Global Forum on Food Security and Nutrition (FSN Forum)

Please find our contributions in the attached Pdf document.

Thank you,

Lida Lhotska

on behalf of IBFAN, the International Baby Food Action Network

Dear Sir/Madame

The ICN2 frame work for action is an excellent document.  I would like to congratulate all those- country and regional representatives-  who were involved and participated in the writing of the frame work for action draft. We had an input in the EMRO region through our Oman representative.

It is well structured; important nutrition issues regarding political will and commitment, social protection, economic, health and agriculture and others are properly addressed ; what is needed is strategies (with prioritized action plans) and commitment to implementation.

This document will certainly be used as reference and guide to many nations for hopefully achieving the goals and targets.

Wish you a successful ICN2 meeting and fruitful outcomes;

Dr. Nawal M. Al Hamad, MD, PhD

WHO Temporary Regional Nutrition Adviser, EMRO

Director, Food and Nutrition Administration,

Ministry of Health, Kuwait.

Addressing point 4:

Mission for long term sustainability of smallholder producer communities:

The UN agencies correctly have and continue to sound alarms about the urgent need for the rural poor smallholder producer communities (about 50% of the world’s population), to return to producer oriented, economies of scope development, following ecological/ natural/ organic agriculture systems, being sustainable in the long term, thus ensuring their access to nutritious food needs, at little or no cost and also feed the world. In contrast, the United States, Canada, Australia and some EU governments are pushing for the high cost external input, chemical intensive and corporate-dominated industrial farming systems and now also GMOs. UNCTAD report, link at:

“Trade and Environment Review 2013: Wake Up Before It’s Too Late,”

has contributions from more than 60 scientist/ experts around the world, mostly re iterating the findings of the IAASTD report, link at:

 December 2010 UN Report

Reports also argue that smallholder producer communities following low cost organic/ natural/ ecological agriculture systems of their area is the answer for “feeding the world,” not the high cost conventional Industrial/ GMOs with a focus on mono cultures agriculture systems, being the cause of distress, deep debt and suicides.

The UN reports rightly calls for, major changes in food, agriculture and trade systems, to focus on  meeting the conversion needs of the rural poor smallholder producer communities, if they  are to access their requirement of nutritious food, thus reducing hunger, malnutrition, poverty and suicides  whilst improving livelihoods, increasing net profits and purchasing power, effects of climate change and ensuring their long term sustainability.

These reports also demand that global trade rules be reformed in order to work toward these ends as the proposed trade deals like the Trans Pacific Partnership (TPP) and the U.S.- EU Trade and Investment Partnership (TTIP) are primarily designed to strengthen the hold of multinational corporate and financial institutions managing the global agriculture economy are mostly working against the rural poor smallholder producer communities. Further ,with food prices (and speculation in food prices) on the rise, the report states that the present conventional systems are seeking to accomplish the opposite by continuing to push for their high cost green revolution/ GMO technologies..

Thus, the reports call upon the Governments, National and Global Agriculture and Research Systems to shift from their conventional, high cost mono culture dependent external input based industrial production to following the low cost successful ecological/ natural agriculture systems, as applicable to the soil and agro climatic conditions in each area, that optimizes nutrition and improves  agriculture productivity of smallholder producer communities.

 

2.1 Enabling environment

a.   We are pleased the FFA recognizes the need to create an enabling environment for improving nutrition outcomes. An enabling environment is also critical for successful behavior change, which the FFA recognizes as a key policy and programme option (3.3.4).

b.   Creating an enabling environment requires recognising all the key barriers to achieving nutrition security. We agree with the FFA’s four key elements: political will, leadership, evidence and capacity. We recommend the inclusion of a fifth key element – equity. Although there has been progress in terms of child mortality and malnutrition, this progress has been matched with widening inequities. However recent process and technological innovations have provided effective options to reach those most in need.

