Forum global sur la sécurité alimentaire et la nutrition (Forum FSN)

February 18, 2017

It is my honor to be asked to comment on this important matter. Respectfully, after reading the First Draft the following are my comments. May you and yours…Be In Good Health.

RE: Dawson, Laura - Comments on: FIRST DRAFT, 27 JANUARY 2017 – Work Programme of the UN Decade of Action on Nutrition 2016-2025

1.       Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources?

a.       Yes.

b.       However, nowhere in this work programme did we see the mention of an essential element of nutrition for human sustenance; WATER, safe clean drinking water was declared a right by the United Nations several of years ago.

c.        Here in the United States these regulations fall on urban leadership to keep the drinking water supply safe.

d.       In rural areas, including farms there is no regulation to guard against water borne diseases, which can be insidious and tenacious as often these microbiologic pathogenic factors are not visible to the human eye.

e.        We believe clean, safe, drinking water needs to be included in the Decade of Nutrition oversights to assure overall quality of life and health.

2.       What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition?

a.       Food in and of itself is or can be a social conversation with most people, however as a healthcare professional using food to heal or treat diseases, the master’s thesis I developed is only as good and the use by a patient or consumer.

b.       We would be wise to remind/encourage each individual of their own responsibility to know how their personal constitution assimilates and utilized food energy, and water needs, that are essential to Quality of Life.

c.        In the traditional oriental medical model taught in most acupuncture colleges in the US, we may likely have been taught to discern or diagnose using the Eight Principles [Hot vs Cold, Internal vs External, Excess vs Deficiency and Yin vs Yang]. Also, many of the schools in the US teach the Five Element Theory, which is more subjective rather than the objective. Whereas the measurable comparisons of the Eight Element Model for Diagnosis, Treatment and Prognosis make it a more transferable and usable model of medical care. These Eight Principles are used when learning to apply foods based on color and flavor, as well as the amino acid, fat, enzymatic compositions that cool, warm, moisten, dry, stagnate or move, organ systems and functions with the human body.

d.       I believe this makes the certified, ‘Food Physics & Body Dynamics’ transferable locally, nationally, and internationally.

e.        Finally, there are no parts of this draft in which WATER is mentioned let alone prescribed as an essential fluid to be consumed, and expelled appropriately to sustain Quality of Life.

1.       Somewhere, we will need to open the discussion on just what and how clean drinking water is accessed and consumed, and its role to sustain a healthy state of well-being, as a part of the whole nutrition aspect.

3.       Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas?

a.       Yes, We have a nationally and internationally Certified Nutrition Education Protocol, which has been approved to teach licensed health care professionals to meet the requirement for Continuing Education in Nutrition as mandated in several states and countries.

b.       I personally, have academics at a college and post-graduate level, have participated in policy making regarding access to healthy food and the Food and Drug Agency [FDA] in the capacity building of the newest Food Safety Modernization Act, instituted by President Obama in 2011-2012.

c.        As a member of the public and a candidate to write the American Food Guidelines, it was my honor to be asked to contribute to the final published Food Guidelines in 2004, published in 2005.

d.       As a stakeholder on several committees at the USDA Center for Nutrition Policy and Promotion, Food Safety and Inspection Services, and now on two Codex Alimentarius Committees, I have added expert comment and suggestions for more than a decade.

e.        As a hosted participant, I contributed my expertise in Urgent Evoke, an event designed to address the world’s biggest issues conducted by International Bank for Reconstruction and Development (The “World Bank”), and am a Founding Member effective 2010.

4.       How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing?

a.       Recognizing that communication is the first and foremost matter we will need to resolve as to how and when we will address these important matters.

b.       Nutrition Education models and certifications for those models will be helpful to encourage ongoing participation and maintain and high level of engagement by us as authors/creators of systems to achieve our desired outcomes and for the global community we are working to serve.

c.        Clean water access as a necessary component of nutrition consumption, in addition to being necessary for clean and safer food use in the kitchen and at the table.

d.       Ideas how to overcome language barriers during the work programs.

1.       A suggestion, in the recent past, SKYPE in the Classroom was formed and utilized by USDA to communicate to young students in schools for comparisons of foods being consumed.

2.       This source could be used in the meetings to accomplish our common goals, and/or

3.       Microsoft has a whole set of tools for Education and Communication here: https://education.microsoft.com/microsoft-innovative-educator-programs/mie

5.       Do you have specific comments on the section on accountability and shared learning?

a.       While not certain how Member States will select their representatives, it is my desire to serve as a representative, or on one of the committees, or boards, as a United States health care professional who specializes in using foods to heal disease and citizen, if that may be feasible. If you have recommendation or suggestions how to facilitate this role, please advise me via direct email using my FAO forum contact information.

b.       I look forward to working on the UN Decade of Action on Nutrition 2015-2015 in collaboration with the UN FAO, and other stakeholders to set benchmarks for the development of commitments and the establishment of action networks to address the potential topics suggested in Table 1.

