World Public Health Nutrition Association comments
on the revised draft of the political outcome document of the ICN2.
We, the World Public Health Nutrition Association (WPHNA), welcome the opportunity to comment on the revised draft of the political outcome Rome Declaration on Nutrition of ICN2. We thank the convenors of ICN2 for their inclusive approach and therefore regard ourselves as partners in the process.
We also thank all those concerned within the UN system who are supporting the necessary moves to make nutrition central in relevant public health policies, throughout high-income as well as lower-income member states. The fact that ICN2 is taking place in the FAO International Year of Family Farming, we regard as auspicious. We also congratulate WHO on the relevant work done so far by its NUGAG initiative. Overall, we thank the UN Food and Agriculture Organization and the World Health Organization for the work being done to make this conference fully collaborative, with the engagement of other UN agencies, and with the other agents whose engagement is essential, including independent health and civil society organisations and social movements.
We urge FAO, WHO, and other members of the UN family, to come together with a will, to give ICN2 all possible and feasible support, so that its outcome and the international and national policies and programmes that follow, address all the main nutrition-related determinants of well-being, health, and disease.
The document as now drafted has some omissions which we suggest can be readily addressed, and as partners we will be pleased to support the drafters in the process of adjustment and revision. We see four omissions perhaps above all.
One is that it is framed in general terms including in places where greater specificity would be helpful. Documents designed to give global guidance need to guard against overlooking and neglecting the diversity which is a glory of human achievement and a wonder of the living and physical world. We should approach our work in a spirit of respect and even humility and be careful not to think or act as if we have all the answers.
Two is that it makes little reference to the political and economic as distinct from the social and environmental determinants of food systems and thus food supplies and dietary patterns. There is an extensive literature on this fundamental aspect of food systems and many member states are now addressing salient issues.
Three is that it does not make much reference to broader aspects of nutrition. These include long established appropriate sustainable agriculture and food systems, native foods that are exceptionally nutritious in the context both of nutritional deficiencies and of overweight, obesity and diabetes, or to meals, cooking, food culture and tradition, commensality, and the impact of food as acquired, prepared and consumed on family, community and social life, as well as on relationships with the living and physical world. FAO has already done much good work here.
Four is that the whole document should, we suggest, be examined to ensure that in its totality, explicitly and implicitly, it does indeed support the human right to adequate nourishing food; and also it recognises, valorises and supports the wisdom and knowledge of all those ‘on the ground’ within countries, municipalities and rural and urban communities whose knowledge and wisdom upholds and develops long-established and traditional food systems that have evolved rationally in response to climate, terrain and resources. In this respect we believe that special recognition and value should be given to regions and countries whose food systems and dietary cultures are of continuous long duration. Of these the classic ‘Mediterranean diet’ or diets throughout the Mediterranean littoral is an example. Well-known other examples are within China, India and Thailand, Mexico and Peru. Others survive elsewhere in Asia, and the Americas, and in Africa, the Arab world, and the Pacific region.
We suggest that reference to malnutrition could be rebalanced to give equal weight to under-nutrition and over-nutrition.
On over-nutrition, leading to overweight and obesity, and related diseases and diabetes in particular, we suggest that the document should make explicit reference to the corporate actors whose activities are driving food systems towards greater supply of fatty, sugary or salty processed products. Evidence that the policies of international food manufacturers, caterers and associated actors in effect displace long-established sustainable food systems is we suggest not seriously disputed, and indeed is even acknowledged by these actors.
Some of our concerns here are mentioned in point (3) in response to the request for general comments.
We also suggest that the document as now drafted gives rather too much emphasis to development that involves highly capitalised and intensive methods. For example, one passage refers to ‘investments and incentives for agricultural production, food processing and distribution’. Misunderstood, this could imply greater intensification, concentration of land and resource ownership and control, loss of land ownership and rights, unjust use and privatisation of common goods such as water, and continued and even accelerated loss of agricultural, horticultural and species and variants biodiversity.
