المنتدى العالمي المعني بالأمن الغذائي والتغذية

Thank you for the opportunity to make a contribution on behalf of the International Agri-Food Netork and the Private Sector Mechanism

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

The draft document tackles a huge number of action areas directly and indirectly impacting on nutrition. Work needs to be done to make the Framework clearer and more focussed so that governments and stakeholders can look forward to partnering in a successful implementation period post-ICN2.

Members of our network would welcome the fact that, woven throughout the Framework for Action there are references to priority actions that seek to: (1) promote good practices for improving nutrition enhancing food and agriculture; (2) address micronutrient deficiencies; (3) improve micronutrient intake through food fortification; (4) strengthen facilities for local food production and processing; (5) promote the consumption of affordable nutritionally enhanced foods; and (6) increase incentives to achieve these and other priority actions.

The private sector is where most people access the products and services to meet their needs. This is the same for food and nutrition, where diverse diets from a range of agricultural systems are key. Business has a direct and indirect impact on nutrition through agriculture, food fortification; promoting safe infant and young child feeding practices; improving access to clean water and improved sanitation and hygiene; changing consumer behaviour and offering insights in how to promote healthier choices. This is why business needs to be part of these ICN2 discussions.

The private sector consists of farmers who regardless of their geographical location, gender, age, or size are subsistence, small, middle or large-scale holders. Farmers produce the food that people consume.  Farmers and their fisherman and livestock counterparts provide the continuous, ongoing linkages to the social, economic and environmental development of the planet. These food producers are the backbone of our local, national and global food systems and take the first step in food security.

Post-agriculture production, the private sector consists of an additional tens of millions of harvesting, processors, manufacturers, packagers, transportation, marketers and distributors and retailers who can also be categorized as small and medium enterprises, large national businesses and multinationals.

These private sector entrepreneurs —individually and collectively—constitute the global interconnected food systems that forge the essential roles in feeding the world. Through these efforts they have had, and will continue to play a critical role in addressing hunger and malnutrition.

Business is prepared to, and recognizes, its responsibility to play even larger roles to help achieve zero hunger and malnutrition in our lifetime. Without these committed businesses and entrepreneurs there would be even greater hunger, malnutrition and pervasive famines, disease and pre-mature deaths in the world. 

The world is in a different and a better place today than 40 years ago when the 1974 World Food Conference was held to address concerns about famine. ICN2 in November, offers us the opportunity to create a new framework, for all actors to find and implement the solutions to malnutrition. This would improve health conditions and reverse the negative impacts on the cognitive, social and economic capabilities among hundreds of millions of people, mostly women and children.

Do you have any comments on chapter 1-2?

Chapters 1-2 have largely been welcomed by the members of our constituency who have read this document. This is because of the emphasis on enabling environments for improving nutrition, knowledge and evidence based strategies, and the need for public-private partnerships.

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)?

The aims of section 3 are commendable and contain crucial acknowledge of the role of modern supply chains, productivity, technology and diversity in food production, as well as diverse diets.

As mentioned by members of our constituency, the value chain approach in 3.1 is welcome, particularly with reference to the powerful role of micronutrients. Partnerships already exist in some countries, for example, the HarvestZinc initiative.

The section is extremely ambitious, aiming to tackle many complex issues, from public procurement, to NCDs, to environmental sustainability and social protection. The way it is currently drafted, not all of these areas are tackled in all of their complexity and as a result certain paragraphs run the risk of being imbalanced and open to misinterpretation.

Suggestions for improvement in section 3 may include:

·         “nutritional justice” and “ “highly processed foods” – are there global definitions of these terms? If not, how would stakeholders and governments be able to coordinate action?

·         “free sugars” – current WHO work on this matter must be reflected and the Framework for Action must not pre-empt any conclusions of consultations that are underway with the global health community, which includes businesses as key stakeholders.

·         The “Priority actions” on page 10 merit further attention. “backyard gardening” and “small animal management” are important and effective ways to communicate food production to the public, however it does not make sense to omit the crucial role of the world’s farmers, in all of their diversity and agricultural systems, in providing nutrition for the global population.

·         The sections on “traditional foods” and “cultural preferences” could be merged and shortened. The term “appropriate traditional foods” may need to be modified in order to encapsulate consumer choice, likewise the term “acceptability…of diets”.

·         Pages 11 &12 – private sector models on action on NCDs and incentives for healthy diets could be taken into account.

·         Those among our constituency such as the International Dairy Federation would like to challenge the recommendation for Saturated Fatty Acids, stating that the type of Trans-Fat should be specified.