Dear facilitator and colleagues,

Thank you very much for this opportunity to provide feedback on the first draft work programme of the UN Decade of Action on Nutrition.

Please find below the joint feedback of the co-leadership team of the Sustainable Food Systems (SFS) Programme of the UN 10-Year Framework of Programmes on Sustainable Consumption and Production (10YFP).

Best regards,

Patrick Mink

1.     Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources?

Yes, in general the draft work programme does present a compelling vision for strategic interaction and mutual support. However, while there is much focus on the role that governments/countries can play, for example as Nutrition Decade champions and/or by establishing action networks, there seems to be less elaboration on the potential roles for other actors and bodies, such as multistakeholder partnerships, for example with regard to action networks.

2.     What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition?

As the Co-Leads of the Sustainable Food Systems (SFS) Programme of the UN 10-Year Framework of Programmes on Sustainable Consumption and Production (10YFP), we would like to propose to strengthen the draft work programme by including also a reference to the SFS Programme in the context of multistakeholder platforms, i.e. in paras 54 and 69.

For the reasons outlined in response to question 3 below, the Co-Leads of the SFS Programme look forward to actively support this joint effort of making the UN Decade of Action on Nutrition a success.

3.     Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas?

We believe that the SFS Programme can make a meaningful contribution to the Nutrition Decade, in particular with regard to Action areas 1 “Sustainable, resilient food systems for healthy diets” and 6 “Review, strengthen and promote nutrition governance and accountability”, but potentially also others.

The 10YFP is a global framework of action to enhance international cooperation to accelerate the shift towards sustainable consumption and production (SCP) in both developed and developing countries. It reports to ECOSOC and the High Level Political Forum on Sustainable Development.

The SFS Programme of the 10YFP promotes sustainable food systems through activities at global, regional and national level. It contributes to the achievements of several Sustainable Development Goals (SDGs), in particular SDG 2 and SDG 12, as well as a series of issues covered by other SDGs including in the areas of health, biodiversity and ecosystems, partnerships, etc. The SFS Programme has five focus themes: sustainable diets; sustainability along all value chains; reduction of food losses and waste; multi-stakeholder platforms; and resilient, inclusive, diverse food production systems. The Programme promotes multistakeholder projects and initiatives along these focus themes, both at the policy level as well as through action on the ground - raising awareness, promoting enabling environments, and facilitating access to knowledge, information and tools.

The SFS Programme has four Co-Lead organizations (South Africa (Department for Trade and Industry), Switzerland (Federal Office for Agriculture), Hivos and WWF). They are supported by a 23 member Multistakeholder Advisory Committee (MAC), composed of organizations from the following five stakeholder clusters: government agencies; civil society organizations; scientific and technical organizations; UN agencies and other international organizations; and private sector. In addition, the Programme currently has more than 95 partners worldwide.

On February 13th, 2017, the SFS Programme MAC endorsed the Programme’s initial eight core initiatives. One of them – under the leadership of FAO and UN Environment, and in collaboration with UNSCN, CIHEAM, Hebrew University, ENEA, Organics International and WWF – aims to identify indicators for sustainable diets and develop guidelines for assessing the sustainability of diets. This core initiative is in line with Action area 1 of the draft work programme. Another one of our core initiatives – under the leadership of Hivos, Biovision Foundation and UN Environment – aims to develop and support inclusive multi‐stakeholder platforms at local and national level, in line with Action area 6. Furthermore, the SFS Programme has a core initiative that aims to strengthen methodologies and capacities on quantifying as well as reducing food losses and waste (FLW), and to establish a global community of practice on FLW. This core initiative is being lead by UN Environment and FAO, in collaboration with WWF, Nestlé, South Africa (dti), CIHEAM and WRAP, and it is in line with the potential action network “Reduction of food waste and losses” contained in table 1

The 1st Global Conference of the SFS Programme will take place on 21-23 June 2017 in Pretoria, South Africa. With an expected participation of 150 food system experts from all relevant stakeholder groups and around the globe, this conference could offer a good opportunity to raise awareness on the Nutrition Decade as well as for approaching potential partners.

