المنتدى العالمي المعني بالأمن الغذائي والتغذية

Please find attached my comments on the FAO consultation: first draft work programme of the UN Decade of Action on Nutrition.

The PDF contains a large number of comments, in comment boxes and on the text while the word document provides my responses to the questions posed on the consultation.

Many thanks again for enabling me to have this opportunity of contributing to the consultation.

Regards,

Elizabeth

The programme provides concrete guidelines and steps forward in the Decade of Action on Nutrition. Yet, it may profit from a more proactive policy-oriented focus.

·         The work programme is comprehensive and: a) provides a summary of the state of affairs on global malnutrition; b) distinguishes the various forms of malnutrition (undernutrition, vitamin & mineral deficiency, overweight/obesity, diet-related non-communicable diseases), c) identifies the international framework of agreements that prioritizes nutrition, d) identifies aims, added value, guidelines, actions areas, means of implementation and accountability elements.

·         Actions areas and means of implementation constitute a sizable part of the substantive parts of the programme. It would be important to include or make reference to relevant experiences of nutrition programmes and actions, to set a more grounded context under which aims and action areas of the Nutrition Decade can occur.

·         With regard to the background section, please note:

·          The CRPD requires State Parties to “prevent discriminatory denial of…food and fluids on the basis of disability” [CRPD 25(f)]

·          The CRPD requires State Parties to “take appropriate steps to safeguard and promote the realization of […the right to adequate food…] without discrimination on the basis of disability” [CRPD 28]

·          The 2030 Agenda recognizes that 80% of persons with disabilities live in poverty (at para. 23)

·          Children with disabilities are at higher risk for malnutrition. A strong bilateral relationship exists between malnutrition and disability. The WHO report “Developmental Difficulties in Early Childhood” (2012) notes that Countries with high levels of malnutrition and nutrient deficiency often also report higher rates of disability and developmental delays. http://www.who.int/maternal_child_adolescent/documents/development_difficulties_early_childhood/en/

·          The UNICEF report: “Stronger Together Nutrition-Disability Links and Synergies Briefing Note” highlights that maternal and early childhood malnutrition lead to the development of disabling conditions and that the children with disabilities are at higher risk for experiencing malnutrition.  https://www.unicef.org/disabilities/files/Stronger-Together_Nutrition_Disability_Groce_Challenger_Kerac.pdf

·         Action Area 3 (on social protection and nutrition education): Stigma surrounding disability may result in children with disabilities being given less nutritious or smaller quantities of food, or intentionally not fed at all, with families rationalising that limited resources should be devoted to children who have a greater chance of surviving and contributing to the household. In order to be fully effective nutrition education must include elements to combat disability stigma. (UNICEF report “Stronger Together Nutrition-Disability Links and Synergies Briefing Note” (2011) pg. 8) 

·         Action area 4 (on trade and investment) cites general yet relevant policy tools such as taxation, subsidies for health foods, removal of subsidies to unhealthy foods and supply-side incentives. It would be good that such rich identification be also complemented with analysis in this and other action areas.

·         Action area 5 (Safe and support environments for nutrition at all ages):

·          The places where food and water are obtained must be accessible to all. Community based health and nutrition services must be provided in buildings that are accessible.

·          Child nutrition programmes should take into account that children with disabilities are less likely to attend school than children who do not have disabilities. Thus programmes designed to function only through school settings may not adequately reach children with disabilities.  (UNICEF report “Stronger Together Nutrition-Disability Links and Synergies Briefing Note (2011) pg. 6)

·         Action area 6 (Review, strengthen and promote nutrition governance and accountability): It would be useful to take into account the observations on institutions and linkages to SDG2, that was considered in session 3 of the expert group meeting held in Vienna in preparation for HLPF 2017 on readying institutions and policies for integrated approaches to implementation of the 2030 Agenda (with FAO, WHO and UNICEF in attendance, among others). (available at http://workspace.unpan.org/sites/Internet/Documents/Report%20Vienna%20meeting%20FINAL.docx.pdf

·         Table 1 is a great contribution to the identification of concrete areas of potential collaboration among governments and other relevant stakeholders in terms of means of implementation (p.14). 