·         3.1.1. Loosely refers to fiscal incentives, whereas experiments with “food taxes”, without any proper scientific evidence, would unfairly discriminate certain types of foods.  It is not clear what the evidence base is for the specific strategies noted in this section, raising the question of why national governments should rely upon this analysis.

·         3.1.2 on “Sustainable healthy diets” aims to tackle a hugely complex issue in just ½ a page.

·         3.3.6 is likewise complex and cannot be discussed fully in a document about nutrition. WHO, FAO and OIE are already undertaking an enormous amount of work on antimicrobial resistance, for example the multistakeholder platform EPRUMA. One recommendation would be to omit this section.

·         3.4 on international trade – another complex issue that cannot be fully characterised in just ½ a page. The current tone is overly negative, a recommendation would either be expansion or deletion.

Do you have any comments on chapter 4-5?

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

The private sector remains committed and fully engaged in its own efforts to improve global nutrition, as well as partnering in the commitments of the Rome Declaration.

A commitment from governments and international institutions is urgent. However, in this part of the document there is a lack of clarity as to how all these platforms, mechanisms, processes and reporting relate to similar activities either in place or proposed by WHO and the UN – for example, the WHO Global Coordinating Mechanism and the UN HLM periodic “Progress Reports” on the 2011 Political Declaration. 

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

The Framework for Action has laudable aims but it must become more focussed and concise if it is to clearly set out ways to realize the commitments in the Rome Declaration.

Inputs for the open discussion on the ICN2 Framework for Action zero draft to implement the Rome Declaration on Nutrition

by the Asian-Pacific Resource and Research Centre for Women (ARROW)

http://www.fao.org/fsnforum/forum/discussions/ICN2-FFA

ARROW, a global South NGO based in the Asia-Pacific,* appreciates the opportunity to comment on the Framework for Action. We hope that our input can be included in the subsequent drafts. We would like to contribute the following input, which is also attached.

1. General Comments

We welcome the development of the Framework for Action (FFA), and see this as a critical opportunity for coherence of global agendas, policy frameworks and global mechanisms, in the midst of ongoing global discussions on the post-2015 development agenda.

We support that the FFA recognizes that the nature and underlying causes of malnutrition are complex and multidimensional, and that it draws especial attention to women and children. We also welcome that health and education, are recognized amongst others, as key sectors. We would recommend that additionally, the FFA should adequately recognize various structural issues, including poverty and gender discrimination, as causal and exacerbating factors to malnutrition, hunger, food insecurity, ill health and lack of wellbeing. Women and girls comprise an estimated 60% of the undernourished[1], and various socio-economic, cultural and political factors combine to make certain groups of women even more vulnerable to hunger and malnutrition, including widows, women with disabilities, women from lower castes, adolescent women and women living with HIV and AIDS.

The FFA needs to specifically recognize the rights to food and nutrition and mention ways to promote, protect and respect these.

The FFA mentions that it will be implemented together with the Decade of Action on Nutrition in the preamble; however, this is not consistently seen in the document. Priority actions must be reframed to be measurable and time-bound where possible. While we acknowledge that resources, needs and problems vary among and within countries and regions, countries should set goals that are sufficiently ambitious to inspire action and show their commitment to solving problems related to hunger, and achieving nutrition, health and food security.

Comments on Chapter 1

Aside from specific nutrition goals, to ensure that it really looks at the interrelatedness with other sectors, the FFA should include specific goals related to access to land, credit, technology, markets, water, and other productive resources and commons. Across the globe, laws and customary practice have restive consequences for women’s access to these, and yet securing these resources enhance women’s rights, and support their nutrition, health and wellbeing, as well as that of their families and communities.                          

While it is good that the FFA recognizes CSOs and social movements as partners in implementing the Rome Declaration on Nutrition, it should enable and guarantee full and meaningful participation of CSOs and social movements, especially women’s rights groups, and particularly from the Global South, at the national, regional and global levels. This includes provision of funding support and giving adequate time so they could meaningfully participate in global discussions.

2. Comments on Chapter 2

2.1 Enabling environments: Aside from those mentioned, to create an enabling environment respect for human rights, including the right to food and nutrition, must be the underlying basis. Additionally, political will and commitment must explicitly be backed by funding.

2.2 Better governance for nutrition: Add women’s groups among the list of groups to be consulted.

2.3 Financing for improved nutrition outcomes: We appreciate the power of economic arguments in convincing governments and donors to address hunger and malnutrition issues, and as such the document should emphasise on the high costs of inaction. This should also be balanced by rights-based framework, which is not sufficiently emphasized in the document. Stakeholders representing those most directly affected by nutrition programmes and policies, including community organisations and women’s rights groups, need to be part of decisionmaking regarding investments and funding.