In its resolution on Agriculture development, food security and nutrition of 2015 (A/RES/70/223), the United Nations General Assembly welcomed the launch of the SFS Programme. In October 2016, the FAO Committee on Agriculture requested FAO to strengthen its work on sustainable food systems in relation to the 10YFP. For more information on the SFS Programme, please refer to the programme brochure, and see: http://www.scpclearinghouse.org/sustainable-food-system

4.     How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing?

The achievement of the Sustainable Development Goals (SDGs) requires an inclusive and holistic approach, accounting for the interlinkages between the goals and targets of the 2030 Agenda, in order to avoid silo thinking. Therefore, we welcome very much the food systems approach that is promoted under Action area 1, which takes into account all stages of the food value chain and links the concepts of healthy diets and sustainable diets. However, in para 20, reference is made to guidelines on healthy diets only, which falls short of the multistakeholder food systems approach that is required to achieve the food and nutrition related SDGs of the 2030 Agenda. We therefore propose to refer to “[..] guidelines on sustainable and healthy diets“ in para 20. 

In addition to the potential topics for action networks listed in table 1, there may be scope for further topics, such as sustainable diets; sustainability along all value chains; and resilient, inclusive and divers food production systems.

5.     Do you have specific comments on the section on accountability and shared learning?

No.

I would like to share another slide which demonstrates the importance of a balanced diet to prevent anemia, it is not done with an iron alone intervention - even if haemoglobin levels are increased it is not guaranteed that the person is healthier or less anemic....

2016-2025 is now. What FAO is waiting for. The SDGs was adopted since September 25, 2015. One year has passed and nothing. 2017 is passing.

1. Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources? Open and inclusive dialogues, biennial reports, open access databases and regular tracking are all good measure to ensure a well-structured action on nutrition coupled with advocacy and technical support all covered in this first draft.

2.What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition? Overall the first draft is comprehensive. The Nutrition Decade secretariat would benefit from working closely with civil society in order to keep governments accountable. In each country a strong CSO focal point would be beneficial in garnering support. The advocacy component is key to ensuring success of the vision of the UN Decade of Action on Nutrition.

3.Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas? As the only nutrition advocacy hub in Zambia, CSO-SUN is strategically positioned to handle action Area 6- to ensure commitments for action towards nutrition related policies and dialogue. CSO-SUN spearheaded the formation of the All Party Parliamentary Caucus on Nutrition (APPCON) which members of parliament MPs including key nutrition champions are advocating nutrition legislation and enhancing political will and accountability to address the burden of malnutrition. CSO-SUN also works closely with the media to keep nutrition relevant and has media trainings to increase accurate nutrition reporting thus creating space for dialogue.

4.How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing? Issues on lack of financial resources may delay progress especially where relevant policies exist and implementation due to financial constraints is often the issue.

5. Do you have specific comments on the section on accountability and shared learning? It’s imperative that the biennial reports that include government commitment should also reflect governments financial commitment as a criteria for commitment e.g. to nutrition related programs and national budget allocation towards nutrition.

Comment on Work Programme of the UN Decade of Action on Nutrition, 2016-2025

Dr Anne Marie Thow, Dr Phillip Baker, Dr Sinead Boylan, Dr Kieron Rooney, Ms Alexandra Jones and Dr Belinda Reeve on behalf of the University of Sydney Food Governance Node

We greatly appreciate the UN support for the Decade of Action on Nutrition, and we welcome the opportunity to comment on the draft of the Work Programme of the UN Decade of Action on Nutrition, 2016-2025. We applaud the WHO and FAO for the comprehensive first draft presented here.

Over-arching comments

-   From a nutrition perspective, the document would be strengthened by a clearer and more consistent conceptualization of what ‘healthy diets’ and ‘healthy food’ constitute, and the development of criteria on which definitions of healthy and unhealthy food might be based, to aid implementation of recommendations. In particular, considering level of processing, dietary diversity, and nutrients associated with poor health outcomes (such as fat, salt and sugar)

-   The document would be strengthened by reference to synergies with declarations on aid effectiveness (Accra Agenda, Paris Declaration) and policy coherence for sustainable development (OECD)

-   Despite the constraint in the Framework for Action that the work programme must be carried out within existing institutional arrangements and capacities, there is no information on existing remits of UN agencies or funding/administrative capacities. This is needed to ensure coherence and coordination among UN agencies involved – and also to ensure that member states are engaging most effectively with the UN.

-   There is only one mention of conflicts of interest. This would be strengthened with more concrete recommendations and guidance regarding operationalisation (i.e. how do countries achieve this).

-   The failure of many multi-sectoral nutrition coordinating bodies has resulted not from their technical competencies but from their failure to advocate for sustained attention, political commitment and resources at the country-level (i.e. from their organizational and strategic capacities). Again, this emphasises the need for country-level capacity building that focuses on more than just the technical aspects of nutrition policy and programming.

