Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

I am pleased to send you my contribution (in MS Word) in response to the Ongoing Online Consultation on UN Decade of Action on Nutrition 2016-2025: priority actions on nutrition for the next five years. The attached document runs in 52 pages, including references.

Message from the facilitator

Dear participants,

Thank you very much for your contributions so far. Many insightful comments have been provided on the proposed Nutrition Decade’s priority focus areas for the next five years. We also received great contributions through the online survey.  More than 80 participants from 38 countries from all over the world answered the questionnaire to date, and offered their insights there. 

Participants have highlighted the relevance of the aspirational proposals but also important gaps such as the need to enhance “nutrition sensitivity” in programs from diverse sectors and to suggest concrete means to achieve that. Also highlighted were the unequal power relations between stakeholders and the need to ensure human-rights based approaches are adopted, marginalized populations participate in decision making, and the second half a Nutrition Decade becomes a truly people centered effort. Participants indicated the crucial importance of being clear about the social and environmental determinants of health and nutrition and the ways of addressing those, also mentioning population growth in same areas of the globe as the elephant in the room. 

Among several interesting contributions, there has also been mention of the importance of fully considering food cultures in nutrition action and the additional work needed on regulations of food marketing, labeling and taxes of unhealthy foods. Many participants also called attention to the fundamental need for good governance for nutrition, including for the effective management of conflict of interest.

I encourage all participants to continue the conversation and new participants to engage in this dialogue based on the several questions listed above and/or by answering the short online survey. We particularly welcome views and perspectives from stakeholders from low- and middle-income countries working at regional, national, sub-national and hands-on at service delivery level on how the Nutrition Decade can bring a renewed energy to the wider nutrition ecosystem in the next five years. 

Finally, it was encouraging to see from the contributions received that you are requesting more ambitious actions to improve governance for nutrition to ensure effective and structured collaboration, going beyond the usual call to break down silos and ensure cross-sectoral work. 

Yes, we must act together now to improve nutrition leaving no one behind. 

Thanks again and we look forward to a continued fruitful discussion over the coming weeks.

Stineke Oenema

UN Nutrition Executive Secretary

Comments on the Priorities in Nutrition for the Next Five Years

The tentative suggestions offered seem to have some undesirable attributes. Vagueness and the more or less explicit inclusion of at least four domains without an apt liaising mechanism to ensure an effective coordination of their actions appear to be the most significant. Although very worthy as an intention, role assigned to health services as related to nutrition, does not reflect an awareness of the reality as it is. Perhaps, these comments might induce some to decide on actions with a greater sense of proportion.

The first three proposals under the first section are well taken. They could have been of real benefit had they specified the following means of achieving them:

• Extensive, appropriate technical and financial support to family farmers, village fishermen, small holders, etc.
• Intensive expansion of cooperative food systems; this should receive tangible international and national assistance.
• Active and appropriate steps to prevent food waste in every sub-system in food systems.
• Creation of a UN inter-organisational liaising unit with sufficient authority to compel all members to harmonise their policies, regulations and ordinances so that none of them would undertake actions that would hinder the others from attaining their objectives. For instance, some of WTO’s policies have a deleterious effect on nutrition and health.
• A similar compulsory inter-departmental coordination at the national level.
• ‘Food chains’ is a term from Zoology; smaller things are eaten by bigger animals while still bigger ones feed on them and so on. It is time man unchained himself from trader’s jargon and thought of nutrition in human terms i. E., as a fundamental need. It is satisfied with the use of food systems of varying technical complexity.

Mr. Claudio Schuftan in his second contribution and M. Anthony Fardet have already suggested several other significant measures which will not be repeated here. Instead, vagueness of the tentative suggestions will be considered:

• Precisely how would food and agriculture authorities ensure adequate nutrition of the people from birth to death? Do they propose to procure such a mandate, if so, how?
• The same question may be raised about the other social aspects mentioned among the above proposals.

Emphasis on the use of health personnel for dietary education has two major disadvantages. First, it would be impractical in a considerable number of areas where even primary health care is scant or inadequate while the number of people seeking health care is very great. There the health personnel are overwhelmed by the number of patients that they hardly have time to under take discourses on nutrition. This is not to deprecate the link between nutrition and good health, but rather a criticism of the proposed method.