Comments on Chapter 3

3.1 Food systems: We appreciate that the discussion noted how gender-sensitive interventions can improve nutritional outcomes, and that women’s critical roles in the food system has been specifically mentioned. However, the priority actions must reflect this.

3.3.1 Delivery of effective nutrition interventions: This section should acknowledge more the unacceptable rates of maternal mortality and morbidity, and have stronger priority actions beyond addressing anemia.

3.3.2 Delivery of health interventions with an impact on nutrition:

-          On the section prevention and treatment of infectious diseases, HIV and AIDS is mentioned as one of the infectious diseases contributing to anemia. We would recommend adding an action dealing with the special nutritional needs of women living with HIV and AIDS. Good nutrition is important for those living with HIV as they have compromised immune systems.

-          We welcome the section on Reproductive Health and Family Planning. We strongly support the priority action, “Ensure access to sexual and reproductive health services for all women” and would caution against the removal of any element. We would also want to highlight the importance of the respect, protection and promotion of sexual and rights of women (not just reproductive rights). Sexuality is in integral aspect of being human, and as such, sexual rights are fundamental human rights; we would like to call for the promotion of an enabling environment wherein everyone may enjoy sexual rights as part of development. We would like consistent use of sexual and reproductive health, as well as sexual and reproductive rights across the document.

-          We would like to reiterate the Civil Society Declaration read endorsed by CSOs and read at the Informal Consultation with Non-State Actors for ICN2 in Rome, Italy on 20 June 2014, which stated, “Actions to end hunger and malnutrition in all forms must work to transform societal norms that result in violations of sexual and reproductive rights.” We would like to ask the consistent use of Sexual Health, and the addition of sexual rights.

-          We strongly support the inclusion of adolescent pregnancy as an issue. As priority action, measures to prevent adolescent pregnancy should include comprehensive sexuality education and changing of norms, values and policies to eliminate child, early and forced marriage.

-          Gap: The intersections of nutrition and sexual health and sexuality is not mentioned in the document. While sexuality, including sexual health, are integral parts of human beings, they receive little attention. Studies have shown that poor nutrition and malnutrition affect sexual health through adverse effects like sexual dysfunctions, in both men and women, including tiredness, lack of desire and painful intercourse among others. There is also plenty of evidence and literature on impact of diabetes, which is linked with obesity, on the sexual health of women and men.[2] It should also be mentioned that undernutrition or obesity can also have other impact on reproductive health, such as lead to subfertility or infertility.

3.3.3 Breastfeeding: Priority actions should include regulations for maternal and paternal leaves.

3.4 International trade and investment: We support that trade and investments policies be coherent with and not undermine nutrition strategies and policies, and that innovations in nutrition are included in the public health exception to intellectual property rights. Food sovereignty should be included as the main principle. There should be accompanying priority actions for this section as currently this is the only section not to contain any.

Comments on Chapter 4: Accountability

We support the establishment of an accountability mechanism, which should be based on human rights and should be gender-responsive. We appreciate that the process is going to be inclusive, where we assume that CSOs and social movements being given opportunity to input into the development of this monitoring and accountability framework. However, sufficient time should be provided to give input – something that current ICN2 processes do not give. This allows those from the global South, and those who also need time to consult among its constituencies, to be able to give feedback.

CSOs and social movements also need to be included in the list with responsibility for action. Monitoring to ensure that governments and international partners are implementing commitments is a key role.

Comments on Chapter 5

There needs to be global policy coherence; it needs to make clear how the Rome Declaration and the Framework for Action will be linked with the post-2015 development agenda, including Sustainable Development Goals, as well as the Committee on Food Security and Human Rights Council.

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

We would like to see the latest version of the Rome Declaration to respond to this, and also to be given further opportunity to give input.

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

As mentioned above, priority actions must be reframed to be measurable and time-bound where possible.

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?

This is already addressed in the above questions.

* ABOUT ARROW

ARROW is a regional, non-profit, women’s NGO based in Kuala Lumpur, Malaysia, and has consultative status with the Economic and Social Council of the United Nations. Since it was established in 1993, it has been working to promote and defend women’s rights and needs, particularly in the areas of health and sexuality, and to reaffirm their agency to claim these rights. ARROW’s current work spans information and communications, knowledge exchange and transfer, evidence generation for advocacy, consistent monitoring of progress towards relevant international commitments made vis-a-vis women’s health, capacity building, partnership building for advocacy, engagement at international and regional forums, and enhancing the organisational strength of both ARROW and her partners. ARROW works with national partners in 17 countries across Asia and the Pacific, as well as with other allies from the global South in Africa, Pacific, Eastern Europe, Latin America and the Caribbean, and the Middle East and North Africa, and with allies from the global North.