Guiding Principles

-   This would be stronger with more clarity regarding what is meant by an enabling environment (See Lancet series on child and maternal nutrition for a definition).

-   In paragraph 15, reference to the ‘latest’ scientific evidence is inappropriate – latest is not necessarily the best, most appropriate or most robust. High quality might be a more appropriate adjective.

Action area 1:

-   The meaning of the term ‘sustainability’ here is not clear, and the concept of sustainability is not reflected in the actions listed. More explicit content as to how sustainability will be achieved through food and nutrition interventions is needed (e.g. incorporation of sustainability objectives into food and nutrition guidelines).

-   The food system approach identified in paragraph 19 is hugely important – and should also explicitly mention trade in addition to transportation.

-   Paragraph 20 needs to include explicit recognition for the need for review of such policies and guidelines, in light of evidence for best-practice

-   In addition to improved production of healthy food, this section should also note the need for incentives to decrease production, availability, accessibility and affordability of energy-dense nutrient poor foods, and highly processed and packaged foods.

-   Food security ensures that nutritious food which is available, accessible and utilized by all. Utilization should be mentioned here.

-   The reason for singling out aflatoxins over other environmental hazards is unclear. Paragraph 22 would be stronger if it ended at line 6, ending with “directly and indirectly”. By keeping it generic, then a country could pick this action area and this specific focus on biological hazards to address and be free to focus on their country specific hazard.

-   The mention of Water, Sanitation and Hygeine here is very important – and could be further emphasized through prioritizing provision of safe water supply

Action area 2:

-   This section should include more specific reference to the recommendations on stunting, wasting, breastfeeding and overweigh/obesity identified in the Framework for Action.

Action area 3:

-   In line with the objective to address the dual burden of malnutrition, point 29 should also address the dual burden of malnutrition at household level, through explicit recognition of the need to design social protection measures with complementary policies that seek to minimize the transition of households to increased consumption of nutrient-dense foods, especially in low-income households with women, infants and children.

-   Point 31 should align with the policy options for diets identified in the recommendations of the Global Action Plan for the Prevention and Control of NCDs, and include specific mention of fiscal policies, regulations on marketing of energy-dense nutrient poor foods, nutrient and health claims, and agricultural/industrial policy incentives that reflect health considerations.

Action area 4:

-   A critical concern that needs to be explicitly addressed in this section is that trade and investment policy should not constrain innovation in nutrition policy making – countries need to have policy space to be able to implement new approaches to protecting nutrition and food security and preventing NCDs. This should be explicitly recognized as a policy objective by trade and investment agreements, such that it can inform interpretation of agreements.

-   It would be helpful to clarify the usefulness of frameworks, guidelines and strategies of agencies other than Codex (e.g. WHO, FAO, UNICEF) as reference points for interpreting WTO and other trade and investment agreements. (e.g. FCTC has been used as reference in trade disputes regarding tobacco)

-   This section should include a specific note on protection of breastfeeding, particularly in light of recent large-scale and rapid growth in global breast-milk substitute markets

Action area 5:

-   This section needs to explicitly incorporate NCD prevention – particularly with respect to access to affordable healthy food in 1) urban environments, 2) schools, 3) hospitals and nursing homes.

-   In line with this, this section should note the importance of reducing the availability, accessibility and affordability of energy-dense nutrient-poor food.

-   Paragraph 36 ends in a strange way by singling out hospitals and the workplace. More open ended text would be more appropriate, such as "in all environments a mother and child may find themselves in need of feeding"

Action area 6:

-   This section would be much stronger with more detail with respect to governance. In particular, specific inclusion of capacity building for governance at all levels, particularly in light of decentralization of power and authority underway in many countries (i.e. overcoming coordination challenges that come with increased role of state and local level actors in nutrition governance)

-   It would be helpful to reiterate previous recommendations (e.g. SUN) that the coordinating body should be situated in a supra-sectoral agency (e.g. national planning, office of PM), to facilitate multisectoral coordination; and if located within line agencies (e.g. ministry of health, agriculture, gender etc) these must be imbued with sufficient authority and capacities for coordinating actions (e.g. through resource control and performance-based budgeting mechanisms)

Implementation

-   “Commitments for Action” – Para 42, point 2, seems confusing: need a more specific connection between the issue-specific recommendations in ICN2 framework (stunting, wasting etc) and the cross-cutting themes in the Decade of Action

-   “Nutrition champions” concept could be strengthened by considering additional strategies to build capacity for nutrition leadership at global, national and subnational level, within government and civil society. For example, drawing on the African Nutrition Leadership Program, European Nutrition Leadership Program, and SUN leadership component. Strategies include: building capacity, mobilizing resources and strategic capacities. Otherwise, this ignores the diversity of leadership types needed for successful nutrition governance including advocates to generate/sustain attention and mobilize civil society networks, policy entrepreneurs who can navigate technical, bureaucratic and political environments, and high-level political leadership (e.g. heads-of-state and ministers).