2.2. Better governance for nutrition

Institutional arrangements that encourage effective multi-sector working

a.   We welcome the recommendation of ‘multi-sector working.’ Too often the responsibility for tackling malnutrition falls on the Ministries of Health (MoH). But no single Ministry can shoulder the all the responsibility for reducing malnutrition. The conceptual framework on the determinants of a child’s nutrition status emphasizes the need for a comprehensive and coordinated effort to improve the nutrition status of a population. All Ministries are responsible for some elements that impact nutrition status. Often the potential impact of one set of interventions delivered by one sector is undermined by the lack of interventions in another. We recommend the FFA encourages the adoption of explicit nutrition objectives and nutrition-related performance indicators for all key line Ministries.

b.   We recommend that implementation be delivered in a coordinated and joined up way that the addresses multiple causes of malnutrition through collaboration within sectors and across a variety of sectors that impact nutrition.

c.  We recommend that as well as encouraging multi-sector coordination, cooperation, and collaboration at the national level, institutional arrangements encourage multi-sector working to extend to district, municipal and village levels. Donors must recognize that improving coordination and collaboration requires resources and ample staffing.

d.   Additional priority actions should include:

i.   Encourage and foster wide civil society participation in the debate and negotiation of the FFA process, both at the global and national level. Civil society must have an ongoing seat on the bodies that monitor implementation of the Framework for Action.

Assessment and accountability

a.   We welcome the recommendation of regular assessments of progress. We recommend that transparency be at the heart of assessment and accountability processes. Transparency is key holding governments, and others responsible for nutrition, to account. Assessments, and subsequent data, should be easily accessible and released in an open format.

b.   The FFA recommends that assessments take into account such factors as climate change and political conflict, among others. We recommend that assessments take into account inequality, rights-based, and social factors, which also perpetuate malnutrition.

2.3 Financing for improved nutrition outcomes

a.   We recommend the FFA include commitments by donor countries (such as Nutrition for Growth, SUN, country bilateral and multilateral support for nutrition, and others), especially in cases where budget support is necessary for policy and implementation effectiveness. Stable, transparent and predictable financial commitment can help enhance policy coherence, coordination, country ownership, budget tracking and multi-stakeholder participation.

b.   The health sector has a vital role to play in delivering better nutrition. Investment in strengthening health systems must go hand-in-hand with implementing nutrition interventions, especially those that are primarily delivered through health systems (e.g. community management of acute-malnutrition (CMAM), vitamin A supplementation, support for early imitation of breastfeeding, etc.). The overall impact, and cost-effectiveness, of nutrition interventions depends on the strength of the health system through which they are being delivered. For example, weak health systems in high-burden countries are currently a major constraint to the expanding treatment of severe acute malnutrition and one reason why global coverage rates remain unacceptably low. We recommend the FFA recognize, within its priority actions, the necessary role of health systems strengthening in achieving better results for nutrition and the need to finance health systems strengthening alongside efforts to scale up nutrition interventions.

c.  Additional priority actions should include:

i.   Financing for strengthening health systems that puts a focus on nutrition- specific interventions and their inherent ties to other health interventions within smartly interlinked health systems.

·    Do you have any comments on chapter 3 (3.1 Food systems, 3.2 Social Protection; 3.3

Health; 3.4 International trade and investment)?

3.1 Food systems

a.  While the FFA recognizes that obesity contributes to the burden of non- communicable disease (NCDs), it should also recognize the role of undernutrition in perpetuating NCDs. Undernutrition is a precursor to a number of NCDs that are often associated with obesity and overnutrition, including diabetes and coronary heart disease.

b.  The FFA recognizes that economic growth at the macro level and income growth at the micro level can improve nutrition status. However, the FFA should be careful not to overplay the role of economic growth. Economic growth does not necessarily lead to improved nutrition. The Lancet Global Health, reported on the largest study to date to examine this issue with data from 1990-2011 in 36 LMIC including India, Colombia, Nigeria and many sub-Saharan countries and suggests that increases in Gross Domestic Product (GDP) over the two decades have generally not been associated with improvements in child nutritional status as economic growth can be unequally distributed, not spent in ways to enhance nutrition, and increases in household income may not be accompanied by the necessary public services and societal infrastructure to improve childhood nutritional status, e.g. additional income may be spent on non-food items. In regards to the role of economic growth, the FFA should reflect that the greatest impact is seen when efforts to improve economic growth are done in conjunction with other nutrition and health efforts. For example, India has experienced steady economic growth over the years, but rates of undernutrition have stagnated. Yet, the recent case of the Indian state, Maharashtra, shows what can be achieved when modest progress on a number of fronts (e.g. economic growth, empowering women and improving their maternal health; a committed government and improving services) combine. It is important to recognise that economic growth on its own has not been sufficient in leading to improved nutrition outcomes.

c.  The FFA states that it is important ‘to meet basic nutrition needs.’  It would be useful to have further clarification, or clearer definitions, about what constitutes ‘basic nutrition.’