·         It would also be important to allude to the linkages between agricultural sustainable policies and complementary policies in the industry and services sectors. For example, the provision of "incentives for local and small farmers and SMEs" (p.14) would be more effective if industrial and environmental policies were part of a national development strategy that prioritizes sustainable agriculture by strengthening capacities for a) seeds production, b) commercialization, c) transport infrastructure, and d) access to affordable food.

·         A linkage between Action 2 (health systems) and Action 3 (social protection and nutrition education) may be needed: while Action 2 alludes to the provision of "universal health coverage UHC), Action 3 alludes to "basic or minimum social protection floors" (p.6). It would be worth considering "health care floors" as complementary or part of "social protection floors" – as anchor for 'minimum and broader floors' in all countries.

·         The programme is inclusive of all relevant stakeholders and aims at supporting "the establishment of action networks". Nonetheless, this would still be a top-down approach unless it includes and prioritizes a) the farming experiences at the local level, b) agriculture as an engine of growth and higher productivity, and c) agriculture, forestry, and fishing activities as cornerstones of sustainable processes of structural transformation.

·         We note that there is only one reference to indigenous peoples. We believe that it will be important to include references to traditional knowledge systems and traditional livelihoods.  These are referenced in the 2007 UN Declaration on the Rights of Indigenous Peoples and also in the outcome document of the 2014 World Conference on Indigenous Peoples (A/RES/69/2):

·          OP 22. We recognize that the traditional knowledge, innovations and practices of indigenous peoples and local communities make an important contribution to the conservation and sustainable use of biodiversity. We acknowledge the importance of the participation of indigenous peoples, wherever possible, in the benefits of their knowledge, innovations and practices.

·          OP 25. We commit ourselves to developing, in conjunction with the indigenous peoples concerned, and where appropriate, policies, programmes and resources to support indigenous peoples’ occupations, traditional subsistence activities, economies, livelihoods, food security and nutrition.

Nutrition For All Analysis of work programme of the UN Decade of Action on Nutrition, 2016-2025.

We at ‘Nutrition For All’ would like to thank the UN SCN Secretariat for giving us the opportunity to contribute to this living document. The Work Program is a good step in showing the open transparent nature of what Nutrition Decade aspires to be. Given the excellent submissions on this forum, the Work Program will change rapidly. We at ‘Nutrition For All’ look forward to the work programme’s evolution.

In particular, we would like to cite submissions from the Sun Movement, regarding the investment case for good nutrition and the double burden as well as country ownership, Raghaventra Guru Srinivasan, regarding the business case for good nutrition and national ownership on tax policy. We strongly agree with Sandy Thomas regarding the lack of reference to obesity and childhood obesity. Save The Children legally binding legislation and clearly reminding us of the metrics in terms of what funding is actually required. We strongly endorse the concept from Jane Sherman on a framework policy on nutrition interventions to act as a guide for Government and aid organizations under criteria such as cost effectiveness and impact. We would like to also to congratulate Jane on her outstanding submission on nutrition education. We pay special attention to Stefano Prato from the Society for International Development Kenya for an excellent and systematic set of documents. Samantha Chivers from 1000 days United states for giving us a realistic overview of funding issues with Decade Nutrition itself.

We would like to contribute to Decade Nutrition’s work program vision, elements and action areas with the following recommendations and rationales.

1. The Nutrition Landscape – Talking About All of The Problem – All of The Time:

The Nutrition landscape:

The nutrition landscape has changed so rapidly that we in the nutrition community do-not either have the words or mindset to deal with it. If we are to finally end global malnutrition it needs to be done using an inclusive and unified approach. We need to be talking about all of the problem all of the time.