We suggest that passages like these need to be rephrased in order to support investments and incentives that are controlled and driven nationally and locally, with affirmative action in favour of small and family farmers whose livelihoods continue to be threatened by inequitable and unjust events and circumstances beyond their control, whose produce amounts to most of the world’s food supplies.
When referring to legislative and regulatory framework the document as now drafted focuses on food safety and quality control. These are essential. It is now we believe agreed beyond serious dispute that what is also needed are effective statutory regulation of supply of and demand for unhealthy products, and of their advertising and marketing, most of all but not only to children up to the age of 18.
Commitment a): eradicate hunger and all forms of malnutrition, particularly to eliminate stunting, wasting and overweight in children under 5 and anemia in women; eliminating undernourishment and reversing rising trends in obesity;
Commitment b): reshape food systems through coherent implementation of public policies and investment plans throughout food value chains to serve the health and nutrition needs of the growing world population by providing access to safe, nutritious and healthy foods in a sustainable and resilient way;
Commitment c): take leadership to shape and manage food systems and improve nutrition by strengthening institutional capacity, ensuring adequate resourcing and coordinating effectively across sectors;
Commitment d): encourage and facilitate contributions by all stakeholders in society and promote collaboration within and across countries, including North-South, South-South and triangular cooperation;
Commitment e): enhance people’s nutrition, including people with special needs, through policies and initiatives for healthy diets throughout the life course, starting from the early stages of life, before and during pregnancy, promoting and supporting adequate breast feeding and appropriate complementary feeding, healthy eating by families, and at school during childhood;
Commitment f): adopt and implement a Framework for Action that should be used to monitor progress in achieving targets and fulfilling commitments;
Commitment g): integrate the objectives of the Framework for Action into the post-2015 development agenda including a possible global goal on food security and nutrition.
Specific suggestion for Commitments (tracked changes can be find in the pdf attached).
We here suggest some drafting adjustments. We are at your disposal to work on such adjustments and other revisions as may be needed.
Commitment b): reshape food systems through coherent implementation of public policies and investment plans throughout food value chains to serve the health and nutrition needs of the growing world population by providing access to safe, nutritious and healthy foods in a sustainable, equitable and resilient way;
Commitment c): take leadership to shape and manage food systems and improve nutrition by strengthening institutional capacity, ensuring adequate resourcing, preserving and/or recovering agro-biodiversity and culinary traditions, preventing manufacturers and suppliers of unhealthy products from undermining local food systems and supplies, and coordinating effectively across sectors;
Commitment e): enhance people’s nutrition, including people with special needs, through policies, initiatives, and economic and legislative measures that can provide protective, fostering and supportive environments for healthy diets throughout the life course, starting from the early stages of life, before and during pregnancy, promoting and supporting adequate breast feeding and appropriate complementary feeding, managing price policies in order to favour the access of families to healthy eating by families, and at school developing knowledge of food and nutrition and family life, and skills to acquire, prepare and cook food, and statutory regulation and restriction of advertising and marketing of unhealthy food products during childhood up to the age of 18 and throughout life.
We see ICN2 as one vital part of the move towards sustainable development that formally begins in 2015, following the 2012 Rio conference. Members and associates of WPHNA are already engaged in initiatives such as those now being undertaken in Mexico and throughout the Americas, and as advisors to FAO, WHO and other relevant UN agencies. We will continue this work.
We place great value in the thinking that has led to the decision to mount ICN2. Malnutrition in all its forms is mostly basically caused by structural failures in food systems and supplies. This has always been so. Conversely, population good health and well-being is vitally enhanced by food systems and supplies that are adequate and equitable. This also has always been so.
We believe that all those most concerned with ICN2 will do well to continue to see this ‘big picture’, which explains why the current interconnected food, finance and fuel crises, manifested among other phenomena by gross economic and social inequity, climate change, fluctuations in availability of food, and continuing food insecurity, all of which are triggering riots and uprisings, are relevant to our considerations.