d.  We are pleased the FFA recognizes the need for nutrition education to be combined with other efforts to improve nutrition. We recommend the FFA expand on this to specify the inclusion of nutrition within the national curriculum, in primary and secondary schools, as well as nutrition education targeted to adults, including women and men. We recommend nutrition education should be broad and, as well as teaching children about ‘appropriate diets’, should include other aspects of nutrition such as WASH and disease control.

e.  We welcome the FFA recognition of the importance of gender-sensitive interventions for improving nutrition. However, the current draft does not mention the role of men in improving nutrition. For instance, educating fathers about the benefits of breastfeeding is critical in creating an enabling and empowering environment for mothers to breastfeed their children. It helps overcome cultural norms and myths that can inhibit mothers from feeding infants colostrum and breastfeeding exclusively. We recommend the FFA recognise the role of men in decision-making and the need to make men more nutrition aware. We recommend that gender-sensitive interventions be targeted at both men and women.

f.   We are pleased that the FFA recognizes the importance of preventing acute malnutrition through building resilience to shocks. However, acute malnutrition is not a condition that is exclusive to emergencies. Many donors are actively bridging the gap between humanitarian and long-term development funding for the treatment of acute malnutrition, recognizing that many children are at risk during periods of stability and that governments need long-term funding to plan and implement strategies to address acute malnutrition.

g.  While prevention is the first step towards management of severe

acute malnutrition (SAM), urgent action is needed to minimize and avoid the risk of death. In many poor countries the majority of children who have SAM are never brought to health facilities. However, recent adoption of Community-based Management of Acute Malnutrition (CMAM) has proved to be successful in treating the condition.

h.  The FFA recommends integrating explicit nutrition objectives into agricultural strategy policy and programme design and implementation. We recommend the FFA encourages the adoption of explicit nutrition objective in all strategies and policies that impact nutrition status.

3.2 Social Protection

a.   We question whether all social protection strategies can be effectively “country- owned” when some marginalization may be exacerbated by government policy, actions, or reinforcing of the status quo. While government leadership on social protection is a vital component of this area of the work, outside evaluation is also needed and, we feel, can be an effective component of country ownership work on nutrition.

b.   The ‘first 1000 days’ between pregnancy and the second birthday of a child are noted to be crucial—and we agree. But we must remember that effective interventions for the health of the child start with ensuring the overall health of women of reproductive age even long before they consider beginning a family.

3.3 Health

a. We are pleased the FFA recognizes the vital role the health sector pleased in delivering better nutrition. However, too often the responsibility for tackling malnutrition falls solely on the health sector, through Ministries of Health. But no single sector can reduce malnutrition working alone. The conceptual framework on the determinants of a child’s nutrition status emphasizes the need for a comprehensive and coordinated effort to improve the nutrition status of a population. All sectors – health, education, WASH, agriculture – are responsible for some elements that impact nutrition status. Often the potential impact of one set of interventions delivered by one sector is undermined by the lack of interventions in another.

c.  We are pleased the FFA recognizes the need for universal health coverage to be integrated in the post-2015 development agenda. We recommend that FFA also recognize need for nutrition to present as a stand-alone goal and the inclusion of nutrition in the goal on health, with appropriately ambitious targets to reduce both stunting and wasting, that are in line with the WHA targets for 2025 and extend proportionately to 2030.

d.   Additional priority actions to address wasting should include:

i.   A wasting target in the post-2015 development framework, under the nutrition stand-alone goal.

ii.   Establishing national wasting targets to help focus efforts on tackling acute malnutrition, which includes a target for reducing the global rate of acute malnutrition to below 5% by 2025 (WHA targets see above). Building on this, all high-burden countries should establish national wasting targets, which would help focus domestic attention on this task and help ensure a joined-up effort across a range of sectors.

iii.   Strengthening health systems to enable long-term expansion and affordability of CMAM.

e.   Additional priority actions to address stunting should include:

i.   A stunting target in the post-2015 development framework, under a nutrition stand-alone goal.

3.3.1 Delivery of nutrition interventions

a.   There is a large body of evidence on the most effective direct interventions – the fortification of food and treatment for acute malnutrition, for example. It is widely acknowledged that micronutrient fortification schemes are extremely cost-effective and can be delivered at scale.

b.   Any gains made through these types of nutrition-specific interventions can be undermined without progress also on the underlying factors, those that need to be addressed through nutrition-sensitive interventions. We recommend the FFA detail the supporting role of nutrition-sensitive interventions and supporting stakeholders in achieving nutrition-specific work, and the need to build the evidence base for nutrition sensitive interventions.

c.  We recommend the FFA provide a platform which improves the ‘nutrition sensitivity’ of existing programmes including, but not limited to, agriculture, early child development, social protection and primary and secondary education.