Language:

We find that a barrier to a unified approach to ending malnutrition is our narrative around it. The recurring statements by the Nutrition Community which call obesity over-nutrition is confusing because we simply cannot be over nourished and malnourished at the same time. It suggests a lack of urgency and is factually incorrect.

Recommendations:

1.1 We propose two possible terms for malnutrition in its two manifestations that are both clear and accurate.

Underweight Malnutrition or Sub Asian Malnutrition and Overweight Malnutrition known as Obesity.

Rationale:

We believe that the words we use are important because it will, in particular, allow Western Nations to take owner ship of the problem. It will also allow governments to present more accurately to its people, the scale and magnitude of the problem that we are all facing.

2. Looking at malnutrition in all its forms:

The Global Nutrition Report 2015 has stated that in order to achieve the second sustainable development goal “we need to pay as much attention to the obesity epidemic as we do to under nutrition“. Given that the ultimate aim of Decade Nutrition is to support ICN2 and the SDGs and the adoption of the WHO’s global noncommunicable disease (NCD) targets by 2025. It is surprising therefore that the draft Work Program is focused on underweight malnutrition with much less emphasis on overweight malnutrition. As was pointed out by Sandy Thomas from the Global panel on Agriculture and Food Systems for Nutrition. It is also surprising to us that the WHO European union and South East Asia action plan for ending obesity in children has not been mentioned given its relevance to global malnutrition.

The Nutrition Decade needs to be a time when we radically redefine our thinking around malnutrition and food production systems. We need to understand better how we present the scale of the problem to our citizens.

Recommendations:

2.1 That Nutrition Decade focuses equally on all aspects of malnutrition

2.2 In line with the Global Nutrition Report 2016 “All national governments should establish SMART national targets for stunting, wasting, exclusive breastfeeding, low birth weight, anemia, childhood overweight, adult obesity, diabetes, and salt reduction by the end of 2017. These targets should be ambitious but achievable and aligned”

2.3 It is imperative that we find ways to make nutrition newsworthy, interesting and personally relevant to everyone. We can do this by creating an inclusive approach that has at its center citizens right to informed choice.

We must directly tackle the impacts and perpetuating cycles of over consumption to health and wellbeing and consequential climate change. We would also suggest that Stainable Development Goal number 12 has a much higher relevance to nutrition than is being suggested. Both our personal consumption and production of food is affecting our lives so negatively. We must act now with the knowledge of what 2050 will be like if we do not succeed. History's pen is watching what we are now doing.

2.4 Establish a world nutrition summit template on the climate change talks in Paris. Please find attached document and brief overview further on in the document.

3. Investment Needed – We Know What To Do:

The painful truth that every organization and institution working in nutrition faces daily, is that we know exactly what to do but we simply do not have the financial resources or the political support to do it or political will

Not only is under investment in nutrition morally incomprehensible it does not make economic sense to not invest given the clearly documented returns. Malnutrition in all its forms is costing 2 trillion dollars per year. We know 6.5 million people, half of whom are children are dying annually because of its effects. According to the World Bank we need an annual investment of 7 billion dollars. Investment over the next 10 years which will give a return of 17 times that number. Tackling malnutrition is proven to be one of the most powerful policy options available to improve our overall health and long-term prosperity. So why is this investment not happening?

Recommendations:

3.1 As a matter of priority set up an advisory nutrition funding council that will reevaluate and reenergize all possible funding and financial streams such as:

The unrealized promise of development aid reaching 0.7% GDP

• Look again at where official development assistance (ODA) is being allocated and how new rules on how it is defined, is hindering on the ground impact.

• External Debt repayments of low-income countries. Following the example of Denmark on its stance on unethical lending to Mozambique. Given the high returns on investment on nutrition it makes financial sense to Reinvest the Debt straight into nutrition. This reinvestment could be one of the flagship calls for Decade Nutrition.