Secondly, even under ideal conditions, their reach is limited to the number of patients. Even in affluent countries, health personnel are overloaded with ‘paper work’ resulting in fairly long waiting periods to those who want to consult their GP’s. This proposal would exacerbate the situation, and is seen with disfavour by most health personnel. Moreover, the present education of the health personnel does not qualify them for this task.

It is curious that the drafters of the tentative proposals have overlooked the obvious; until not so long ago, school education in many countries included basic health and hygiene, which could be carried out further. Re-introduction of this subject with chapters on balanced diet, food and beverages injurious to health, etc., is a more effective action that the education authorities could undertake. This must accord with the local food culture, and does not require specialist teachers, for they could learn from the books they will use.

Environment, legal, trade and industry, finance and labour are some of the other domains whose cooperation at international and national levels would be essential to achieve not only SDG-2, but also all the others. One of the key roles education could play has been already noted. Dietary education is not concerned with mechanical calorie and micro-nutrient count in food eaten like number of litres of petrol pumped into a car, for civilised humans derive a culinary enjoyment from their meals as multifarious traditions of cuisine illustrate.

The proposed plan would be much benefited by appropriate action in the following areas:

• Preservation and active regeneration of the environment; strictly enforced regulations for this is urgently needed. Extensive restoration of world’s green cover with endemic species, world-wide expansion of biodiversity in agriculture, rapid introduction of agricultural techniques that promote it etc. These would be insufficient unless accompanied by comparable actions undertaken in trade and industry, legal systems, etc.
• Ban on audio and graphical propaganda to increase the sale of mass-produced comestibles and beverages.
• Understanding that halting of population growth is critical not only to environmental sustainability, but also for the survival of civilised life. It is crucial to understand that reductive scientism i.e., a belief in that ‘science’ could solve all human problems is a mere reactive response categorically identical to any undertaken by a Neanderthal. The difference between the new and old are only technological; ‘novel foods’ today and in Neander valley would have been eaten merely because of hunger, hardly with enjoyment. Consider how many so-called ‘poor man’s food now fetches high prices in food shops and restaurants in affluent countries while the modern poor have to subsist on mass-produced stuff. Simply compare the prices of once poor man’s dark rye bread and rich man’s white loaf today; generally, the former is five to six times more expensive at present.
• It is hoped that human culinary enjoyment will enter into the proposed scheme; naturalists have observed that even animals display food preferences and seem to enjoy their preferred food. A cursory perusal of the literature will show that most societies have evolved a food culture to promote social and personal enjoyment civilised life affords one’s meal times. This is not something confined to the affluent, but it is universally valued as a cultural good. Its exclusion from nutrition can not be justified.

Best wishes!

Lal Manavado.

Thank you for the invitation to contribute to "UN Decade of Action on Nutrition 2016-2025: priority actions on nutrition for the next five years".

My comments are as follows; I proposed to add the following key priority areas under mentioned Action areas;

Action Area 1: Sustainable, resilient food systems for healthy diets

To ensure resilient it should not only capture the deceases but also climate change and disaster impact on food. Hence priority on increase climate resilient food production is timely and vital. 

Further,at the same time add a priority to  reduced production on highly processed and geneticaly modified foods.

Action Area 2 and 3: Aligned health systems providing universal coverage of essential nutrition actions and social protection and education 

Presenting nutritional fact of each and every food produced and genetically modified is important. Increasing awareness on negative impact of highly processed, modified and junkfood among young generation. also important.

impose taxes on artificial and GMO's while subsidies for organic foods.

Action Area 4: Trade and investment for improved nutrition

Improve social corporate responsibility of food producers, importers and investers should be prioritized.

Action Area 6: Strengthened governance and accountability for nutrition

Improving institutional frameworks and consumer protection laws and regulatory areas  of developing countries also an important area to improve. 

English translation below

Dr. Edgar Jaimes. ULA-NURR, Trujillo. Venezuela

Las prioridades sugeridas a continuación, se suman a las indicadas en cada una de las esferas de acción  puntualizadas en la propuesta original; esto es:

1. Sistemas alimentarios sostenibles y resilientes en favor de dietas saludables.

Promover sistemas de producción agroalimentaria diversos (Agro-Silvo-Pastoriles), con  bajos insumos tecnológicos, de menor impacto socio-ecológico y biológicamente eficiente, con el fin de asegurar:

El abastecimiento y distribución, per cápita, de 2.500 calorías/día;

Definición de procesamientos agroindustriales para hacer más digeribles las cosechas y los productos pecuarios y

Reducción de residuos animales y vegetales postcosecha y de pérdidas posteriores al consumo humano.