-   The inclusion of the private sector in “Action Networks” is concerning, and there is no transparency in where the ideas for action networks have come from (“potential partners”?). We suggest inclusion of an additional statement regarding avoidance of conflict of interests here.

-   In addition, the proposed structure of the “Action networks” appears to limit participants to single topics rather than holistic integration of nutrition challenges. This potentially generates a high administrative burden (i.e. managing and attending network meetings and outputs) while also narrowing complex multi-sectoral nutrition problems down into vertical issue-specific responses.

-   The section on “Technical support for implementation” seems to imply that the challenge is a technical one in isolation from political and institutional environments in which nutrition actors operate. Strong evidence shows that technocratic approaches to nutrition are likely to fail in the absence of politically savvy leadership within countries.

o   Nutrition action is not just about technical capacity but also engagement with policy and practice

o   Imbuing nutrition policy networks within countries with necessary organizational and strategic capacities they require to navigate political systems and policy making processes.

o   This section would be stronger with a clearer statement of what is meant by Technical assistance and what it’s designed to achieved

Governance

-   This section is very vague on how actions will be coordinated across the various agencies.

-   The institutional framework for nutrition action at the global level is not clear and needs to be articulated, including clearly delineated roles and responsibilities for UN actors.

-   This section would be stronger with consideration of how this engagement will also engage with other existing multisectoral fora that relate to nutrition (e.g. Zero Hunger, NCD Prevention and Control), that engage UN and other agencies related to nutrition.

Feedback on the First Draft Work Programme of the UN Decade of Action on Nutrition, 2016-2025 from the Scaling Up Nutrition (SUN) Movement Coordinator & Secretariat 

We applaud the work of colleagues at WHO and FAO to bring together the latest draft of the Work Programme of the UN Decade of Action.  We would like to share some general comments on the overall direction of the documents.  We then include in annex some more specific comments related to various elements. 

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After years of neglect, nutrition has received unprecedented attention over the past several years.  This has resulted in some hugely promising commitments including but not limited to: the six global nutrition goals adopted by the WHA in 2012 and the nutrition and the NCD framework adopted at the 66th session of the WHA in 2013;  the Global Compact of the Nutrition for Growth meeting in 2013; the second International Conference on Nutrition (ICN2) in 2014, the adoption of the 2030 Agenda of sustainable development and in particular SDG 2 in 2015 as well as the World Bank-hosted Human Capital Summit in 2016 where ministers from nine countries pledged to improve nutrition, health and education programs for young children to dramatically reduce childhood stunting. In the SUN Movement, the leadership of the 59 countries and the Indian States of Maharashtra, Uttar Pradesh and Jharkhand as well as the large number of in-country stakeholders supporting the SUN Movement’s efforts to fight all forms of malnutrition are particularly promising,

A myriad of processes, projects and working groups have been launched to support these commitments -  government ministries, development partners, businesses and academia have begun to reorient their focus and realign their approaches to ensure that nutrition is at the heart of their work. 

Now is the time to secure the leadership and shine a light on the pathways to coherent ACTIONs leading to results and impact, which is at the heart of this Decade. 

We see the Decade of Action as the opportunity to consolidate the gains made in recent years and ensure that the final collective results are greater than the sum of smaller, disconnected or isolated efforts.  Most importantly, we see it as a platform on which country-ownership and leadership can be displayed, celebrated, better understood and further replicated.  It is also the opportunity to explain how UN agencies involved will work together to bring coherence, encourage and guide collaboration, support capacity, build trust and make smart use of what is going on, using the naming and faming method to encourage the smart and opportunistic combination of supports from various initiatives for better impact.

These elements are not easy to find in the document as it currently reads and we have some suggestions to help improve this. 

1.       This document could open by clearly demonstrating the urgency of securing lasting leadership for nutrition.  This could be done by concisely summarising the powerful evidence of the impact that good nutrition has on people’s well-being as well as the business case of investing in nutrition. (This could be easily backed up by the various studies and reports that has been pulled together in recent years.)

2.       In order to ignite support behind a coordinated Decade of Action for nutrition, it would be helpful to:

a.       Remind the reader how harmful inaction can be.    In this sense, it would be useful to acknowledge how decades of underinvestment in nutrition further jeopardized the lives and potential of millions.   While at the same time highlighting that improved nutrition can contribute to GDP growth

b.      Celebrate what has already been achieved:   Acknowledge the huge gains made in recent years.  Illustrating this momentum with clear examples will help to set up this work plan up in a positive and inspiring way that compels the reader to participate in the Decade of Action.   

c.       Draw on what exists to sketch out a clear roadmap – highlighting existing processes and initiatives that bring results and impact at country level   and can be shared at regional events and global fora.