• Strengthen advocacy for Investment

• Consider a Reinvest the Debt campaign

• International Monetary fund

• World Bank

• Investment funds

• Stock market

• Reinvest unhealthy food tax back into nutrition initiatives

4 Country Commitments Accountability:

“More must be done to hold countries, donors, and agencies accountable for meeting their commitments to improve nutrition." Global Nutrition Report. (2014)

Recommendation:

4.1 Governments to set legally binding targets in order to meet commitments on ending malnutrition in all its forms by 2030. To the extent we know the scale of the problem, we can set targets to reduce it by percentage year on year from now till 2030. The voluntary route is unfortunately not yielding results. Millions of people are dying on our humanitarian watch. We are now at the scale of billions of people are not reaching their full potential because their basic rights to nutrition are not being met. The malnutrition crisis should be committed to, in the same legally binding way we are committing to change our behavior on Climate Action, including cost implications which are to be directed into investment in nutrition.

We believe that these need to be key questions of the Nutrition Decade.

5. SUN Movement Mechanisms – A Template for Change:

A stated aim of Nutrition Decade is to foster a global movement to end all forms of malnutrition within existing structures. We are fortunate to have such a structure in place already in the form of the SUN Movement, which is a framework for action that is working. Its vision is to have a world free from malnutrition in all its forms by 2030. It is impossible however for the movement to achieve its stated vision, as it is continuing to concentrate on underweight malnutrition.

However, the mechanism is in place for that to change ‘SUN is open to all countries whose governments commit themselves to scaling up nutrition and to all stakeholders committed to providing support.’ (SUN ICE ToR, 4) (Mokoro, 2015: 8)

A central question for the future of the movement needs to be whether the next developmental stage requires it to become a truly global movement.

Recommendation:

5.1 SUN’s evolution needs to include a broader nutrition objective, that would also specifically address over weight malnutrition and so embrace all forms of malnutrition on an equal footing. Tailoring SUN support to different country contexts and needs. The west can take a leadership role with swift multi sectorial actions spurred on by the active membership of the SUN Movement. Citizens know if they are overweight, they do not however know that they are malnourished. This might help to generate public debate.

Rationale:

Creating a truly global multi-sectorial will help all countries and its’ citizens to face the problem ahead of us inclusively. This so far has not happened and in the view of Nutrition For All is unlikely to happen given current plans. Resources will need to be in place to facilitate such an expansion. We however feel strongly that such a move can and will be revenue positive.

6. Call to Action - Nutrition For All World Summit:

A proposal has been sent in late 2016 to a small group of people in the nutrition sector for a Nutrition For All World Summit. Inspired by the Paris climate change talks, the Nutrition for All Summit, where every country would recognize their problem in terms of malnutrition and make public commitments to its citizens. This is what Tom Arnold former SUN movement coordinator regarding the proposal for the Nutrition for All World Summit. (2016)

“There is a lot in the submission I agree with. I also admire the work you have been doing in India over many years and the credibility this brings to underpinning what you are advocating for.’’

Find attached Nutrition For All world summit proposal.

Rationale:

Over-nutrition, obesity and their associated non-communicable diseases are now widespread and increasing so rapidly that the World Health Organization refers to this phenomenon as a new pandemic. Moreover, obesity is growing in all developing regions, even in countries beset by high levels of poverty where increasingly there is a double burden on the healthcare system from Under Weight Malnutrition-nutrition and Overweigh Malnutrition.

All international conferences on nutrition focus on underweight malnutrition. A unified global response is needed and has been shown to work as is evident in the Climate Change talks. A key to the summit will be to stimulate citizen involvement. Nutrition Decade can play a key role in this. Investment in solving underweight malnutrition and overweight malnutrition would be key elements of the proposed summit.

Data Collection:

“As the world embarks on an ambitious project to meet new Sustainable Development Goals (SDGs), there is a urgent need to mobilize the data revolution for all people and the whole planet in order to monitor progress, hold governments accountable and foster sustainable development” A World That Counts 2014

Nutrition For All have developed and completed the first year trialing of the 1000 day app. It is a real time data collection monitoring and evaluation tool, that encourages stake holders to implement targeted nutrition programs around the first 1000 days of a child's life. It is bringing data monitoring into the 21st century with a intuitive, easy to use interface that is within the learning capabilities of all field workers. It relies on SMS to send and received data such as real time outcomes.