[1] Sources: UN Economic and Social Council (ECOSOC). 2007. Strengthening Efforts to Eradicate Poverty and Hunger, Including through the Global Partnership for Development. Report of the Secretary-General. UN doc. E/2007/71. New York: ECOSOC. And World Food Programme (WFP). 2009. WFP Gender Policy and Strategy: Promoting Gender Equality and the Empowerment of Women in Addressing Food and Nutrition Challenges. Rome: WFP, p.6

[2] See ARROW & the World Diabetes Foundation (2012). Diabetes: A missing link to achieving sexual and reproductive health in the Asia-Pacific Region. Kuala Lumpur. http://www.arrow.org.my/publications/Diabetes_A_Missing_Link.pdf

Thank you.  The Food Fortification Initative (FFI) appreciates the opportunity to provide feedback. Our comments are in the attached pdf.

AHI is the national trade association representing research and development companies for animal medicines and vaccines in the United States.  Many of our member companies are global in nature and supply technologies to animal agriculture to keep animals healthy in order to provide a safe and affordable food supply.  As such we have a great interest in food safety and security issues.

We appreciate the opportunity to comment on the ICN2 Framework for Action.  We have some general comments and some specific suggestions for rewording the recommendations under 3.3.6 Food Safety and Antimicrobial Resistance.

On page 8 – the WHO dietary recommendations; the last bullet point (“adequate intake of animal source foods is guaranteed in children under five) could identify a more specific quantitative goal and could be expanded to children older than  five.

 Page 24 – last paragraph of section 4.4; 2nd sentence could read:  “There should be effective incentives for farmers to produce sufficient healthy foods (e.g. fruits, vegetables and animal-sourced proteins) to be sold at affordable prices.

3.3.6 Food Safety and Antimicrobial Resistance

We find it curious that the issue of antimicrobial resistance, while important, would be specifically covered in a document dealing with nutrition to the exclusion of other food safety issues of greater importance. We do not believe that recommendations presented here are necessary as this issue has already been extensively reviewed by WHO, FAO, the OIE and many national authorities.  However, if the report is to include  recommendations we would suggest the following wording changes:

1. On the third bullet point we suggest it be reworded to “Phase out the use of medically important antimicrobials for growth promotion.” 

1. On point number 4 revise to: “Ensure appropriate control of the use in food-producing animals of antimicrobials identified as critically important in human medicine, such as fluoroquinolones and third-and fourth generation cephalosporins.”

1. On point number 6, revise to: “Develop and implement national guidelines on responsible use of antimicrobials in food-producing animals, with multidisciplinary involvement, taking into consideration recommendations made by OIE for clinical practices.”

We again thank you for the opportunity to comment on this important work.

CIFF comments on the draft ICN2 framework for action

Many thanks for the opportunity to comment on the draft ICN2 framework for action.

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

·         We welcome the systems-focused approach of this draft; in particular the recognition of nutrition as a cross-sectoral issue, rather than simply a food systems one. However, we would like to see this balance reflected more in both the introduction and recommendations in the document: currently food systems have a much stronger footing, and the entire document is framed within a food systems context. 

·         It would be helpful if the document was clearer on how this FFA fits with existing frameworks (such as the Comprehensive Implementation Plan on Maternal, Infant and Young Child Nutrition, or post-MDGs). Does this plan aim to be the guidance, does this complement? Important that stakeholders at country and global audiences are not confused by another framework.

·         The report contains a huge number of recommendations: it should also make clear that countries and organisations should prioritise recommendations based on data and evidence, and where possible prioritise recommendations within the FFA.

·         The report recommends reviewing nutrition plans, and that WHO and FAO report on FFA actions: many countries have recently reviewed and revised their nutrition plans, so it is important to ensure that we do not replicate existing processes. Wherever possible FFA monitoring should be linked to existing processes, rather than creating new ones.

Do you have any comments on chapters 1-2?

Para 1.1:

-          As well as underlining micronutrient deficiency and obesity levels, please also cite the statistic for stunting and wasting, which are important indicators of undernutrition.

-          The introduction of the draft FFA places too much emphasis on food systems, given the emphasis the rest of the document places on other actors. We recommend amending the introduction to give the reader a sense of the cross-sectoral nature of the document to come. Paras 3 and 4 of 1.1. in particular should be more balanced.

Para 1.2:

-          We welcome the reference in para 3 of 1.2 to previous frameworks and declarations, including the Nutrition for Growth Compact. We’d like to see the Global Nutrition Report referenced, to ensure that ongoing processes are not duplicated.