2. Sistemas de salud armonizados que proporcionen cobertura universal de las medidas nutricionales esenciales.

Es urgente acoger el llamado formulado por Kailash Satyarthi, Premio Nobel de la Paz 2014, dirigido a las naciones que conforman el G20 en el sentido de ofrecer una respuesta que sea mundial, equitativa, moral y justa a los impactos de la mal nutrición para los más vulnerables, en particular los niños, mediante la asignación del 20 % del total de 8 billones de dólares (1,6 billones de dólares), y no el 0,13 % de ese monto total como se había indicado antes de la cumbre del G20, en la cual se acordó destinar como respuesta para el alivio global del impacto que está causando la actual pandemia. Se estima que, con esa cantidad de 1,6 billones de dólares, es posible atender las necesidades básicas de salud, alimentación y nutrición entre un 20 y 25 por ciento de los niños más marginados y sus familias, en particular los que viven en los 24 países prioritarios del Plan Global de Respuesta Humanitaria (PGRH) de Naciones Unidas.

3. Protección social y educación nutricional.

Es necesario  incluir acciones de protección social y modelos educativo-culturales en materia nutricional dirigidos a resolver el desbalance generado en los últimos 50 años en el consumo agroalimentario; toda vez que entre el 2 % más rico y el 20 % más pobre de la población mundial, la brecha es brutal e inaceptable, ya que pone de relieve el “consumo de lujo” que tienen 154.000 personas del primer estrato social, en contraste con el “consumo miserable” que exhibe un poco más de 1.500 millones de seres humanos que viven con menos de 1,9 USD/día

4. Comercio e inversión para la mejora de la nutrición.

En esta esfera de acción tiene plena cabida las ideas y criterios emitidos por dos destacadas expertas del Banco Mundial (Caroline Freund y Carolina Sánchez-Páramo), disponibles en: https://blogs.worldbank.org/es/voices/lograr-que-el-comercio-beneficie-…

5. Entornos inocuos y propicios para la nutrición en todas las edades.

En el contexto de esta esfera de acción, es pertinente poner de relieve el concepto de sustentabilidad biótica entendida como la capacidad que tienen los seres vivos de mantenerse en condiciones metaestables mediante ajustes adaptativos de sus estructuras e interacciones socio ecológicas, importantes para controlar y mitigar cualquier amenaza a su integridad, en términos de su salud físico-mental, incluyendo su alimentación y nutrición. Tal sustentabilidad es la expresión inequívoca del balance de dos fuerzas antagónicas: el desorden caótico o entrópico que tiende al cese de la vida y el orden transformador o neg-entrópico que busca la creación y evolución de la vida en entornos diversos, heterogéneos y resilientes, constituyendo los ámbitos más propicios al desarrollo de sistemas agroalimentarios y nutricionales que aseguren la sustentabilidad del mejor vivir para todas las personas.

6. Fortalecimiento de la gobernanza y la rendición de cuentas en materia de nutrición.

Sugiero que se complementen las prioridades indicadas por la CIN2 con las Ideas-Fuerza contenidas en las Directrices Voluntarias sobre la Gobernanza Responsable de la Tenencia de la tierra, la pesca y los bosques en el contexto de la seguridad alimentaria y nutricional ya que ellas constituyen un marco que los Estados pueden utilizar a la hora de elaborar sus propias estrategias, políticas, legislación, programas y actividades. Además, permiten a los gobiernos, la sociedad civil, el sector privado y los ciudadanos juzgar si las actuaciones que ellos se proponen llevar a cabo, o si las actuaciones de otros sujetos, constituyen prácticas aceptables, en particular lo relacionado con la rendición de cuentas en la rendición de cuentas en materia agroalimentaria y nutricional. Estas Directrices están disponibles en: http://www.fao.org/nr/tenure/voluntary-guidelines/es/

The priorities suggested below come in addition to those indicated in each of the Action Areas outlined in the original proposal. Namely:

1. Sustainable, resilient food systems for healthy diets.

Promote diverse agri-food production systems (Agro-silvo-pastoral), with low technological inputs, with less socio-ecological impact and biologically efficient, in order to ensure:

The supply and distribution, per capita, of 2,500 calories/day;

Definition of agro-industrial processing to make crops and livestock products more easily digestible and

Reduction of animal and plant post-harvest waste and losses after human consumption.