3.3.3 Breastfeeding

a.   We are pleased the FFA recognizes the importance of breastfeeding in improving nutrition outcomes. However, the draft does not recognise the barriers that inhibit women from breastfeeding according to WHO recommendations. Priority actions should endeavor to provide mother with an enabling environment to breastfeed, which require addressing:

·    The critical shortage of skilled health workers to support mothers to breastfeed in the first hour and to continue breastfeeding exclusively for the first 6 months. Evidence suggests that mothers are twice as likely to breastfeed within the first hour after birth if a skilled health worker is present. However, the shortage of global health workers means that too many mothers are not given the support to breastfeed in the critical first hour after giving birth.

·    The lack of legislation to support mothers in breastfeeding, particularly around maternity leave. A mother’s choice to return to work should not affect her ability to breastfeed.

·    The unsupportive work environments for breastfeeding mothers. They are not often conducive to help mother breastfeed. If mothers do make the decision to return to work employers need to provide safe clean environments for mothers to breastfeed, including on-site day-care and facilities for mothers to express and store breast milk.

·    The EFA should support governments to be stronger in standing up to multinational infant feeding companies that flout the code of practice on breastfeeding and the promotion of infant formulas.

·    The FFA should support the inclusion of Breastfeeding in the standalone goal on nutrition. Leaving breastfeeding out of the standalone goal, undermines the fundamental role that breastfeeding plays in child survival, early development, and in achieving the WHA’s nutrition target for 2025 and natural extensions of these targets for 2030.

3.3.3 Nutrition education for behavior change

a.   Education is not enough on its own to lead to behavior change. For example, many mothers may want to exclusively breastfeed their babies, aware of the nutritional and health benefits of breast milk; however, the environment is often not enabling to allow them to enact that behavior change. Short maternity leave and unsupportive work environments are major barriers for breastfeeding mothers. We recommend the FFA recognize the importance of providing an enabling environment for effective behavior change, and the priority actions reflect barriers to creating an enabling environment.

·    Do you have any comments on chapter 4-5?

Accountability Mechanisms

4.1.1 National Level

a.  While government reporting on implementation progress of national plans is a part of measuring progress for vulnerable groups, outside evaluation and monitoring is also needed to ensure accountability and standards of measurement across governments. Th SUN structures have a critical role to play in M&E of national progress.

4.2 International Level

a.  While the actors named should indeed take into consideration the final FFA, the document will be strongest and most likely to be used as an accountability tool if it begins by taking into account corresponding recommendations in existing international frameworks. For example, the FFA would be greatly strengthened through incorporation of targets in the finalized Open Working Group draft of the Sustainable Development Goals. Alignment with UN frameworks and processes is further underlined through the recommended by the stated want to use UNGA as a moment to update on progress against the FFA each year.

b.  The annual Global Nutrition Report will be a fundamental tool for accountability. The FFA must be aligned with global accountability mechanisms already set in motion and with the post-2015 development agenda and its targets for nutrition, food security, and broader health.

2.  Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition, and how could this be improved?

3.  Does the Framework for Action provide sufficient guidance to realize the commitments made?

In future drafts, further guidance and more clarity should be given to targets and timelines to implement and realize the commitments made.

4.  Are there any issues which are missing in the draft Framework for Action to ensure the effective implementation of the commitments and action to achieve the objectives of the ICN2 and its Declaration?

Our comments on this are integrated into the above points.

The International Diabetes Federation (IDF) response to the ICN2 Framework for Action zero draft to implement the Rome Declaration on Nutrition, August 2014

The International Diabetes Federation (IDF) is an umbrella organization of over 230 national diabetes associations in 170 countries and territories. It represents the interests of the growing number of people with diabetes and those at risk. As a founding federation of the NCD Alliance, IDF fully supports and reinforces all comments made in the NCD Alliance submission.

The International Diabetes Federation (IDF) welcomes the opportunity to provide comments on the diabetes perspective to the ICN2 Framework for Action zero draft.