A short video outing the app is available to watch. The system cost E 120,000 to build and a lot of hard work. We are taking steps for this to become open source so that Governments can create there own versions of it and helping regain autonomy over their Nations nutrition status. We are seeking more stakeholders to conduct field trials of the 1000 day App.

How can we contribute to Decade Nutrition:

We at Nutrition For All believe that we can be a strong independent voice of advocacy with an inclusive approach. We will advocate for nutrition without prejudice and with out preconceived ideas of what is not possible. We come with a decade and a half field experience in targeted Maternal nutrition programs. And Community Management of Severe Acute Malnutrition (CMAM)

We warmly welcome all contacts regarding this submissions.

[email protected]

Pat J Mc Mahon

I would like to add that a focus on ethno/anthro food knowledge be taught. Each culture has indigenous knowledge that should be preserved. This knowledge includes food preparations methods including fermentation that is now being found to be 'cutting edge' in the research areas of human health and the microbiome and interdependence of humans and the organisms that help keep us functioning to our peak capacity. Fermentation also acts to preserve foods (from spoilage and harmful organisms) and prolongs 'shelf-life' where refridgeration is limited. 

UN Decade of Action on Nutrition

Draft Programme

Comments from the Private Sector Mechanism

The Private Sector Mechanism  welcomes the opportunity to provide comments on the work programme of the UN Decade of Action on Nutrition. Several PSM members have already commented individually, this is a summary of our views.

1.     Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources?

The PSM supports the overall aim of the Work Programme to provide a clearly-defined, time-bound operational framework for governments to adopt and implement nutrition-related initiatives to create sustainable food systems and enabling environments that promote healthy dietary practices and support the fulfillment of ICN2 commitments and achievement of the diet-related NCD targets by 2025 and the Sustainable Development Goals by 2030. PSM supports a Work Programme that is guided by the principles of inclusiveness and we are encouraged that the current draft work programme recognizes recognises that addressing all forms of malnutrition and NCDs requires the commitment of all sectors and of a wide range of stakeholders, including the private sector.

2.     What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition?

The PSM supports the selection of the 6 priority areas. On trade, we would like to point that trade policy frameworks that foster open, dynamic, and competitive economies increase food security and improve nutritional outcomes. Trade is an essential tool for ensuring commodities and food can be effectively and affordably distributed when and where they are needed and for promoting economic opportunities for producers[1], in particular smallholder farmers and SMEs. Trade also creates opportunities beyond the farm because of the potential for value-added employment in food processing, marketing and distribution[2]. Trade policies also have a knock-on effect on farmers’ and countries’ decisions to invest in agriculture and to adopt new technologies. Open markets and private enterprise are critical for development and are an important part of achieving SDG 1 and 2. Trade liberalization protects national food markets against domestic shocks, and thus insulates vulnerable consumers from price volatility, by allowing more food to be imported in times of shortage and exported in periods of plenty. Standard setting is of key importance to trade. Global standards need to be science-based and developed through broad-based consultations. The Codex Alimentarius plays a critical role in food trade, as the most important international standard setting body in the areas of food safety, quality and fairness. It enables trade in agricultural products to benefit producers, importers and consumers.

3.     Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas?

In order to effectively achieve the Decade of Action’s goals, we believe that the private sector should play a key role in helping people everywhere to achieve and maintain balanced diets and healthy lifestyles. Improving food security worldwide requires the collective effort of all stakeholders. We support actions for sustainable food systems that promote healthy and safe diets and strategies that integrate nutrition and food safety objectives into food and agriculture policies and strengthen local food production and processing. We believe that real progress can be made only through a constructive, transparent engagement between Governments, international organizations, the private sector and civil society. The Private Sector Mechanism is committed to working with all stakeholders to contribute to the success of the Decade.