-          On page 3 in 1.2, the document states that “this FFA provides the technical basis for adopting major policy guidelines and strategies and for developing and updating national plans of action and investments to improve nutrition.” This being the case, it is doubly important that the introduction and later recommendations focus less heavily on the food systems, and become more balanced. Again, it would be helpful to clarify how this fits with existing guidance and networks (such as SUN).

-          Strongly welcome the inclusion of WHA 2025 targets in this section.

Para 2.1

-          We welcome the emphasis on creating an enabling environment for nutrition. Once again, the focus here is on food systems primarily: this does not reflect the multi-sectoral nature of the document or   - more importantly – nutrition as an issue. We’d also like to see domestic resources included in this: they are key to a national-level enabling environment.

Para 2.2:

-          We applaud the emphasis on better governance for nutrition. Again, at the end of the first point – “Coherent government-endorsed policies with explicit targets and situation-specific strategies” – there is a strong emphasis on the need for strategies to address people’s dietary choices. As the rest of the document demonstrates, strategies need to do much more than this: for example health systems need to factor nutrition outcomes in to their delivery strategies. Suggest adjustment of this point to recognise the multi-sectoral nature of tackling nutrition challenges.

-          The emphasis on accountability is welcome here, as is the emphasis on the engagement of all partners in the implementation of policies. However, under ‘priority actions’, please include the formulation and monitoring of accountability plans at national and global levels: this is critical to ensuring greater accountability. Please also include an emphasis on the need for high-level coordination within government to ensure better implementation of strategies and clearer accountability.

2.3:

- In ‘priority actions’, please include the measurement of nutrition spend at both national and international levels. At present, spend is measured patchily, if at all. We also recommend making a reference to the Global Nutrition Report here. Within this point, it will be important to also emphasise the quality pf spend, not just quantity: we need money better spent for better nutrition outcomes.

- We suggest including the economic case for investing in nutrition here, also – specifically linking to GDP costs.

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)?

Section  3 overall places too much emphasis on food systems; we recommend including greater balance both in the way nutrition is framed, and the quantity of text on each sector. 

3.1:

-           The section and recommendations are disproportionally long compared to other sections. Suggest addressing this imbalance.

-           Para 2, page 7 emphasises that, “interventions that consider food systems as a whole are more likely to succeed.” This could also apply to health, education, agriculture: suggest this is removed, or amended to reflect the multi-sectoral nature of nutrition.

-           Good to see the emphasis on nutritional quality of diets, also the emphasis on the role of gender in section 3.1.

3.2:

-          We welcome the focus on the first 1000 days here, but suggest that this is referenced much sooner in the document – perhaps in the introduction. The critical 1000 day window is relevant across all sectors, not just social protection. Please also underline the importance of pre-pregnancy interventions to improve nutrition, as these are important in ensuring better nutrition outcomes in mother and baby.

3.3:

-          This section sees disproportionately short, given the important role that health systems have to play in delivering better nutrition outcomes. Suggest much greater emphasis on ante-natal care and 1000 days, and on the vital role that health systems play in those first 1000 days.

3.3.1:

-          Strongly support the reference to the economic impacts of stunting on page 16, and suggest that this is strengthened.

-          The terminology on wasting is out of date. It is more usual to refer to Severe Acute Malnutrition.

-          The section is entitled “delivery of effective nutrition interventions”, yet the recommendations on wasting are mostly about improved understanding and refining of models rather than overcoming actual delivery bottlenecks (they read like a research agenda more than an action agenda). There should be concrete and actionable recommendations on:

o    In high-prevalence areas, implement service points for the treatment of severe acute malnutrition within easy reach of every household;

o    Track and eliminate stock-outs of specialised products for the treatment of SAM;

o    Monitor cure rates in SAM treatment programs and deploy quality improvement methods to bring them to SPHERE standards if inadequate;

o    Institute routine longer-term follow-up of children treated for SAM to prevent relapse or death.

-          On stunting, we suggest adding the following practical recommendations:

o    Screen and treat pregnant women for diseases such as malaria, urinary tract infections and/or pre-eclampsia, all of which predispose to low birth weight

o    Protect young infants from infectious diseases such as malaria, and measles (at the moment the comments are based exclusively on diarrhoeal disease, but all disease in this age group is going to tip the child towards or into stunting)

o    Through social protection measures or direct provision of appropriate foods, ensure that the most food insecure households have access to appropriate foods for feeding of the young infant (6-24 months) throughout the year

o    The promotion of appropriate complementary foods should include a specific citation of animal-source protein.

-          We question the inclusion of a linear growth assessment. As far as we know, there are no interventions which would be provided conditional on the finding from a linear growth assessment, so this would add programme complexity with limited advantages.

-          In the priority actions to address stunting, should nutrition-sensitive agricultural interventions be referenced here?