 Chapter 1

IDF regrets that overconsumption (defined as population-wide increased consumption of energy-dense food products) does not appear listed as a form of malnutrition in the background section. However, we welcome the inclusion of the ‘food systems’ concept and the acknowledgement of the deep and fast changes they are undergoing and their implications in nutritional outcomes.

We request that the omission of diabetes in the commitment made by the 66th WHA on ‘halting the increase in obesity prevalence in adolescents and adults’ is amended.

Chapter 2

IDF agrees that further global and national financing is needed to improve nutrition outcomes and develop interventions that are cost-effective in the mid- and long-term. Diabetes and other non-communicable diseases (NCDs) pose an economic burden to society on two counts.  Diabetes predominantly affects people of working age leading to significant loss of economic activity and productivity. In addition, diabetes-related health expenditure totalled at least US$ 548 billion in 2013 and IDF estimates that it will exceed US$ 627 billion by 2035.

We agree that resources for financing improved nutrition outcomes should be partly generated through national taxes: according to a recent report by the European Commission[1], food taxes result in a reduction in the consumption of the taxed products. However, taxation measures need to be coherent, to avoid consumers switching to similar but un-taxed or less-taxed unhealthy products.

Chapter 3

IDF agrees that the protection of the nutritional quality of diets needs to be prioritised. We particularly appreciate that WHO recommendations on the intake of free sugars are included in this Framework for Action. However, in order for these recommendations to have the highest possible impact, we urge WHO to finalise its work on the guidelines on free sugars intake for children and adults as soon as possible.

Among the set of priority actions proposed across this chapter, those regarding maternal nutrition status before and during pregnancy, and nutritional status during the ‘first 1000 days’ are of particular relevance for diabetes. Maternal overweight and obesity at the time of pregnancy (a risk factor for childhood obesity and gestational diabetes) have steadily increased in low- and middle-income countries (LMICs) since 1980. This trans-generational transmission of obesity is fuelling the diabetes epidemic in the LMICs, where 80% of the people with diabetes live. 

IDF also welcomes actions regarding nutrition education for behavioural change as a measure to tackle diabetes in the long-term. Nutrient profiling can be one useful tool to help consumers make healthy choices, but so far implementation has been geographically uneven and information about servings has proven to be insufficient, unclear and, in some cases, misleading.

Chapter 4

IDF welcomes the accountability framework to be developed with input from different national ministries and international agencies, given nutrition is a cross-cutting issue. However, as the Rome Declaration will be adopted during ICN2 in November 2014, we urge the involved actors to agree on a Framework for Action within the shortest possible time.

 The Framework for Action provides two groups of priority actions to incentivize healthy dietary choices, including price reductions on healthy foods and the creation of fiscal incentives and disincentives. However, these actions will not be successful if the production of crops used in highly-processed food (e.g. sugar) continues to be incentivized. Therefore, IDF requests that the priority actions for food systems specifically include disincentivizing the production of such crops, in order to attain policy coherence across the different areas of action.

As for the format of the Framework for Action, we believe that priority actions would be clearer if they are set out in the same format as the commitments included in the Rome Declaration, in the shape of a shorter and more concise document.

 Although some of the priority actions offered are well developed and even offer examples, others lack that depth. IDF recommends priority actions to be specific and, where possible, to reference good practices that have proven to be effective to date.

 With the Sustainable Development Goals’ discussions ongoing, now is the moment to act to address malnutrition in all its forms. Therefore, as previously stated in the comments for chapter 4, IDF recommends finalising the work on this Framework for Action as soon as possible, so it can contribute to the post-2015 framework from the beginning.

We also urge to continue involving civil society in consultations and call on assuring its participation in accountability processes.

The International Dairy Federation (IDF) is grateful for the opportunity to comment on the ICN2 Framework for Action zero draft. Our comments relate to Question 1  addressing general aspects of the draft FfA, chapter 3.1 Food systems and chapter 3.3. Health, section 3.3.6 Food safety and antimicrobial resistance.

Thank you for giving such an opportunity.

Please find herewith my comments:

1. Do you have any general comments on the draft Framework for Action?

Draft framework when it was read I felt that this is something which is really required at this juncture to address the nutritional needs and also to refine and revise some of the ongoing strategies at the policy level. Discussions and concerns that was flowing till this time need to stop and look at such plan of action and seriously demands a strong commitment on the part of all the nutrition and health professionals to make our people healthy and to ensure a better life for children.

  = Do you have any comments on chapter 1-2?