2. Aligned health systems providing universal coverage of essential nutritional actions.

It is urgent to respond to the call made by Kailash Satyarthi, 2014 Nobel Peace Prize Laureate, addressed to the G20 nations to provide a global, equitable, moral and just response to the impacts of malnutrition for the most vulnerable, particularly children, by allocating 20% of the total of USD 8 trillion (USD 1.6 trillion) -and not 0.13% of that total amount as indicated before the G20 summit-, as a response to the global relief of the impact of the current pandemic. It is estimated that, with this sum of USD 1.6 trillion, it is possible to meet the basic health, food and nutrition needs of 20 to 25% of the most marginalized children and their families, particularly those living in the 24 priority countries of the UN Global Humanitarian Response Plan for COVID-19.

3. Social protection and nutrition education.

It is necessary to include social protection actions and educational-cultural models in nutritional matters aimed at resolving the imbalance generated over the last 50 years in agri-food consumption. The gap between the richest 2% and the poorest 20% of the world population is brutal and unacceptable, as it highlights the “luxury consumption” of 154,000 people in the top social stratum, in contrast to the “miserable consumption” of more than 1.5 billion human beings who live on less than USD 1.9 per day.

4. Trade and investment for improved nutrition.

In this Action Area, the ideas and criteria issued by two leading World Bank experts (Caroline Freund and Carolina Sánchez-Páramo) are fully relevant. Available at: https://blogs.worldbank.org/es/voices/lograr-que-el-comercio-beneficie-l...

5. Safe and supportive environments for nutrition at all ages.

In the context of this Action Area, it is relevant to highlight the concept of biotic sustainability, understood as the capacity of living beings to remain in meta-stable conditions through adaptive adjustments to their ecological socio-structures and interactions, important to control and mitigate any threat to their integrity, in terms of their physical and mental health, including their food and nutrition. Such sustainability is the unequivocal expression of the balance of two antagonistic forces: chaotic or entropic disorder that tends to cease life and the transformative or neg-entropic order that seeks the creation and evolution of life in diverse, heterogeneous and resilient environments. These areas are most conducive to the development of agri-food and nutritional systems that ensure the sustainability of a better life for all people.

6. Strengthened governance and accountability for nutrition.

I suggest that the priorities indicated by the Second International Conference on Nutrition (ICN2) should be complemented by the overarching ideas included in the Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forest in the Context of National Food Security as they constitute a framework that States can use when developing their own strategies, policies, legislation, programmes and activities. In addition, they allow governments, civil society, the private sector and citizens to judge whether the actions they intend to take -or the actions of others-, constitute acceptable practices, in particular with regard to accountability in agri-food and nutritional matters. These Guidelines are available at: http://www.fao.org/nr/tenure/voluntary-guidelines/en/

My contribution relate to two action areas:

Action Area 1: Sustainable, resilient food systems for healthy diets

• There is currently a vast gap in 'nutrition sensitiveness' of development programmes in agriculcutre, forestry, health, education, water and sanitation etc. Without improving nutrition sensitiveness of all development interventions, it will be way too difficult to achieve food systems that promote healthy diets. Essentially ground level /micro actions that can direct benefit producers and consumers need to be designed and implemented with deep embedding of nutrition agenda as otherwise nutrition will continue to remain sidelined and /or just confined to some nutrition-specific programmes. We should move away from knee-jerk reactions for addressing symptoms (e.g. with ready to use theraputic food) to tackling the root causes of malnutrition (in its various forms) for large number of people currently experience malnutrition.  

Action Area 6: Strengthened governance and accountability for nutrition

• Accountability assurance would essentially mean effectively tracking the performance and impact of current programmes and policies. Needless to say, we should make a strong move towards evidence-informed planning and programming. Without this, we will continue to highlight some pockets of achievements at macro level (e.g. nutrition policies, nutrition investments) without really making deep impact at micro and meso levels. We would need to understand the big picture as well as large number of smallers pictures to analyse where a county/province/state/country/region stands on nutrition achievements and gaps. Importance of robust statistical analysis and monitoring and evaluation systems in this context can never be overemphasised in this context. 