3.3.2:

-    We suggest adding in PMTCT, measles immunisation, antibiotics for women with bacteria in their urine.

3.3.4:

-          It would be helpful to see the link between adolescent girls’ education (secondary) and its link to reduced stunting levels referenced here.

-          It would be helpful to add some priority actions for BCC.

Do you have any comments on chapter 4-5?

-          The emphasis on a trust fund risks taking the focus away from the need for domestic resources to be mobilised in developing countries. We strongly recommend putting greater emphasis on national resource mobilisation in this section in recognition of the fact that only domestic resource allocation will be sustainable.

-          It’s not clear how a trust fund would overlap with other mechanisms – it would be helpful to clarify this further.

-           4.4.1 – it would be good to a reference to the importance of programmes being managed in a cross-sectoral way.

-          Overall chapters 4 and 5 need to reference WHA targets and the Global Nutrition Report, and explain how this framework will fit in with existing initiatives such as SUN and the GNR.

-          Under recommendation 5(b), please emphasise the measure progress on allocating adequate resources for nutrition, and the impact of doing so.

-          Many countries have recently reviewed their nutrition plans: important that this document and process draws on existing processes, rather than repeating them.

-          How will FAO and WHO involve other agencies on the monitoring of the FFA? Given the multisectoral  nature of the FFA, this is key. Similarly, greater clarity on linkages to SUN would be helpful.

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

The framework needs to have a more balanced focus on all sectors: it is still introduced through a food security lens and this should be adjusted.

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

As mentioned above, the framework should place more emphasis on measuring progress on both the allocation of resources (inn particular domestic resources) and their impact.

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?

As referenced above, it’s not clear how this FFA will draw on and fit with existing processes and avoid duplication. Current references to existing processes are vague. More clarity on this will avoid future duplication and confusion, for example with SUN or the Global Nutrition Report. 

Comments from IFAH

Thank you for taking on board the following comments related to section 3.3.6 Food safety and antimicrobial resistance from IFAH (International Federation for Animal Health). IFAH is the global representative body of companies engaged in research, development, manufacturing and commercialisation of veterinary medicines, vaccines and other animal health products in both developed and developing countries across the five continents. IFAH represents both animal health companies and national/regional animal health associations. These associations comprise both local small and medium-sized enterprises and international companies. Overall, these companies represent approximately 80% of the global market for animal health products.

Section 3.3.6 Food safety and antimicrobial resistance should be deleted as it does not belong in a document addressing food nutrition, as it is solely a food safety issue. AMR in animals is being dealt with separately by the WHO/FAO/OIE and individual countries. A specific action plan is being drafted by WHO, OIE has already taken extensive action in this area, as have many IFAH companies and food chain operators. A good example is the multi-stakeholder platform linking best practice with animal health and public health called EPRUMA (European Platform for Responsible Use of Medicines in Animals) www.epruma.eu.  

If the text is kept, we recommend that at a minimum it should: 1) recognise the need for appropriate animal treatments to ensure that animals for food, are healthy animals, and 2) explicitly recognised that if the animals are not healthy, they and their products cannot be used to meet the rising demand for animal protein. Ineffective disease control, leading to inefficient animal production will lead to higher prices, once again hitting the poorest worst.

Regarding the text, we suggest three specific improvements to better reflect current developments.

1.  On the third bullet point under “Priority actions” (page 23) reading: “Terminate non-therapeutic use of antimicrobials, such as the use of antimicrobials as growth promoters.”   

We suggest that the text be reworked to read: “In line with current actions of national authorities, phase-out non-therapeutic use of medically important antimicrobials, such as the use of antimicrobials as growth promoters.”  If the phase-out approach is not embraced, some constituencies will ignore this. It is also important to distinguish between therapy - the act of applying a medicine, – and a cure - which is the act of healing.

2.     On the fourth bullet point under “Priority actions” (page 23) reading: “Restrict or eliminate the use in food-producing animals of antimicrobials identified as critically important in human medicine, especially the use of fluoroquinolones, and third-and fourth generation cephalosporins.”

We suggest changing the text to: “Apply the prudent and responsible use of antibiotics guidelines developed by OIE to the use in food-producing animals of antimicrobials identified as critically important in human medicine, especially the use of fluoroquinolones, and third-and fourth generation cephalosporins.”  Many countries have developed intensive and widely-accepted responsible use guidelines in line with the OIE guidelines. Simply ‘eliminating’ will not be accepted and duly ignored by many countries and stakeholders, because it does not take into account medicinal needs and animal welfare considerations. Furthermore, in countries where the responsible use approach is applied rigorously, the use of those classes is minimal relative to the overall use of antibiotics, and in any case much lower relative to the human side.

