds production, b) commercialization, c) transport infrastructure, and d) access to affordable food.
· A linkage between Action 2 (health systems) and Action 3 (social protection and nutrition education) may be needed: while Action 2 alludes to the provision of "universal health coverage UHC), Action 3 alludes to "basic or minimum social protection floors" (p.6). It would be worth considering "health care floors" as complementary or part of "social protection floors" – as anchor for 'minimum and broader floors' in all countries.
· The programme is inclusive of all relevant stakeholders and aims at supporting "the establishment of action networks". Nonetheless, this would still be a top-down approach unless it includes and prioritizes a) the farming experiences at the local level, b) agriculture as an engine of growth and higher productivity, and c) agriculture, forestry, and fishing activities as cornerstones of sustainable processes of structural transformation.
· We note that there is only one reference to indigenous peoples. We believe that it will be important to include references to traditional knowledge systems and traditional livelihoods. These are referenced in the 2007 UN Declaration on the Rights of Indigenous Peoples and also in the outcome document of the 2014 World Conference on Indigenous Peoples (A/RES/69/2):
· OP 22. We recognize that the traditional knowledge, innovations and practices of indigenous peoples and local communities make an important contribution to the conservation and sustainable use of biodiversity. We acknowledge the importance of the participation of indigenous peoples, wherever possible, in the benefits of their knowledge, innovations and practices.
· OP 25. We commit ourselves to developing, in conjunction with the indigenous peoples concerned, and where appropriate, policies, programmes and resources to support indigenous peoples’ occupations, traditional subsistence activities, economies, livelihoods, food security and nutrition.