Some comments:

Action Area 1: Sustainable, resilient food systems for healthy diets

• Scale up the inclusion of nutrition objectives in food and agriculture policies: increase production of context-appropriate fruits and vegetables for domestic consumption, and of legumes and pulses that contribute to healthy diets; raise production of oils in support of the elimination of industrially produced trans-fat in the food supply.

I will add: “Increase production of oleaginous nuts and seeds, consumption of wholegrain cereals, and drastically reduced production and consumption of ultra-processed foods.”

• Accelerate food reformulation: provide reference ranges for sodium reduction level benchmarks for processed foods.

No reformation (reductionist approach) does not work and concern green washing of ultra-processed foods which are still more ultra-processed with reformulation. We should accelerate the development of mildly processed foods with preserved matrix (holistic approach). In addition, while nutrients are not really linked to global health and food systems, degree of processing is.

Action Area 2: Aligned health systems providing universal coverage of essential nutrition actions

• Scale up the integration of nutrition actions into health systems: integrate essential nutrition actions into national Universal Health Coverage (UHC) plans.

All depends of what is meant by nutrition actions. If it is nutrient-centered nutrition actions, it will not be sufficient. Food/diet-centered nutrition actions are more appropriate.

Action Area 3: Social protection and nutrition education

• Scale up the implementation of nutrition-sensitive social protection policies: ensure coherence between social protection and other sector programmes such as with agricultural production, livelihood diversification and local economic development; national supplementary food bank programmes provide weekly vouchers to each user for purchase of fresh fruits and vegetables from local farmers.

I will add: taxations on ultra-processed foods which are the most consumed by the most disadvantaged people.

• Better leverage of schools as a platform for food and nutrition education and enabling healthy diets: set and improve nutrition standards for school meals.

Very good point. The main point is to agree with what is a “healthy diet”, i.e., holistic and/or reductionist perspective.

• Scale up the implementation of nutrition education interventions: implement easily understandable nutrition (front-of-pack) labelling on food products that supports consumers’ choices for healthy diets.

Yes, but a labelling based on degree of food processing (NOVA, Siga…), not on nutrients such as compositional score which are not adapted in reality to eat healthy and sustainable. Everywhere they are applied, chronic diseases continue to progress…

Action Area 4: Trade and investment for improved nutrition

• Accelerate responsible and sustainable investments in nutrition: a minimum percentage of the overall national governmental yearly budget is set for nutrition interventions.

Yes, investing in holistic prevention rather than reductionist curative treatments.

Action Area 5: Safe and supportive environments for nutrition at all ages

• Scale up the implementation of regulatory instruments to promote healthy diets: introduce taxation of sugar-sweetened beverages and subsidies for fruits and vegetables; implement legislation of marketing restrictions of foods and beverages high in fat, sugar and/or salt to children.

Extending taxation on ultra-processed foods as a whole entity with growing tax as a function of the number of markers of ultra-processing linked to global human and environmental health (hidden costs).

• Scale up the implementation of national dietary guidelines: include in national dietary guidelines for children, adults and elderly biodiversity and sustainability considerations.

Also food degree of processing, the missing link.

Action Area 6: Strengthened governance and accountability for nutrition

• Enhance political commitment through political dialogue and advocacy at national and sub-national levels: establish and strengthen coordination mechanism through a multistakeholder consultation process for the uptake of the CFS Voluntary Guidelines on Food Systems and Nutrition.

Yes, but the question of lobbies should be addressed. Lobbying may be virtuous or deleterious, depending on public or private interests. To discuss.