Referring to 2.2. Better governance on Nutrition: Institutional arrangements at the national level should focus on developing collaborations with the Non-Governmental organisations in the health sector  and this might be  important to address two of the four key elements mentioned under 2.1. Enabling environment- Leadership for progress on nutrition at all levels and enhanced capacities for strong and sustainable effective action

Also, referring to Facilitation of effective implementation at all levels: Intensive social mobilization  should primarily focus on mobilizing children and adolescent girls in schools and colleges to make it sustainable and effective action

  = Do you have any comments on chapter 3 (3.1 Food systems, 3.2 Social Protection; 3.3 Health; 3.4 International trade and investment)?

3.1. Food systems: Gender sensitive intervention also should focus on developing nutrition sensitivity. This will help in the long run to reinforce the need for the intake of nutrient dense foods. Availability of locally grown nutrient dense foods at an affordable price is always possible and proper steps to be taken towards making such foods available. This will increase the accessibility of such foods to the vulnerable population and thus enable them to make a healthy dietary choice.

Promoting the concept of developing food gardens by involving communities at the village level and integrating such programmes into the existing nutrition programmes will address the affordability and accessibility issues of some of the nutrient rich foods.

3.2. Social protection: Public food distribution schemes, ensuring universal coverage etc., should have a special team focussing on nutrition related issues. Strengthening the capacities of the human resources and using these resources in studying the impact of all such programmes will have a definite contribution in the long run to refine and understand the role of such interventions in reaching the millennium development goals  

3.3. Health: Nutrition should become an integrated and parallel function in the existing health systems. Nutrition has a preventive function in breaking the vicious cycle of malnutrition that gets transferred from the mother to the child

3.3.1. Delivery of effective nutrition interventions: Deploying the resources at the primary health centre level and collaborating with Non Governmental health service institutes will help to develop the evidence for effective strategy development.

3.3.4. Nutrition education for behavior change: Rapid evidence development on the Knowledge, Attitude and Practices of women against dietary choices and food consumption at this point is important as this will help to assess the impact of ongoing projects and for any revision in policy or implementation if required. This will help to understand the changes in the existing behavior from earlier and what kind of interventions would improve this further.

  = Do you have any comments on chapter 4-5? Nil

2. Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition, and how could this be improved?

3. Does the Framework for Action provide sufficient guidance to realize the commitments made?

I feel that the success of this framework lies in effective execution and evaluation at the national level.

Stringent monitoring system at the national level

Brining in nutrition as a parallel support pillar in achieving the health goals of the countries only will ensure effective buy in at all levels. Otherwise amalgamation of health and nutrition always makes nutrition as a second priority since addressing the immediate health need is more important for any health system rather than focussing on preventive aspect.

Effective collaboration between the local bodies and the key stake holders is crucial.

A guidance on the above  aspects also would help

4. Are there any issues which are missing in the draft Framework for Action to ensure the effective implementation of the commitments and action to achieve the objectives of the ICN2 and its Declaration?

Regards,

M.Asha Latha

Associate Public Health Specialist

Allen Foster Community Eye Health Research Centre

Gullapalli Pratibha Rao International Centre for Advancement of Rural Eye Care (ICARE)

L V Prasad Eye Institute (LVPEI)

L V Prasad Marg, Hyderabad – 500 034

World Cancer Research Fund (WCRF) International and the NCD Alliance (NCDA) comments on the Second International Conference on Nutrition (ICN2) draft Framework for Action (Version dated 22 July 2014)

August 13 2014

General comments

•     We support the focus of the Framework for Action on “malnutrition in all its forms”. However, we would like to see this terminology used throughout the document for consistency and clarity, and for it to be clearly defined upfront.

•     We support the preamble owing to its presentation of malnutrition in all its forms as a multi-dimensional issue, including a food systems issue, its reference to complementary documents and processes, its focus on meeting nutrition targets already set by WHO in the Comprehensive implementation plan on maternal, infant and young child nutrition, and the WHO Global Action Plan on the Prevention and Control of NCDs 2013-2020. It should, however, also signpost other key documents and agreements from which the priority actions are taken, and also make reference to the costs of inaction.

•     Apart from the preamble, the document should be a relatively short and concise list of specific, time-bound priority actions. The priority actions should provide a roadmap for implementing the Outcomes Document of ICN2.