We admire the work done by colleagues within the UN System, and now also within associated agencies notably the World Bank, to drive towards equitable, sustainable food systems and supplies, and thus adequate and nourishing food and nutrition for a growing world population. These responsibilities are very serious and must be seen as one crucial part of the drive to recover, protect and enhance sustainable systems of world, national municipal and local governance within increasingly participatory democracies. This is the best chance for humanity at this critical time in history. Our policies and actions now will be judged in future. We are at your disposal to support you in your work from now leading to ICN2, at the conference, and thereafter.
World Public Health Nutrition Association comments
on the ICN2 Zero draft ‘Rome Accord’
As requested we, the World Public Health Nutrition Association (WPHNA), have made some general and specific comments on this zero draft. We welcome the opportunity to comment on this draft, and appreciate the efforts in putting this document together. However, it is a disappointing document. Its statements, claims and implications continually seem to contradict currently agreed positions of relevant UN agencies.
Inasmuch as we can understand the document, its approach and suppositions represent a great step backwards from the position of the 1992 ICN1, and could if put into practice cause further deterioration in the quality of food systems and supplies and thus of human health. We also feel uneasy about working on a document that is often unclear, confused or fragmentary. We would like to suggest that it is a ‘pre-Zero draft’ that needs substantial revision. We will be happy to make more detailed comments on a new draft. We hope the comments presented here are helpful for the preparation of a new, more substantial version.
Some examples of lack of clarity and of confusion follow. In item 1 'malnutrition' is defined to include overconsumption, whereas in item 2 the term is used to refer only to undernutrition. Item 2, first bullet point, states that 'at least 842 million' children were undernourished in 2011-2013. We assume this means in each of these three years, and suggest that the draft needs some basic checking and editing. Also here and throughout the document it is unclear whether obesity is counted as a chronic non-communicable disease: either way, the general point here is that key concepts and the language of the document need revision. The same applies, for instance, for the concept of food systems that is presented later on in the document.
The human right to adequate food is absent of the document, which is clearly not written with a human-rights lens. There is no recognition of the roles and responsibilities of the different stakeholders that the document proposes to engage in the promotion of food as a right of all people. FAO’s efforts in promoting food as a human right have been of extreme importance, yet this is not reflected in the document in its current form. When addressing targets the focus is restricted to undernutrition, despite the fact that an outcome document of the ICN2 needs to cover all forms of malnutrition. Although malnutrition is referred to as a complex problem, a simplistic position is often taken. Thus, key determinants of malnutrition of all types are overlooked or ignored. These include penetration of transnational corporations into global South food systems; interference by foreign governments and corporations in public policies designed to protect rational and sustainable food systems and supplies; and the impoverishment of agricultural and biological diversity. Many other examples can be given, including of themes that are now seen as central by relevant UN agencies.
Some statements or claims, while unclear, seem to us to be simply incorrect. For instance, it is implied that increases in supply and consumption of fruits and vegetables, and increased diet diversity, are attributable to agricultural innovations. This is not true. The impact of agribusiness and of corporate food commodity and product development has made food systems more monotonous and more homogenous. This is well known to the relevant UN agencies.
The document implies a grandiose concept of some universal food system, to be adopted or imposed on regions and countries throughout the world. Such concept reflects what transnational food and drink product corporations want and are planning for. This is not in the interests of public health or public goods.
There is no recognition or reference in the document to the fact that the prime drivers of what are and now the uncontrolled pandemics of obesity and diabetes are the ultra-processed food and drink products manufactured and advertised by transnational corporations. It is a prime duty of relevant UN agencies to resist this trend in favour of genuine diversity and food systems that are appropriate in different cultures, climates and terrains. This is surely what the UN Food and Agriculture Organization 2014 year of family farming is all about.