For the remaining years of the Decade, with others, I think much will need change:

• Better late than never, HR --as indivisible-- are to progressively (but quickly) become the framework of the Decade so as to truly be bindingly addressing the root causes of malnutrition.
• PPPs and multistakeholder platforms (such as SUN) in the food and nutrition sector are to be placed on hold until reviewed under a new optic focused on CoI.
• An up-to-date comprehensive assessment of current international trade and investment regimes and their norms and policies is needed so as to ensure that they do not limit states’ ability to perform their sovereign duty bearer responsibilities.
• Greater progress towards achieving the WHO NCDs Action Plan must be demanded from UN member states and from the private sector. (…not just by reformulating junk food!).
• Nutrition education needs to be reconsidered to encompass a wider focus more based on the basic/structural causes of worrisome nutrition outcomes. Basically, how we train nutritionists and health workers to work with policy makers and with communities needs to be changed with a more bottom-up approach creating enabling environments for change rather than focusing on behavior change communication. 
• An independent assessment of the impact of the private sector on nutrition policies and funding needs to be commissioned including the impact of the private sector’s role in CODEX ALIMENTARIUS and in the global and national SUN programs.
• Food safety interventions will need more emphasis including the thorny issue of antimicrobials use in animal husbandry.
• More emphasis is needed on all water and sanitation (WASH) issues and on violence and discrimination against women and girls.
• The protection, promotion and support of breastfeeding and complementary feeding desperately calls for a much higher positioning in the nutrition action agenda.
• As accountability must be much more centered on legitimate national and multilateral institutions, the direct participation of rights holders in all issues of nutrition governance --thus protecting the public policy space from undue influence by powerful economic actors-- has become un-postponable.
• Given the need to move away from unsustainable food systems based on agro-industrial food production, any further promotion of them is for us, unacceptable. So are unfair international trade and investment regimes and their responsibility in eco-destruction --all linked to climate change.
• Product-based approaches (e.g., vitamin capsules, RUTF,) must be limited and exclusively targeted to those that actually require them.
• Member states will have to pay more than lip service to sovereign local food systems and to traditional knowledge and native seeds based on biodiversity --and only accept participatory decision-making on these issues.
• Consumer protection against the ever-increasing influx of ultraprocessed foods will require a manifold increased mobilization of consumers as rights holders to demand the needed changes and regulations. This goes hand-in-hand with demands for subsidizing healthy foods, especially in ‘food deserts’.
• Finally, UN member states are to set participatory annual national benchmarks of progress commensurate with the allocation of adequate resources. It is in this spirit, that what remains of the Decade will eventually become a “People’s Decade of Action on Nutrition”.

All the above will require WHO and FAO, as well as Northern external funders and member states, to change the steering and implementation of the Decade in a more holistic and HR-based manner. The question is, can they? will they? Adherence to Extraterritorial HR Obligations will be key here as well.

The experience from other past UN 'decades' has not been too good. We need to do better --therein the challenge. Significant difference will only come from public interest CSOs and social movements pushing member states to commit to action plans and then hold them accountable for the same on a year-to-year basis.

Critical is to refocus the decade on the HR framework clearly identifying rights holders and duty bearers and doing an analysis of what their respective expected roles are. A massive HR learning process will be the only thing that will lead to this. A process of empowerment of rights holders to organize, mobilize and demand needed changes is key. Without this, we can anticipate little happening or just token steps to save face in front of the international community. Moreover, it is not for us to, top-down, decide priorities! It is for the rights holders suffering violations of their right to food and nutrition to lead in deciding priority actions!

The next five years boil down to a push or pull question. Only pulling from the rights holders side will move the Decade ahead. UN and other international agencies can do little to push member states to commit. History is clear about this. Forget about private sector actors being involved in empowering rights holders: it is counterintuitive to them.... This is why so many of us are skeptical about the SUN Initiative with its clearly visible CoI. As said, public interest CSOs have the crucial role in monitoring progress made in the progressive realization of ten year plans to fulfill the right to food and nutrition. Annual benchmarks of processes-set-in-motion have to be set so that CSOs can assess progress, stagnation or retrogression on an annual basis with something like shadow reports.

If shy of all this, we will be discussing the same shortcomings by the end of the Decade.

The full paper can be obtained from the External Affairs Secretary of WPHNA

I believe the very top priority for the coming period to improve global nutrition in high-, medium- and low income countries lies in very active promotion of national mandatory food fortification including ;

milk and milk substitute products with vitamin D;

salt with iodine; and 

flour or othe equivalent common use with iron, vitamin B group, including folic acid and vitamin B12.

The international agencies and NGOs striving to promote the Sustainable Development Goals, eg. UN, WHO, UNICEF, World Bank, FAO, UNDP and others, can and should actively promote this responsibility of national government providing political, technical assistance along with incentive grants.

The Canadian model, in efffect for many years is workable and successful. 