3.       The ‘aims and added value’ needs to feature much earlier

a.       Country-ownership and leadership on ALL forms of malnutrition

b.      Human rights based approach – with women and girls at the center

c.       Focus on evidence and results

4.       The 2030 Agenda and the SDGs have ignited a new approach that should define the spirit of the decade.  In particular, there are elements of the 2030 Agenda that are particularly relevant:  

a.       Universality – the 2030 Agenda belongs to everyone; there is no country that is without the challenge of malnutrition and every country should be able to find a role of some size and shape in this Decade of Action. The Decade is not only meant for developing countries but also crucial for countries that face a growing challenge of over-nutrition, obesity and related NCD’s. They can be partners in sharing expertise in preventing and fighting this.

b.      Transformative- people-centered, putting human rights and social justice at its core

c.       Partnerships – at the heart of the SUN Movement’s approach is the belief that every actor has a role to play – from governments, business, civil society, development partners and academia.  While the UN Member States are the primary audience for this work programme, it would be a missed opportunity if all of the existing partnerships were not encouraged to take part in this Decade of Action for nutrition.

The Partnerships Playbook, which was developed in partnership with Every Woman, Every Child, the Global Partnership for Education, Sanitation and Water for All, the Zero Hunger Challenge and the SUN Movement, was recently endorsed at the Second High-Level Meeting (HLM2) of the Global Partnership for Effective Development Cooperation as an official Global Partnership Initiative.  This could provide some inspiration for further developing this section of the work programme of the Decade of Action.

5.       The Rome Declaration and Framework for Action should be clearly referenced and concisely summarized but reopening or reinterpreting the substance in this document in the detail as currently expressed in six ‘areas’ doesn’t seem to advance collaborative action.  As suggested above, it may be more helpful to highlight the initiatives, mechanisms or opportunities that have been established or are underway in each of these areas and then spend more time articulating the entry points for UN Member States to engage and align with these and how WHO and FAO in collaboration with WFP, IFAD and UNICEF will support Member States to do this.

a.       Several examples include: highlight the objectives and process underway within the High Level Panel of Experts of the Committee on World Food Security to draft a paper on Nutrition and Food Systems;

b.      Be clear on the role that WHO, FAO and others can and will play in raising awareness and connecting Member States with these opportunities to contribute and build upon.

6.       Nutrition champions – There is much work underway that can be capitalized upon: The African Leaders for Nutrition; the SUN Movement Lead Group, the ambassador programmes of the UN agencies – particularly the celebrity chefs who have an enormous following across the globe. 

7.       Accountability and lesson sharing – There are several bodies to which UN Members States are already committed to reporting their progress and sharing lessons.  The challenge for this work programme is to show how these link together and suggest inclusive ways for Member States to engage in coherence with 2030 Agenda and the SDGs without imposing more arduous burdens

a.       The Voluntary National Review process of the High Level Political Forum for Sustainable Development

b.      Reporting to the WHA on the six global nutrition goals and the NCD framework

c.       Annual plenaries of the Committee on World Food Security (and in particular the work planned by its Open Ended Working Group on Nutrition)

8.       It would be very useful to include a calendar that maps out key dates and milestones for the Decade.

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More specific comments:

Point 2: Include a reference (footnote) to the Rome Declaration and the Framework for Action. It would be good to use ICN2 Framework for Action throughout the document. 

Point 5: Is the Framework of the Decade of Action on Nutrition (2016-2025) different from the Framework for Action (point 2 and 4)?

Point 9:

·         How is the “operational” framework different from the voluntary Framework for Action (point 2 and 4) and from the Framework of the Decade of Action on Nutrition (point 5)?

·         The third bullet point assumes that global commitments translate into national policies and programmes. This is not aligned with the country-led and country-driven bottom up process that is then described in other parts of the document.

·         On the NCD targets: please confirm that salt/sodium intake and obesity are the only two diet-related NCD targets considered by the Decade of Action and that diabetes and raised blood pressure will not be considered by the Decade of Action.

Point 11: Describes very well the added value of the Decade of Action. You may wish to review Point 9 in light of what is expressed under Point 11. It seems that some of the concepts are repeated or even reversed between Point 9 and Point 11.

Guiding principles: As mentioned above, WHO and FAO may wish to consider aligning with the 10 principles endorsed by the other partnerships including Every Woman, Every Child, the Global Partnership for Education, Sanitation and Water for All, the Zero Hunger Challenge, the SUN Movement as part of the Partnership Playbook.

