Overall general comments: (all in a personal capacity)
[V0 is way too long and academic to digest. It must be drastically cut for it to have any impact on the CFS. If V0 cannot say what is needed and why in 30 pages, CFS will simply be overwhelmed (I am not talking about an executive summary, but a convincing piece of around 33 pages). One possibility, to start with, is to put the case studies in annex and summarize the outcomes of those in the main report.].
· V0 variously speaks of food, nutrition and/or unhealthy environments. Using this terminology, avoids using already UN-sanctioned language as relates to the influence of a) the physical environment, and b) of the social determinants of nutrition (a la Social Determinants of Health that are very explicit of what these determinants are).
· The concept of ‘value chain’ replaces the over 50 year old concept of ‘food chain’ (from production to digestion). Yes, it adds increases and losses of nutrients along the chain. But does it/shouldn’t it also add the tracking of for-profit hikes or distortions of food prices negatively affecting poor consumers as foods go from producers to consumers? (the latter not presented in Figure 27, p68 and only tangentially touched upon in Fig 29, p69)
· VO mentions the concept of food sovereignty only twice: Once anteceded by “it is argued…” and another time quoting CSM. It does not take a stand on whether the concept ought to be recommended for adoption by the CFS
· VO mentions the concept of ultra-processed foods 3 times: Once quoting the Brazilian Dietary Guidelines, once citing Popkin, and once just describing these products are consumed. V0 does not take a clear position on them.
· V0 does not mention the grave issue of land grabbing at all. This cannot be omitted in this day and age.
· There are very few examples worldwide of where the burdens of malnutrition have been made a political priority (Brazil for example--although in jeopardy now). The best we have to show for is a collection of vertical interventions with little or no participation of the affected, i.e., the claim holders. Malnutrition has simply not been addressed as a human rights violation. Publications like the Lancet Nutrition Series have nothing but contributed to this, claiming to be the best our profession(als) has(ve) to offer.
· In multiple places and indifferent contexts (7 times), V0 refers to “the poor”… This is such a depersonalizing pejorative thing to do… What we are really talking about is “those individuals and groups rendered poor by an unfair economic system”. Along the same vein, V0 mentions poverty alleviation or reduction 2 times when what it really ought to be talking about is “disparity reduction” in a 99/1 world.
· V0 mentions nutrition-sensitive approaches or programming five times without ever defining the concept.
· If we take the example of the needed mobilization aimed at democratizing all instances of nutrition governance, we have to be clear that this objective is not separate from, but very much part of, a mobilization effort of a wider perspective. To treat nutrition governance as somehow independent of national and global economic and political governance is outright absurd. Simply said, proclaiming that the challenges of nutrition governance can be dealt independently plays the important political role aimed at obscuring the vested interests and power relations at play. (relates to p72 and p104)
· Section 4.2 on p92 and beyond focuses on food system supply interventions. This is only one arm of the problem! The bigger constraints, many of us argue, are on the demand side, i.e., on the social determinants of nutrition as I argue in the first bullet above and also below as I critique the conceptual framework. (For instance: is innovation in technology really a very high priority? (Line 11 p92).
· In many places, V0 calls for multidisciplinary or multisectoral approaches to solve the problems of right to food violations. There is nothing terribly wrong with this concept, but it just gratuitously assumes that looking at the problem of these violations from a ‘wider’ multi-professional perspective is going to automatically lead us to the better, more rational and egalitarian solutions. The call is for sharing paradigms among the different scientific disciplines or sectors where practitioners come from. But by just putting together brains ‘sowed’ differently, without considering where they are coming from ideologically, is not going to, all of a sudden, make a significant difference in the outcome and the options chosen. They may well stay in the domain of immediate or underlying causes, only now everybody involved contributing a small monodisciplinary window to the package of (still pat?) solutions proposed. Multidisciplinary approaches simply, most often, take the social and political context (i.e., the individual and institutional power relations) as given; they therefore end up being conservative in their recommendations.
Specific comments:
INTRODUCTION
· Line 16 p9: not only decision-makers in the public and private sector (duty bearers) need to be empowered; they already have excess power in the prevailing system. It is claim holders that need to empower themselves to demand changes in the food system.
· Line 18 p9: The SDGs are not per-se accountability tools…
· Line 25 p10: It is not for the current leaders (duty bearers) alone to act for nutrition. Claim holders have to be given a say.
CONCEPTUAL FRAMEWORK
· Line 15 p11: The definition given is for Food Systems and not for Nutrition Systems which the VO claims to also address. The definition wrongly puts socioeconomic growth and equity (should be equity and equality!) only as outcomes and not as determinants. [see comment on social determinants (and not only outcomes) above].
· The Conceptual Framework diagram p14:
o Under Political and Economic Drivers, only livelihoods and income, markets and trade are mentioned. The more structural political and drivers are not mentioned: not acceptable in this day and age.
o A special box is allocated to consumer behaviors, but not a word is mentioned here about the role of Big Food in negatively influencing those behaviors: Should be in the diagram. (This is mentioned on p17, but not in the diagram). (The role of Big Food in shaping consumer behavior is also missing on page 108).
o The economic and social impacts are placed on the very right of the diagram as outcomes; should economic and social considerations not also find a place on the very left of the diagram as determinants of the food system?