I have been in public health for over 50 yeas in Canada and Israel, with much experience in the European Region of WHO. I am lead author of a textbook called The New Public Health (Tulchinsky and Varavikova) in three editions since 2000 . We are currently workng on the fourth edition at the request of the publisher (Elsevier). Various editions have been translated and published in Russian, Bulgarian, Macedonian, Romanian, Uzbek, Mongolian, Georgian and Turkish languages. We are now working on the fourth edition.

Attached please find Proceedings of a Conference sponsored by the Israel Ministry of Health, the Israeli Association of Public Health Physicians and Ashkelon College on Micronutrient Deficiencies and food fortification in Israel  (7 November 2019). THe Ministry presented new evidence-based policies on food fortification. 

I would be glad to hear from persons and organizations interested in this topic.

Best wishes.

Theodore H (Ted) Tulchinsky MD MPH

Emeritus, Braun School of Public Health, Hebrew University, Jerusalem, Israel

Emeritus, Ashkelon Academic College, Ashkelon, Israel

Action Area 1: Sustainable, resilient food systems for healthy diets

• Scale up the inclusion of nutrition objectives in food and agriculture policies: increase production of context-appropriate fruits and vegetables for domestic consumption, and of legumes and pulses that contribute to healthy diets; raise production of oils in support of the elimination of industrially produced trans-fat in the food supply. [First of all, I find it devious that here you use the verb scale up in almost all action areas while in the survey you have the original verbs. The reference to SUN is, as I say, devious]. Wording on elimination of transfats must be stringer here.
• Accelerate food reformulation: provide reference ranges for sodium reduction level benchmarks for processed foods. Reformulation applies mostly to ultra processed foods. This is no solution, it is the white washing of Big Food to keep the public hooked to their products. World Nutrition has articles that make this plenty clear.
• Accelerate strengthening food control systems: implement national programmes for surveillance of food-borne diseases in humans and contamination of food-borne hazards in the food chain.

Action Area 2: Aligned health systems providing universal coverage of essential nutrition actions

• Scale up the integration of nutrition actions into health systems: integrate essential nutrition actions into national Universal Health Coverage (UHC) plans. UHC has been a controversial theme with public interest CSOs and social movements having a different take on it than WHO. Yes, nutrition is important in there.
• Address funding gaps: increase investments for nutrition in UHC, including for integrated data systems for tracking coverage and quality of essential nutrition actions. What are essential nutr actions? Do we all agree on these? No. Tracking only chronicles trends; what is needed more is actions …and we know a lot already.
• Accelerate progress on wasting reduction: implement the UN Global Action Plan on Child Wasting and its Roadmap.

Action Area 3: Social protection and nutrition education

• Scale up the implementation of nutrition-sensitive social protection policies: ensure coherence between social protection and other sector programmes such as with agricultural production, livelihood diversification and local economic development; national supplementary food bank programmes provide weekly vouchers to each user for purchase of fresh fruits and vegetables from local farmers. Nutr-sens social prot pols are nothing but the social determinants of (mal)nutrtion that the UN system has NOT embraced. It is only secondarily about coherence; it is about the social determination!
• Better leverage of schools as a platform for food and nutrition education and enabling healthy diets: set and improve nutrition standards for school meals. What is leverage? Keep in mind that school meals are mostly an educational intervention (retention), not so much a nutritional one. (stunting is already done for… any data on improving wasting?)
• Accelerate building nutrition capacity: increase the number and quality of nutrition professionals; train healthcare workers to better deliver nutrition action across the life-course. The key here is the content of the curricula. The ones currently there are biomedical and nutrient-centered. …not much help.
• Scale up the implementation of nutrition education interventions: implement easily understandable nutrition (front-of-pack) labelling on food products that supports consumers’ choices for healthy diets. Same as above: the content of this education is the key. Needs to change to include social determinants. Front of pack info is just a tiny part of the challenge (not very helpful for rural populations important sufferers of malnutrition)