4.     How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing?

The PSM continues to advocate for a focus on foods and diets rather than single nutrients in any policy development and activities, other than where specific micronutrient deficiencies need to be addressed through targeted food fortification and/or supplements. Foods and diets are far more than the sum of their individual nutrients. Nutrients are not consumed in isolation and it is inaccurate to generalize about the effects of a single nutrient without considering the food matrix in which it is present. In some countries, dietary guidelines are shifting away from recommendations based on nutrients or foods in isolation and now focus primarily on healthy eating patterns.

In addition, we wish to underline the added value of focusing on stimulating concrete nationally-determined policies and programmes with the objective of creating sustainable food systems and enabling environments that promote healthy dietary practices. A localized approach is of utmost importance in order to ensure member state ownership of initiatives and policies in the context.

We wish to support HarvestPlus comments when they note that “Two important issues/topics that we think are missing from the action areas are: (a) both in situ and ex situ conservation of agricultural biodiversity – which is crucial for the development of productive and nutritious varieties/breeds of crops and livestock that are adapted to ever-changing and agroclimatic conditions, and (b) biofortification, i.e., development and delivery of micronutrient-enriched staple food crops, which has been proven to improve vitamin A and iron deficiency status.  Both conservation of agricultural biodiversity and promotion of biofortified crops merit inclusion under action area 1 (sustainable, resilient food systems for healthy diets). UNSCN might consider consulting/collaborating with the Convention on Biological Diversity on (a), and with HarvestPlus on (b).  Both of these topics should also be included among the potential topics for the development of commitments and the establishment of action networks, listed in table 1.”

Finally, we do not understand Table 1 in Annex: Potential topics for the development of commitments and the establishment of action networks. We are not sure what this is meant to be, how the list was compiled and how it is supposed to be used. The list of topics sounds eclectic and not based on any particular piece of research. We would recommend deleting it from the work programme at this stage, unless clarification is given into how it was developed, what the rationale and criteria were for selecting the topics and how they are meant to be used.  

5.     Do you have specific comments on the section on accountability and shared learning?

We are encouraged to see that the Work Programme recognizes that actions taken by governments and other stakeholders must rely on the latest scientific evidence. The PSM also strongly believes that policy initiatives must be supported by strong scientific evidence.

Thank you for the opportunity to offer comments on the E-consultation. We are pleased to note the awareness placed on the role of food safety and quality. We have offered editorial comments with deletions shown in track changes and additions in red on Action Area 1. 

Please find the comment attached.

Dear Christine,

I have followed discussions in this Forum  and have enjoyed many shared contributions.

I would like to add the following:

 Even though many talked about the need of strong coordination and Leadership, my big concern is how actors in diverse areas build synergies to  ensure strong impact. In many times, complementarity is only on paper even when we hear one UN, we don't see much  in concrete action. Often what we see is a kind of verticality in the way every organisation implements interventions and some times on less benefit for people served when they are the same. So I think the program should help countries create concrete ways to bring actors be complementary to reach better results.

Thank you and best Regards,

Judith

To: FSN Moderator

Subject: FIA Responses to the Open discussion on the first draft work programme of the UN Decade of Action on Nutrition

Dear Sir/Madam,

Food Industry Asia (FIA) would like to thank you for the opportunity to participate in the consultation on the Open discussion on the first draft work programme of the UN Decade of Action on Nutrition.

Please find attached contribution from FIA.

Should you have any questions, please feel free to contact the Secretariat at [email protected] or Celia Zheng, Regional Policy Officer of the FIA Secretariat at [email protected].

Best regards,

Food Industry Asia (FIA) Secretariat

1 Scotts Road, Shaw Centre #19-07/08, Singapore 228208

1. Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources?