Action Areas:

As expressed above, this section is unclear. Are the points a reminder on the types of actions that are already included in the ICN2 Framework for Action?

It might be more useful to simply clarify how the countries and partners can access and use the ICN2 Framework for Action document. It would even help to have an Annex with the summary list of the 60 actions included in the ICN2 Framework for Action for easy access and reference.

Nutrition education: Why is it linked only to social protection if this is clearly a cross-cutting theme?

Means of implementation:

It would make sense for this section to be the main focus of the Work Programme. It should provide much more clarity on how the Decade of Action will work with what is already existing.

Point 44: How will the UN Agencies solicit the engagement and support of other stakeholders?  Is a call for commitments from “other stakeholders” the only option? How will this be carried out, recorded and monitored? 

Point 45: It is difficult to understand what the high-commitments on ICN recommendations are.

Point 46: Nutrition Decade Secretariat is mentioned for the first and only time. It would be great to have more details on objectives and modalities of functioning. If a Nutrition Decade Secretariat is to be set up, it will be crucial to avoid duplication and mandate confusion with the existing UN coordination initiatives.

Action Networks

The first point should explain how the Decade of Action will effectively partner with the existing alliances, networks and initiatives to ensure increased focus and action.

The Action Networks could be a mechanism to ensure that the partnerships are accelerating and aligning efforts around certain topics.

Funding, TA and Advocacy: all three sections are very vague. We suggest the topic of funding is more precise.  The topics of technical assistance and advocacy could be well covered when highlighting the related existing initiatives in the ‘means of implementation’ section.

Potential Topics in Table 1: How do these topics link with the ICN2 Framework for Action? Should the ICN2 Framework for Action not be the reference point for the establishment of the Action Networks?

CIAI– Italian Association for Aid to Children – we really appreciate the invitation of UNSCN to share our views about the draft. We would like to bring your attention to the specific measures that  have been taken in consideration in the “Action area 3: Social protection and nutrition education” and along the full draft, regarding children of all ages.  Form our experience of almost 50 years working with children, we consider that Governments, non-governmental organizations (NGOs), the private sector and nutrition advocates should also promote more participative actions, where children are not only a passive receptor of school feeding programs and nutritional education, but participate actively during the programming, implementation and valuation of the actions and services addressed to them. Children’ of all ages should have an active role that can be activated through children  clubs, schools committees for food, nutrition,  and WASH services, and their participation in the local and national level consultation platforms, to increase the effectiveness and sustainability of the measures to address malnutrition challenges.

Dear UNSCN,

Thank you for the opportunity to comment on the first draft Work Programme of the UN Decade of Action on Nutrition. The Coordination Unit of the Global Agriculture and Food Security Program (GAFSP) is pleased to provide responses to the following questions posed in the FSN Forum:

What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition? It may be helpful to have a simplified/”big-picture” Theory of Change (ToC) of the Nutrition Decade demonstrating links and sequencing among various elements listed under Principles and Action Areas.  Moreover, a ToC approach could help conceptualize appropriate indicators to measure progress.

Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas? Yes. GAFSP invests in agriculture to reduce poverty and improve food and nutrition security in low-income countries through investments in both the public and private sectors.  

More than half of the Public Sector Window projects in the current portfolio include nutri­tion-related activities, totaling $140 million (about 14 percent of fund­ing from the Public Sector Window financing). About two-thirds of the nutrition-related spend by GAFSP is on nutrition-sensitive agricultural activities, while about a third is for direct nutrition-specific activities, such as the distribution of micronu­trient supplements (such as folic acid and iron to pregnant women, women of reproductive age, and adoles­cent girls, or sprinkles for children), behavioral change campaigns, and improving home conditions (kitchen and latrines).  

The Private Sector Window also addresses the issue of chronic mal­nutrition and its negative impact on human capital development. In 2015 the Private Sector Window made an investment in Africa Improved Foods Limited (AIFL) to establish a nutritious food processing plant in Rwanda that will feed 700,000 malnourished children in that country each year. The AIFL project is simple but prom­ises significant development impact. Using maize and soy sourced and grown locally by Rwandan farmers, the processing plant will develop fortified blended foods for young children and their mothers, support­ing the prevention and treatment of malnutrition in this vulnerable popu­lation. The project is part of a broader public-private partnership between the Clinton Health Access Initiative, the World Food Programme, the IFC, the government of Rwanda, GAFSP, and private sector actors. This project enables GAFSP to help malnour­ished children by giving them access to fortified nutrients that will allow them to reach their full potential. It also means that farmers in Rwanda can gain access to higher-quality inputs and better farm management practices.