Action Area 4: Trade and investment for improved nutrition

• Accelerate responsible and sustainable investments in nutrition: a minimum percentage of the overall national governmental yearly budget is set for nutrition interventions. Something to be said here about curbing Big Food/Big Soda investments in junk.
• Scale up the implementation of nutrition-sensitive trade policies: establish a national task force represented by different sectors for assessing the coherence between national trade policies and the implemented nutrition actions. FTAs have quite consistently been negative for nutrition. Throwing a task force at them (even if multisectoral) will do little. It is politico-economic issues that control these SECRET negotiations.
• Strengthen partnerships for data collection and development of tools: global institutions to continue to improve data collection and develop methods and indicators to better understand trade policy impacts on nutrition. What tools? Partnerships of EQUALS are certainly not the norm. Look at SUN… Data collection (only by global institutions?) on impacts of trade policies is a-posteriori, so, what good? Just chronicle negative impacts? Will that help in future negotiations?
• Accelerate public investments in local food supply chains: gradual increase yearly public sector government budget for investments in cold chain technology and post-harvest handling of perishable foods.

Action Area 5: Safe and supportive environments for nutrition at all ages

• Scale up the implementation of regulatory instruments to promote healthy diets: introduce taxation of sugar-sweetened beverages and subsidies for fruits and vegetables; implement legislation of marketing restrictions of foods and beverages high in fat, sugar and/or salt to children. Scale up? Hardly much exists. Be aware that the concept of healthy diets was contested by CSM during negotiations of the Voluntary Guidelines on food systems. CSM lost on this and on many other red lines it set. Parliamentarians have been absent in most of the advocacy work, so how will we get the needed legislation? Corporations lobby parliaments much more effectively!
• Scale up the implementation of nutrition-sensitive public food procurement policies: set food and nutrition-based standards for the food and meals provided in hospitals, care facilities and other public settings. Does this also apply to the general public? Are you talking about nutrients or food and meals for the latter?
• Scale up the implementation of national dietary guidelines: include in national dietary guidelines for children, adults and elderly biodiversity and sustainability considerations. I’d say NOVA MUST be mentioned here as the preferred alternative.
• Scale up the implementation of nutrition-sensitive policies for improving local food and nutrition environments: introduce zoning regulations and tax regimes to minimize food deserts and swamps. Again, you are skipping the social determinant by mentioning them by name, because they ARE part of the ‘F+N environment’. The role of aggressive penetration of UPfoods in deserts/swamps must be denounced here.

Action Area 6: Strengthened governance and accountability for nutrition

• Enhance political commitment through political dialogue and advocacy at national and sub-national levels: establish and strengthen coordination mechanism through a multistakeholder consultation process for the uptake of the CFS Voluntary Guidelines on Food Systems and Nutrition. Who will do this? us? We have a pretty dismal record, no? Is it not organizing and mobilizing claim holders that we have a real chance for changing this politically? Claim holders have never had level field dialogue with duty bearers and they have to achieve such equal level. The UN (and SCN) say they are human rights based, but are they? HR/RTF are not mentioned once in this action for the next 5 yrs… And, please, as a respect to a high proportion of us out there who opted out from the Guidelines, do not use ‘multistakeholder’ in this action plan.
• Address research funding gap: increase investment for research on the adaptation of global recommendations to the country context to support capacity development for implementation.
• Scale up investments in national nutrition information system: establish and strengthen a national nutrition monitoring framework in line with global guidance and the SDG monitoring framework in order to identify challenges and gaps for informed and effective policymaking. Again, info systems are only good if the data are used. Can we say this has been the case in the last 50 yrs? Hardly. We keep good statistics on how bad things are, yes. We know the gaps. Quantifying gaps does not automatically result in ‘informed and effective policies’. I am not saying we do not need this, but coupled with what? This is the challenge for the next 5 yrs of the (ailing) Decade.
• Accelerate global governance and accountability: use global summits such as the UN Food Systems Summit 2021 and the Tokyo Nutrition for Growth Summit 2021 for setting new commitments for action on nutrition and streamlining the global nutrition accountability infrastructure. Accelerate?? The global governance and accountability in F+N badly needs replacement, not acceleration. Look at the role of the conflicted private sector in SUN in glob gov. Furthermore, please keep in mind that a high proportion of us out there have opted out from the FSS for reasons widely explained. If the next 5 years will be guided by outcomes on the FSS, we are doomed. I think colleagues at the UNN know this.

I THINK TOO MANY ACTIONS ARE ASPIRATIONAL AND ARE TOP-DOWN. WHERE IS THE CONSULTATION HERE (IN COMING UP WITH THIS SO FAR) WITH THE REPS OF THE AFFECTED POPULATIONS?