Being sensitive to and focused on strengthening local circumstances is essential in order to avoid transplanting global actions into local socio-political contexts that are far distant from some plan for a ‘global solution’. Countries where traditional and long-established food systems and dietary patterns based on meals, need encouragement to preserve protect their diversity. In such countries certainly, any policy to reformulate intrinsically unhealthy ultra-processed products would only increase their market share.
The document refers to renewal or resurrection of commitments and processes. This section is vague. What ‘renewals’ and ‘recalls’ mean is never made clear. There is also practically no reference in the document to the fundamental need to promote equitable food systems.
We agree that 'food system' is the appropriate concept. But the use of the term in the singular, as if there is or should be only one global 'food system', is tendentious and mistaken. Also the term 'our food systems' (here in the plural) in the points at the end of the document is strange.
Further and respectfully, references to 'the private sector' and to 'industry' seem not to recognise that the main issue here is the activities of transnational corporations whose policies and products are a main part of the problem. WHO Director-General Dr Margaret Chan has already made this very clear, for example in her address to the 8th Global Conference on Health Promotion in 2013.
This section is completely vague. The suggested actions are unclear. We do not understand what is meant by ‘technical elaboration’ – most issues that determine food systems and dietary patterns and the health of nations are political. Nothing is said about how the actions could be achieved. No guide is suggested.
Also, the document has nothing to say about strengthening and amplifying the participation of civil society organizations and social movements, and regulating conflicts of interest in order to prevent policies from being undermined by corporate interests.
These are some of the reasons why we recommend that the ‘Zero draft’ on which these are comments is set aside, and that a new Zero draft is issued. The problem now is partly one of clarity and coherence but is more than that. A new draft should have an appropriate conceptual framework that takes proper account of the social, cultural, economic, political and environmental determinants of food systems and thus dietary patterns.
A new draft should state and amplify current policies of the relevant UN agencies setting clear guides on how to enact them. It should include a clear recognition that transnational corporate penetration and takeover of food systems and supplies especially in the global South is not in the public interest and will lead to further deterioration of public health, notably in the form of very rapidly rising rates of obesity and diabetes, and of public goods including in the form of loss of biodiversity. It should abandon all language that implies that a solution lies in a global food system imposed from on high.
World Public Health Nutrition Association
Contextual comments
Thank you for instituting this process of consultation with civil society organisations and social movements. Our specific comments are in the separate document below.
Work on ICN2 has a practical context. We recognise that this participatory process, not used for the 1992 International Conference on Nutrition, imposes an additional load on the UN agency secretariats. This response is in a spirit of sympathy and solidarity. We also recognise other strains that are stressing the UN system. Relevant UN agencies need much more unrestricted funding, absolutely and relatively, from member states, in order to fulfil their mandates, to serve member states and the public interest, and to protect and preserve sustainable agriculture, food and health systems.
ICN2 needs to be positioned as within a very broad context of knowledge, policy and action. We emphatically support the commitment of the UN Food and Agriculture Organization to family farming, which will and must remain fundamental, and the commitment of the World Health Organization, frequently emphasised by Director-General Margaret Chan, to universal primary health care.
What people eat and the effect of diets on personal health, and of dietary patterns on population health, are now well known to have environmental, economic, political, social and cultural as well as behavioural and biological determinants. These can be grasped only by use of systems methods. The linked financial, fuel and food crises are symptoms of world disorder that can be addressed only at the very highest level. Climate change has now been identified by the President of the World Bank as potentially profoundly disruptive of food systems and population health, so much so as to be a cause of wars. The deliberations and outcomes of ICN2 will make a real and lasting difference for the better if, and only if, they focus on the basic and underlying causes of disease, health and well-being in the whole sense of these terms.
We appreciate that our overstretched colleagues in the UN system who are working on ICN2, together with many member state representatives especially from the more vulnerable regions, know all this. We pledge to give the ICN2 process and its outcomes all the support we can.
