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.
Д-р. Anne Marie Thow