Moreover, going forward, GAFSP will measure progress towards food security by using the SDG2 Indicator for hunger, the Food Insecurity Experience Scale (FIES), as well as the Food Consumption Score (FCS) to track progress on improving dietary diversity of households; or, for individuals, the Minimum Dietary Diversity of women/young children (MDD-W/C) where these are explicit objectives in GAFSP projects. GAFSP, thanks to its strong M&E system aligned to the SDGs, is leading efforts to implement the use of FIES in projects.

Lastly, GAFSP as a multistakeholder platform of an  inclusive approach has a balanced representation of donors and recipients, strong participation of partner institutions and civil society throughout the project cycle, and growing private sector involvement across the program. Three of the Decade  conveners, specifically FAO, IFAD and WFP, are also participating in GAFSP.

How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing? The roles of the private sector and the public at large could be highlighted further as being part of the collective action required.

Do you have specific comments on the section on accountability and shared learning? There are other overall accountability frameworks and networks that could be acknowledged. The Decade Action Plan could explore explicit synergy with for instance the formal Agenda 2030 monitoring and accountability system that lies within the High-Level Political Forum and ECOSOC, or the SDG2 Accountability Framework led by the GODAN Secretariat.

Comments provided on behalf of the GAFSP Coordination Unit, acknowledging kind assistance of Nadim Khouri.

Kind regards,

Aira Htenas

Agric. Economist

World Bank Group

This Decade document is unfortunately quite disapointing. It has no teeth. It repeats all the old (predictable) remedies and cliches. It is jargony. It too often states the obvious.

By paragraphs:

4, 38, 54. multistakeholder platforms are taken as a given. Will not more people oppose this? The conflicts of interest (CoI) issue has not been solved...

9. "Leaving no one behind"… You know the quote that says that this is not an accident.

     The para also speaks of a "global accountability framework": where is such to be found?

12, 13, 15, 38, 41, 44, 54, 67, 69, 73.  “Stakeholder” is used over and over. In many of these places, using rights holders and duty bearers is what is called for.

12. The SUN initiative is mentioned casually…without quoting what some of its detractors object.

13. 31. Speak of CSOs or NGOs as the same. It should say (private interest CSOs (PICSOs). It mentions ”an enabling environment” for HR and the RTF. Only enabling? Isn't it to be the cornerstone?

13. The para only says “management of CoI”. Will we demand stronger language on CoI?

14. Speaks of  “an enabling environment” for HR and the RTF. Will we demand stronger language?

16. Cross-cutting area #4 calls for “trade and investment for improved nutrition”. How? Does past experience teach us something?

17. Asks for “fostering policy dialogue…to ensure that solutions are equitable and people-centered”. This is not what the HR framework calls for! Claim holders demand!

19. Paragraph sooo weak..

20. Calls for “strengthening local food production especially by small holders”. This is not what we stand for. Language already a consensus puts central emphasis on small holders.

29. Mentions “nutrient dense foods”. Which? RUTF?

30. This para on nutrition education is sooo weak and naif. Could have been written in the 1970s.

31. “Lead by example” ????

34. Are only “coherence and flexibility” needed??

35. “Achieve global food and nutrition through trade", i.e. “appropriate trade agreements”? What is that?

38. “Multistakeholder governance mechanisms should avoid Coi”. We certainly need stronger wording here.

41. “Member states are encouraged to translate the commitments of ICN2”. Just encourage?? (Then in para 42 there is a call for them to actually commit…. A contradiction).

The mention of SMART here is a gimmick, just for show.

43. The call is “to raise the level of ambition”. Only? Need stronger language?

45. Speaks of a “commitments repository in FAO and WHO”? Would this work and be binding?

47, 48. The call here is for “champions” and “action networks”; seems to me wishful thinking. I may be wrong.

54. “SUN will provide opportunities”? How many years has SUN been on? What to show for?

59. “The Decade will strengthen the capacities at community level as appropriate? Meaning what? Far from what we are asking for re empowering clim holders and duty bearers...

63. Calls for “Evidence-informed advocacy”. What gimmick is that? Does scientific evidence convince politicians?

64. What “visual identity” is referred here to?

69. We read “FAO/WHO will consult with the private sector” …for governance issues? This sentence is in the governance section!! Needs to be deleted. No private sector in governance.

Table 1. Proposes a “reformulation” of foods group. We all know what Monteiro and Cannon say about this giving BIG Food a way to whitewash their image and the public still staying hooked on ultrprocessed foods.

The table also proposes a nutrition sensitive issues group. We all know this was invented as a (bad) substitute for what are the social determinants of nutrition.