•     The actions should be consistent with existing agreements. Following from the ICN2 Outcomes Document, it should include actions to address malnutrition in all its forms. It should seek to bring together priority actions to address the full range of determinants of malnutrition, and add value to existing frameworks and processes by including food systems solutions not typically found in existing political and technical documents.

•     The actions should be clear and specific, but not so narrow that they remove flexibility in implementation for countries. Countries should be able to tailor the actions to their own national contexts.

•     The FFA should be designed for the same time frame as the proposed "Decade for action on nutrition” i.e., 2015-2025.

•     The FFA should be adopted at the ICN2 in November, along with the Outcomes Document in order that there are concrete priority actions agreed upon as a result of the meeting. If this is not possible due to the tight timeframe, the Outcomes Document should include a commitment to implement the Framework for Action, and set out a clear process for developing it.

General recommendations:

•     In the preamble, text in the first paragraph is changed from: “Moreover, most countries are burdened by multiple types of malnutrition. Over two billion people suffer from one or more micronutrient deficiencies, while over half a billion are obese, with an increasing incidence of diet-related noncommunicable diseases (NCDs). The common denominator among all types of malnutrition is nutritionally inappropriate diets, but the nature and underlying causes of malnutrition are complex and multidimensional.” TO “Moreover, most countries are burdened by multiple types of malnutrition in a wide range of forms. Over two billion people suffer from one or more micronutrient deficiencies, while over half a billion are obese, with an increasing incidence of diet-related noncommunicable diseases (NCDs). The common denominator among all types of malnutrition in all its forms is nutritionally inappropriate diets, but the nature and underlying causes of malnutrition are complex and multidimensional”.

•     In the preamble, reference is made to a greater number of existing plans and monitoring frameworks on food security, nutrition, NCDs, sustainability etc issued by WHO, FAO, UNICEF, UNEP, World Bank, Scaling up Nutrition etc; regional plans (e.g. for African Union, Small Island Development States, WHO Regional Offices); and national action plans for nutrition.

•     In the preamble, include text on the costs of inaction.

•     Most of the technical text is removed from the FFA so that it is much clearer focused on priority actions. Actions should then be prioritized; replication should be removed, along with “non-priority” actions; and existing action plans and strategies should be signposted as much as possible in order to ensure that this document does not replicate, or de facto revise, existing nutrition agreements.

•     Where relevant, actions should be reworded so that they become “actions” countries and international actors can take, rather than general statements about what is needed. For example by changing “Institutional arrangements that encourage effective multi-sector working” into “Establish a cross- government, inter-sectoral governance mechanism.”

•     Most of the priority actions should focus on the national level, but there is also a section for international actions. Furthermore a section on actions by international partners (including civil society) should be included.

•     It includes an accountability framework. This should be consistent with existing frameworks for nutrition and NCDs, but with a mechanism for reporting back specifically on the FFA. The current accountability framework requires a complete revision. We also question the need for an International Panel on Nutrition.

•     The preamble should stay largely as it is, but with the additional reference to the existing plans etc on which the priority actions should be based.

Specific recommendations on priority actions

We have reviewed the priority actions listed in the document and recommend that the following are included; many of the others can be deleted. Many of the actions we include here combine similar actions in the current draft to remove duplication. In other cases, existing agreements should be looked up to ensure consistency and to avoid replication.

NATIONAL ACTIONS

We recommend that priority actions are listed for the national level in three main areas: governance and financing; policies on food systems and food environments; and nutrition and health interventions.

Recommended priority actions for governance and financing

•    Establish a cross-government, inter-sectoral governance mechanism including the engagement of local and intermediate level governments, with the mandate of providing leadership in nutrition and the identification of implementation of nationally appropriate actions.

•    Establish multi-stakeholder platforms, including engagement with local communities, with adequate mechanisms to safeguard against potential conflicts of interest.

•    We strongly support the inclusion of actions on financing. We would recommend adding an action on financing, taken from existing frameworks/agreements. We also support the proposal to a proposal to cost national plans and assess the gaps.

•    We would also recommend including an action about supporting research to find the most effective solutions and evaluate effects of actions.

Recommended priority actions for policies on food systems and food environments

•     Review existing national policies and programmes across sectors which influence food and nutrition and identify and address areas of incoherence with nutrition objectives. Review public investments in agriculture and food systems for coherence with nutrition objectives. Based on the findings, take actions to integrate nutrition objectives with agriculture and food systems policies and programmes to ensure they are not detrimental to nutrition objectives and utilise opportunities to improve nutrition.