General comments
The main ICN2 input and output documents should include explicit reference to and citation of other documents on which ICN2 has been built, or that are relevant to its work. This is of course normal in UN processes. Two recent examples are the May 2014 publication on Family Farming, Food Security, Nutrition and Public Health in the Americas, prepared by UN agency colleagues; and the June 2014 Santa Cruz Declaration For a New World Order for Living Well of the G77 group of member states (now 133, + China). Pdfs of these documents are attached.
Of the statements and recommendations made in comments seen so far, we wish to give broad support to four that have, as here, been submitted by named people on behalf of international organisations. These include that by Corinna Hawkes, on behalf of World Cancer Research Fund International and the NCD Alliance, on achieving an effective process. They also include those by Lida Llotska on behalf of the International Baby Food Action Network; by Claudio Schuftan on behalf of the People’s Health Movement; Xaviera Cabada on behalf of El Poder del Consumidor; and Flavio Valente on behalf of FIAN International. We basically agree with their comments on the broad issues that are neglected in or missing from the Framework For Action draft. We also agree that the draft is still not in a state where it is sensible to propose drafting changes and adjustments. Its general approach requires new thinking, much of which has now been proposed.
These and other statements made in these three documents are amply supported, not seriously contested, and need emphasis. On the issue of transnational corporations, we agree with the position reached in a relevant February 2013 Lancet paper in its Non-Communicable Diseases series, attached. To include such powerful industries, whose interests directly conflict with those of public health, in any form of policy planning (as distinct from implementation) is absurd.
In addition, we propose that all the main ICN2 input and output documents need to be introduced by a short set of governing and guiding principles which set out the conceptual and ethical framework of ICN2 and in effect of all other high-level meetings whose intention is to preserve and protect agriculture, food, nutrition and health systems. If this recommendation is accepted we will propose some principles, one of which certainly is that concerning the human right to adequate and nourishing food.
Specific comments
The specific comments that follow indicate general concern about the nature of the draft Framework For Action. The stage has not yet been reached when the sole or main focus should be on specifics. This said, here are some specific concerns, keyed to the text of the Framework draft.
What customers acquire and consumers eat and drink is not influenced just by availability and access, as indicated and implied. One of other determinants that are decisive, are the product formulation and marketing policies and practices most of all of gigantic transnational and other huge food and drink manufacturing and catering corporations. The Framework needs to emphasise this and other determinants explicitly (page 1, paragraph 3)
The draft fails to specify the basic and underlying causes of malnutrition. It identifies the problems and then quickly moves on to propose solutions. But unless social, economic, political and other determinants are understood, it is all too likely that policies will be irrational and actions and programmes ineffective or unsustainable. (page 1, paragraph 3-4)
The scientific basis of the Framework should be governed by human rights principles, to which there is no reference. (page 2, paragraph 1)
The Framework refers to ‘the global food system’. This is a basic error. The term implies among other mistakes, standardisation, concentration of power, sources, supplies, inequity, cultural monotony, and reduction of cultivars. What is needed is the identification, protection and strengthening multiple, traditional, democratic, equitable, sustainable and heath promoting food systems. (page 2, paragraph 1)
While referring to its alignment with World Health Assembly agreements, the Framework fails to indicate the need to recognise and uphold family farming, as emphasised by the UN Food and Agriculture Organisation as responsible for most of the food produced supplied worldwide. (page 3)
Member states are indeed primarily responsible for implementing UN agreements, such as those planned for ICN2. But the term and concept of ‘partnering’ with other sectors is not appropriate. This in particular implies a community of interests with corporations whose business depends on unhealthy products. Instead, the term and concept of ‘negotiation’ is appropriate. (page 3, paragraph 3)
It is essential to state indicate that solid mechanisms to avoid conflicts of interest are put in place. A fifth key element is needed, on the need for enhanced, strong and sustained monitoring and sanctioning mechanisms. (page 3, last paragraph)