3.     On the sixth bullet point under “Priority actions” (page 23) reading: “Develop and implement national guidelines on prudent use of antimicrobials in food-producing animals, with multidisciplinary involvement, taking into  consideration antimicrobials categorized as critically important for human medicine by WHO.”

We suggest adding at the end “as well as the OIE list of antimicrobial agents of veterinary importance.” (http://www.oie.int/fileadmin/Home/eng/Our_scientific_expertise/docs/pdf/OIE_list_antimicrobials.pdf)

Thank you very much for this document and for giving experts the opportunity to comment on it.

I have some comments on one single point: in section 3.1 on food systems, the document endorses WHO recommendations for an "intake of free sugars less than 10% of total energy intake, or, preferably, less than 5%". This is a draft recommendation, still under discussion. Recently, similar draft recommendations were released for discussion in the UK as well. There are however an number of important issues to consider regarding dietary sugars, ie:

- there is no current scientific evidence supporting adverse effects of sugars at a threshold of 5% (or 10%) total energy. These recommendations are therefore extremely cautious on sugars.

- expressing sugar intake as % total energy may be misleading, unless one specifies "energy intake corresponding to that needed to maintain a normal body weight"

- while its is amply justify to recommend energy and sugar reduction in overweight subjects as a way of reducing body weight, recommendations to decrease total sugar intake (from 10-15% presently to 5%) at the general population level should be assorted of specific recommendations on how to replace sugar energy. One can fear that replacing sugar calories with refined cereals or saturated fat may have undesirable effects on health!

- Given the fact that sugar from fruits is metabolized the same way as added sugar, the definition of free "unhealthy" vs "natural,healthy" sugars is tricky. This is an important issue to avoid confusion and to ensure proper labeling of industry products.

These are important points which remain presently unsettled and will have to be very carefully addressed in the final document.

Luc TAPPY, M.D.

1. Do you have any general comments on the draft Framework for Action? Abbott Nutrition is grateful for the opportunity to comment on the draft Framework for Action. The Framework recognizes that malnutrition is a complex and multifactorial global challenge that requires involvement of multistakeholders to provide solutions. We welcome the recognition that there is a need to achieve political and policy coherence and coordination across all sectors, including in agriculture and food systems, health, social protection, education, employment, trade, environment, information, consumer affairs, planning and other sectors.  Coherent and co- ordinated policy making is an important factor in resolving global malnutrition – in both developing and developed economies – recognizing local and national specificities.

Do you have any comments on chapter 1-2?

2.1 Enabling Environment: We agree with the need for the development of knowledge and evidence-based strategies, policies and programmes and would recommend the involvement and consultation of the private sector to access additional knowledge and evidence to inform policies and programmes, at both national and international level.

2.2 Better governance for nutrition: We agree with the need to establish multi-stakeholder platforms as highlighted in 2.2. This will result in better governance and facilitate the implementation of policies and national strategies. The Private sector has science based programs designed for the needs of countries they operate in and that address local and national specific nutrition related issues and food consumption patterns.

Abbott Nutrition specifically support the need to establish: A cross-government, inter-sectoral governance mechanism, including the engagement of local and intermediate level governments; and multi-stakeholder platforms, including engagement with local communities, with adequate mechanisms to safeguard against potential conflicts of interest.

2.3 Financing for improved nutrition outcomes We support the need to identify innovative financing tools and welcome the identification of public-private partnerships as a mechanism for financing for improved nutrition outcomes.

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)?

feedM.E. is a publically available resource which recognizes the global problem of malnutrition and provides extensive resources that can inform local, national and international policy-makers. feedM.E. is a global awareness, education, and action initiative designed to:

•    Heighten awareness of the high prevalence of malnutrition and the importance of nutrition

•    Educate hospital staff and patients about nutrition’s important role in recovery from illness and injury

•    Galvanize action to improve nutrition status feedM.E. works with healthcare systems and communities to help bring about global change on a local level.

3.1 Food systems: We agree with the priority actions identified in this section but are would request the consideration for the need for appropriate specialised nutritional interventions as needed in food crises situations. Codex Alimentarious Commission recently recognized a request from UNICEF and WFP for the development of a standard for ready to use supplementary foods in the treatment of malnourishment of children. We believe this should also be considered in this Framework.

3.2 Social Protection: We agree that special attention needs to be given to the ‘first 1000 days’ when vulnerability to nutritional deficiencies is greatest. Well-targeted interventions can have significant results. The private sector can contribute to the evidence-based to support policy actions in this area.