•     Take actions to remove barriers to the access of sufficient, safe and nutritious foods and diverse diets, such as by strengthening the infrastructure, facilities and training, for production, post-harvest storage processing, distribution, procurement logistics and retailing of safe and nutritious foods, creating incentives for their production, distribution and sale, leveraging local food systems and engaging local populations, establishing markets for smallholder and family farmers, supporting women engaged in local and smallholder food production systems, leveraging traditional/indigenous crops and developing urban food systems to meet the needs of the local population.

•     Implement population-wide nutrition policies outlined in the WHO Comprehensive Implementation Plan on Maternal, Infant and Young Child Nutrition and the WHO Global Action Plan for the Prevention and Control of NCDs 2013-2020, including the implementation of the WHO Set of Recommendations on the Marketing of Food and Non-Alcoholic Beverages to Children.

•     Implement a plan to improve the healthiness of the food supply, including policy measures to promote the provision and availability of safe and nutritious food, increase the provision of clean water, such as in public institutions, replace trans-fatty acids with unsaturated fats, reduce the level of salt in the food supply, and reduce the level of sugar and caloric sweeteners.

•     We also recommend an action is included here on nutrition education.

Nutrition and health interventions

We recommend priority actions are included in the following areas. These actions should be consistent with existing agreements on priority actions in these areas:

•     Social protection

•     Integration of nutrition into health systems

•     Wasting, stunting, anemia

•     Infections

•     Breastfeeding

•     Water and sanitation

•     Food safety, including anti-microbial resistance

INTERNATIONAL  ACTIONS

A range of priority actions are needed for international agencies. These should include:

•     Define sustainable diets and develop and disseminate a clear and robust set of guidelines for sustainable food production practices applicable to the setting.

•     Create and improve systems and tools for gathering better and more frequent data, particularly on undernutrition rates, micronutrients, diet quality (including metrics relevant to obesity and non-communicable diseases) and local availability and affordability of diverse nutritious foods. This data is essential to monitor the problem of malnutrition in all its forms, as the basis for solutions, and to monitor and evaluate impact.

ACCOUNTABILITY FRAMEWORK

•     We support the inclusion of an accountability framework but in a much revised form. The current version includes many specific actions which would be more appropriate if placed in the priority actions, or are not necessary and can be deleted.

•     The accountability framework should start with reference to the “Decade of Action for Nutrition”, and explain what this would consist of i.e, what the “actions” would be during the decade.

•     It should call for the development of a monitoring and evaluation framework, which is made up of existing frameworks complemented with additional needs created by the ICN2 Outcomes Document Framework for Action.

•     It should include reporting mechanisms, and suggested timelines for reporting.

•     It should include actions designed to promote accountability among international agencies, as well as action taken by them to promote national accountability.

•     The objective of an International Panel on Nutrition should be better defined in order to enable a fuller discussion on what it could achieve and whether it is needed. Discussion of new governance structures should follow from the needs created by the Outcomes Document, the Framework for Action and the Decade for Nutrition, rather than precede them.

•     While we recognise that more resources are needed for nutrition, the notion of a Global Trust Fund should be considered in the context of existing funding allocated to malnutrition in all its forms. Again, we believe new governance structures should be considered after an assessment of the needs created by Outcomes Document, the Framework for Action and the Decade for Nutrition.

Dear all, 

I have posted a brief description of the FAO and Brazil Project, through which we work with the subject of School Feeding programmes in the Latin American and the Caribbean.  

Making reference to the ICN 2 document, I would like to know how can we incorporate the School Feeding Programme as strategy for the strengthening of the nutritional condition of the students. It is important to mention that the students represents nearly 1/3 percent of the population in the countries and that all countries develop some kind of SFP. So, my message is in the sense that this SF policy is a excellent opportunity to use the school space and the food offer to overcome the malnutrition problems. Also, the school period is a special moment to develop food and nutrition education to all in the school community.        

This vision enables that the students overcome malnutrition and also prevents other students against malnutrition and diseases in their future.      

En términos generales debería incluirse el concepto de desarrollo sustentable, además de hablar de sostenible; el primero asegura la renovación de los recursos naturales y el segundo valora la gestión en varias dimensiiones (política, económica, cultural, social...)

Igualmente, consideramos indispensable animar a las naciones con el replanteamiento de una reforma agraria en la que se proponga un control en la distribución de la tierra más equitativa.