That nutrition has been bestowed with a “UN Decade” assignment  is a serious and honorable matter and should reflect the responsibility this entails of really drawing on the wider United Nations framework  as informed by its Charter.  While appreciating that this is to be an action programme, the nutrition community must recognise some of the fundaments of the United Nations and build them into the frame for the Nutrition decade and fit the action areas accordingly.

1. What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition?

I miss an introduction or preamble which problematises in short and crisp language, some of the major causes of malnutrition at different levels, hereunder as related to skewed economic and other power relationships, and forms of exploitation that lead to poverty as the key underlying determinant of food inseurity, hunger and undernutrition and to a large extent also poverty-based obesity and related NCDs. The responsibilites of the corporate sector and other economic interests should already at the beginning be tabled as potentially conflicting with people’s interests,  also to make it more meaningful to establish an action network for managing conflict of interest.

The Decade coincides with signs that human rights as a basis for food security and nutrition progamming, implementation and monitoring is again on the rise, informed particularly by the human right to adequate food and diet-related health but also other relevant human rights. While the ICN2 was weak on this, the Nutrition Decade is the occasion to bring human rights more systematcally  to the fore in fighting all forms of malnutrition.  The draft programme has an explicit opening for this in paragraph 14: “The Nutrition Decade will provide an enabling environment such that national, regional and international policies and programmes respect, protect and fulfil human rights obligations in accordance with the progressive realization of the right to adequate food and nutrition and other related human rights.”

However, this statement is meaningless unless further operationalised for what the human rights obligations listed (now reckoned as part of international human right law) would mean in practice at each stage in the “action”. It is fully possible to carry out that exercise and it should be done as part of the  further developent of the work programme . Inspirations can be found in the excellent work carried out by the FAO Right to Food Unit since 2005, and in more recent inititives by several departments of WHO, including Nutrition for Health and Development Department.

1. Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas?

and

1. How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing?

Members of the Norwegian-based research and action network FoHRC – Food, Human Rights and Corporations, would in principle be ready to engage in discussions how elements of a rights based approach (as developed by the UNDG and specified further for the right to food by FAO); could bring new dimensions to the conduct of action on nutrition within the areas proposed. The relative length of the decade (9 years) offers the opportunity for testing human rights theory and values against practical realities, drawing on experiences from policy/programming and grassroots initiatives as would already be documented. Master students trained in both nutrition/PHN and human rights might be available for part of this work, also in their own interest.

And why not establish a separate Action network for operationalising a human rights based approach to action on nutrition?  Or, combine this with the one proposed on Conflict of interest? One should also remember that one of the key values in human rights thinking and practice is the accountability of duty-bearers.

A special case of a human rights approach is the work of the UN regarding business and human rights (UN Guiding Principles on Business and Human Rights adopted by the UN Human Rights Council in 2011), emphasising Member states’ established obligation to protect their population from any harm done by a third party e.g. business, and at the same time the need for business to respect human rights in their operations and business relations.

FoHRC tries to operationalise these principles for the food-related business sector, which should be of interest to all concerned with the need for the food industry to end harmful practices (e.g. unethical marketing to children) and begin respect the human right to adequate food and diet-related heath.

1. Do you have specific comments on the section on accountability and shared learning?

The Independent Accountability Panel seems to be the potentially most important mechanisms for accountability in the area of women and children’s (nutritional) health.

On shared learning, there will be a general need for sharing/learning new knowledge and experiences across sectors. In the case of human rights and nutrition, two very different sets of knowledge (legal and biomedical) and practice must be shared and synthesised for mutual understanding of how to handle nutrition challenges through a rights-based approach.  The work programme should take account of this.

Dear Christine, 

Please see below the submission to the open discussion from 1,000 Days in Washington, D.C. Please feel free to contact me with any questions. 

Best, 

Sam

1. Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources?

The work programme provides a basic framework for organising action across the UN agencies, as well as providing strategic opportunity for donor and high-burden countries to take action against malnutrition. However, without either a dedicated funding stream, institutional space and staff, or compulsory actions for members, the initiative does not provide a compelling vision for action.