3.3 Health:

3.3.1 Delivery of effective nutrition interventions: We recognize the challenge for local and national governments in developing policies regarding wasting, stunting and to address anaemia in women of reproductive age. We support the priority actions identified regarding these issues and would encourage consultation with the private sector in the development of policies in this area.

3.3.3 Breastfeeding: We acknowledge and support the important role of breastfeeding in infant nutrition.  We also fully support the introduction of nutritionally appropriate and safe complementary foods after six months of age. We recognize the challenge of meeting the developing infant’s nutritional needs, particularly those outlined within this section, and encourage continued consultation with industry in addressing these challenges.

3.3.4 Nutrition education for behaviour change: We also suggest that the all healthcare professionals dealing with patients suffering from disease associated malnutrition are educated in the value of nutrition. Malnutrition assessment tools should be standardised globally. Also, nutrient profiling tools should be standardised and finalized.

3.4 International trade and investment: We agree that trade policies and agreements should ‘do no harm’ to nutrition and that trade and investment policies should be coherent with and not undermine national nutrition strategies. Trade policy should also support nutrition policy and not restrict the ability to implement effective nutrition policies.

Do you have any comments on chapter 4-5?

4.1.1 National level: Same comments as for Section 2.2 above. We would agree that there is a need for Governments, industry and academic institutions to sustain (rather than increase) their contributions in research to improve the scientific and technological knowledge base against which food, nutrition and health problems can be analysed and solved. Significant resources have already been invested globally providing substantial scientific knowledge. There is now a need to bring together all of this knowledge, validate it for its application and use it as an evidence base for policy interventions. Future investments should be co-ordinated to ensure impact from the investments made. To ensure future investments provide the required outcomes, all stakeholders should be engaged from the early stages in the development of the research program. In addition, we agree that public and private efforts should also be directed to training the appropriate personnel needed in all relevant sectors.

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

In the absence of the final version of the Declaration it is difficult to assess whether the Framework reflects the Declaration.

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

The Framework provides guidance, however there are some aspects that requirement reconsideration / refinement – see comments above. Also, realization of the commitments depends on the actions outlines for 2015 in Section 5.

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?

None at this time however, we would reiterate the need to fully engage the private sector as a partner in developing solutions to resolve the global issue of malnutrition. The private sector has a substantial scientific knowledge – local and international – that can help inform the development of policies and programs.

Estimados: 

considero que en el capítulo 3, sistemas alimentarios, sería deseable explicitar el impacto de los productos altamente industrializados (ultra-procesados, Carlos Monteiro et al) sobre la salud, y su vinculación con la malnutrición, especialmente el sobrepeso y la obesidad. Existe múltiple evidencia que demuestra que los productos ultra-procesados (PUP) están afectando los sistemas alimentarios, especialmente de los países con economías emergentes, con una sustitución de alimentos y preparaciones de tipo tradicional por estos productos, que en su composición tienen más sal, más azúcar, más grasa y mayor densidad calórica.

El aumento en el consumo de PUP en la alimentación, tiene como consecuencia la reducción en el consumo de alimentos enteros, frescos y mínimamente procesados. Por esta razón la agricultura también sufre las consecuencias de este cambio, aunque indeseablemente, muchos productores pasan a acompañar el incremento de la demanda por la producción de ingredientes que sirven a la fabricación de PUP (básicamente harinas, azúcar, sal, aceites y grasas) y la reducción de la demanda por alimentos. Los PUP tienen una composición monótona, pues se componen de pocos ingredientes (fundamentalmente los recién citados y muchos aditivos). En la medida que la agricultura acompaña la producción de materia prima para PUP pasa a comprometer la agro-biodiversidad.

Frente a este problema debemos pensar más allá de los conceptos tradicionales:

·         es un desafío del mundo moderno considerar qué se hace con los alimentos y los nutrientes contenidos originalmente en ellos,  antes de que sean comprados y consumidos

·         por tanto, es fundamental considerar el procesamiento de los alimentos y lo que nos ocurre a nosotros como resultado

nos preocupa mucho el incremento en el consumo en los últimos 20 años de estos productos (que a su vez aplican campañas de marketing intensivo -y no ético- tienen envases muy atractivos), aspecto que se vincula estrechamente con el incremento del sobrepeso y obesidad y con la pérdida progresiva de la cultura alimentaria regional y local que lentamente homogeiniza la forma de alimentarnos mundialmente.

Este no solo es un grave problema de salud pública, sino también un problema político y de soberanía alimentaria (que afecta muy especialmente a las economías emergentes), pues implica una lenta y progresiva destrucción de los sistemas alimentarios regionales y locales y una mayor dependencia externa para alimentar a la población.

Estamos muy  agradecidos con la posiblidad de brindar nuestra opinión, saludamos cordiamente.