THEREAFTER:
· Lines 1-6 p16: Mention is missing of the documented negative effects of fee trade agreements.
· Line 7 p16: GDP/cap is actually meant, but we know it is an average so of no help for work from a right to food perspective.
· Lines 21-29 p16: The determinants of demographic drivers are missing here.
· Lines 36-49 p16: No mention is made of the encroachment of cash crops displacing food crops.
· Lines 14+15 p18: No mention is made of why some vulnerable groups rendered poor spend most of their income on food.
· Line 29 p18: Reformulation of ultra-processed foods is not the solution as clearly shown by Monteiro et al. Yes, industry can reformulate, but will boast about it as an advertising gimmick….and we will still be hooked on ultra-processed (junk) food for ever longer. (also in p83)
· Lines 24-35: Mention of the Brazilian Guidelines ought to be made here too.
· Lines 2-4 p24: Again here, economic and social equity parameters are seen as outcomes and not also as determinants.
· Lines 25-32 p33: The focus called for must also include regulating Big Food/Big Soda and the advertising of ultra-processed foods and soft drinks.
· Lines 16-21 p38 (Conclusions): See the 6th bullet of my general comments.
· Lines 32-40 p50: To preserve the fairness of V0, the critical literature towards the SUN Initiative (not a movement…) must be quoted, particularly in what pertains to the conflicts of interest of and lack of substantial investments by participating private sector actors to address the multiple burdens presented in V0. (Will this come after line 42 in p104?).
· Lines 18-19 p54: For many years, open trade on food dumped highly subsidized US grains in countries rendered poor with devastating consequences for small farmers.
· Lines 20-21 p.54: Increased trade is actually seldom associated with rising incomes; look at NAFTA.
· Lines 42-43 p54: Yes, nutrition and trade policies are included in the SDGs, but better coherence will not resolve the negative effects of the latter; much more is needed in terms of protecting nutrition in existing and upcoming FTAs. (V0 says this in the next page).
· At this point I started skipping….Just too much information to digest…
· Lines 19-25 p.62: This is the crux of the problem we are faced with in 2016 and beyond!
· Line 13 p72: Says: “Having good governance helps to support the provision of social services.” …. Not always the case: look at the USA.
· Lines 3-14 p86: This intro on nutrition education totally ignores educating and organizing consumers about the role Big Food and Big Soda play in eating and drinking habits that lead (not only) to NCDs. This, so consumers turned claim holders can demand their governments regulate and or tax ultra-processed foods.
· Lines 2-7 p87: CODEX is mentioned in a positive role here. But CODEX gives an inordinate place in the table to Big Food/Big Soda with public interest civil society organizations being shut out of meaningful negotiations that protect consumers.
· Lines 21-24 p87: What the example of Chile does not say is that the levels of unwanted nutrients in the labeling’s ‘red light’ (‘stop sign’) category are set too high due to industry pressures; permitted levels will go down to internationally recommended levels only over a period of four years: a typical delaying tactic by industry.
· Line 16 p91: Why is V0 asking more R&D in nutrient-rich foods? The Brazilian Guidelines are clear about the alternative (and correct) options.
· Line 37 p93: V0 says: “There are also ethical issues with genetic modification… Should it rather say: “There are serious issues….?
· Lines 29-38 p96: V0 says: “Increasingly, technology is playing a bigger role in influencing behavior through nudges or prompts in purchasing decisions.” Meaning what? and “A technology focus on prevention through nutrition and wellness category could be a well over USD trillion dollar market opportunity”. Really?? …and why should V0 worry about market opportunities? Furthermore, “The increase in available technology has empowered consumers to take charge of their own health”. Really?? …this must come from some type of a fabricated evidence source…
· Lines 13-17 p87: V0 says: “The ability to connect the right social nudges through information and convenience will help combat the issues of obesity.” Very unclear what this is supposed to mean, but it somehow rings wrong to me.
· Line 41 p100: V0 calls for subsidies for nutrient-rich foods. Why only? Why not mentioning subsidies for unprocessed foods as the Brazilian Guidelines call for?
· Lines 4-23 p104: By targeting the very poor, safety nets somehow attempt to ‘reduce poverty’ but, in reality, going for safety net approaches means accepting the exacerbation of inequality. As said above the real issue is not poverty alleviation, but rather disparity reduction.
· Line 29 p104: Why do these require “top-level design”? Is V0 not for participatory approaches?
· Lines 19-28 p105: V0 does not mention the many published important PPP critiques relating to inherent conflicts of interest in private sector participants. (Also missing on Line 42 p109). (I see V0 plans to still add a short section on conflicts of interest on page 107).
· Line 33 p109: V0 speaks of a nutrition-sensitive value chain approach and centers the same on nutrients, not on foods….Is this the way to go?
I AM AWARE THESE COMMENTS ARE LONG AND DO NOT HIGHLIGHT THE MANY GOOD POINTS THE V0 DRAFT HAS. THE INTENTION JUST IS TO MAKE IT BETTER.
Claudio Schuftan