As a coordinating mechanism, the Decade will not have a lot of power. Without dedicated funding, the vision presented here is primarily a monitoring one, not an active or advocacy one, so does not reflect the urgency in which the world must invest in nutrition to achieve the WHA targets.

Unfortunately, we believe that the roles and responsibilities remain vague, accountability issues are not addressed in detail, and the ‘how’ remains to be detailed. In order to enable strategic interaction, there is a need to have more of a focus on resource mobilisation, more concrete outlines of specific actions, timelines/time commitments and next steps.

A welcome addition would be more country-specificity outlining a focus on high-burden countries and awareness of differences between locations in terms of how to tackle malnutrition in all its forms.

2. What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition?

3. How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing?

To 1,000 Days, the goal is to integrate nutrition as a cross-cutting issue into the work of all UN agencies, but how to do that is not clearly enumerated in this workplan. One way to do that would be to require UN agencies to implement nutrition (-sensitive) indicators into related programming.

Related, this work plan sets out to accomplish a lot in the next 10 years, with very little guidance on how to stay on track. This is problematic to reaching the goals laid out, but also to suggesting any urgency of action. Having annual goals as benchmarks to periodically measure success against throughout the Decade would reflect its progress.

We also question the level of ambition to member states only achieving ‘one or more’ of the nutrition targets, or ‘one or more’ of the ICN2 recommendations, as this will not hit the 2030 targets. Commitments should not be voluntary, as this is unambitious and not SMART enough - clear time-bound targets and commitments over the next two years are needed, with review and follow up hereafter.

Reports to the UN coordinating bodies (WHA, UNGA) are biennial, not annual. That doesn’t provide many opportunities for information from a “decade” of action; in fact, perhaps only three or four reports will be provided by the end of the decade, after the platform is fully implemented. A lack of annual focus also does not provide a lot of impetus for countries to move quickly and thus, to achieve results. We understand that progress in changing malnutrition plans will take time, and there may not be too much progress to report each year, but small victories, including the development of costed plans and the uptake of policies in high-burden countries, is a victory and should be celebrated. Annual reports would provide a more compelling vision for all actors.

Having a clearer remit to promote integrated action between nutrition and other nutrition-related sectors such as WASH.

Table 2 seems incomplete, without specific timelines and details of activities and responsibilities. There is also a lack of what the intended impact/outcome would be for the secretariat’s activities (besides ‘convening member states’ etc.). We therefore urge the Secretariat to finalise Table 2 in conversation with member states and civil society actors to act as a work plan for the period April 2016-April 2018.

The range of action areas is broad but relevant to the issue.

The communications aspect seems well designed and ready to implement.

4. Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas?

1,000 Days is the leading NGO that advocates for action and investment in child malnutrition. As such, our advocacy work aligns with several action areas of the UN Decade of Action. We are also the secretariat for the International Coalition for Advocacy on Nutrition (ICAN). As such, we are managing ICAN’s response to the Decade of Action, in both advocacy and communications. As both 1,000 Days and ICAN representatives, we are willing to share advocacy goals and targets, and use and support accountability mechanisms. We are also willing to review and participate in shared creative work as part of campaigns, and are very interested in working directly with UN leaders to co-develop campaigns as a CSO partner.

5. Do you have specific comments on the section on accountability and shared learning?

A database can be a great tool for monitoring, accountability and advocacy, provided it is kept up to date and with strong institutional support and separate earmarked funding. Specifics of where such earmarked funding would come from would be a welcome addition. ICAN believes that the reporting to UN coordinating bodies, such as UNGA and WHA, should be done on an annual basis, not biannually, to have annual goals as benchmarks to monitor progress and success, create a sense of urgency and ensure achievements are made within the Decade’s existence. Commitments by governments are only encouraged as voluntary and not required - and all reporting done through self-assessments – which will lead to issues of accountability. There is a clear need to outline whether and how this information will be verified.