The fourth element of ‘Better governance for nutrition’ should also state the need to assess corporate commercial practices, policies and products promoting or associated with unsustainable or unhealthy ways of production or consumption. (page 3, last paragraph)
Business jargon and its implications should be avoided. For instance, the ‘stakeholder’ concept should be eliminated. Instead, social participation forums and councils should be specified to be used to engage social movements and those most affected by nutrition problems. (page 5, bullet points)
Fiscal measures to reduce the demand for products contributing to unhealthy eating, such as taxes on sugared drinks, should be identified as a source of revenue earmarked for public health initiatives, such as guaranteeing the right to safe drinking water. (page 6, bullet points)
The Food Systems section is inadequate. It indicates that achieving foods adequate in quantity and in quality is the aim. However, who and how these foods have been produced are essential for the environmental, cultural and social adequacy and sustainability. It is possible to supply food adequate in quantity and quality from a biomedical perspective that nevertheless causes calamitous loss of biodiversity, cultural and socioeconomic impoverishment, and vast increases in inequities. (page 7)
The text on traditional and industrial food systems is incoherent. On the one hand it states problems with industrial systems. Yet at the same time, the Framework recommendations favour or assume ‘modern’ industrial systems. The value of traditional systems, universal until very recently in history, which are still the norm in many parts of the world, needs to be clearly stated. For instance, the use of pesticides in modern systems impoverishes the soil. In this vein, the document elides reference to low-input traditional technologies to improve food production. (page 7, paragraphs 3 and 4)
‘Increasing productivity and economic growth can improve nutrition outcomes’. But it can also cause and worsen nutrition problems. The document also includes inappropriate and misleading statements implying that automation of agriculture and food production gives more time to women to take care of children and prepare food. Massive mechanization does indeed reduce rural employment, but thereby increases immiseration in rural communities and urban slums. (page 8, first paragraph)
The use of nutritional supplements should be identified on most situations as a temporary expedient only. (page 8, 4th paragraph)
‘At each step in the chain…’ – This paragraph is mainly about artificial measures. It should include suggestions of the value of traditional technologies in farming, cooking, eating. (page 9, paragraph 4)
Page 10: Priority actions
Under ‘Promoting dietary quality and diversity,,,’ there should be included the sub-item:
Page 10: Priority actions
On the action: ‘Identifying and promoting good practices for improving nutrition enhancing food and agriculture based approaches on a large scale.’ This should give foremost emphasis to small scale farming.
Page 10: Priority actions
An additional item is needed that recommends radical scaling-down of the use of agrochemicals of all types, including antimicrobial drugs, and corresponding scaling-up of diversification.
Page 12 and several other passages in the following pages
Priority actions to improve the food environment. Mainly from this item on, the term ‘nutrient-rich food’ is continually used. It is confusing and misleading and should be avoided. For nutrition specialists the term refers to micro and trace nutrients. But it can be and is also interpreted as energy-rich foods, fat-rich foods, and so on. Also, the term and the way it is used implies that food products however unhealthy that are fortified with nutrients are therefore healthy.
Under ‘Healthy Diets’, the term ‘nutrient-rich foods’ should be replaced by ‘unprocessed or minimally or moderately processed foods’. (page 12)
Under the text on social protection it needs to be made clear that the impact of in-kind food transfers has been considerably higher than cash transfers where food is not available on the market, particularly in emergency contexts, as cash transfers can have an inflationary effect, resulting in further local food price increases. Food distributed through these scheme needs to be nutritionally adequate, and preferably produced by and purchased from the most socioeconomic vulnerable communities that grow food. (page 14, white bullet point 3)
On actions to addressing micronutrient deficiencies, it is a mistake to give priority to artificial addition of nutrients to food. The priority needs to be diversification of diet and preservation of agro-biodiversity. (pages 16-18)
On the priority actions on water, sanitation and hygiene. This needs to identify water as a public good and a human right. (page 22)