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Madam
Chair, distinquished members of the Executive Board, ladies
and gentlemen,
I have
the privilege to address you on behalf of Consumers International,
one of the founding members of the International Baby Food Action
Network (IBFAN).
IBFAN
welcomes the draft Global Strategy for Infant and Young Child
Feeding which accompanies Draft Resolution EB 109/12 . We appreciated
the opportunity to participate in the consultation process on
the Strategy and the invitation to submit comments on the draft.
It is unfortunate, however, that our collective input in response
to WHO’s invitation was not reflected in the draft Strategy
which is before the members of this Board. The draft is now
dated 24 November 2001 but we were given a 30 November deadline
and we met that deadline.
We would
thus like to take this opportunity to highlight some of our
concerns.
Firstly,
it is essential that the paragraphs of the section "Defining
the Challenge" in the draft Strategy reiterate the recommendation
in WHA
Resolution 54.2 (2001) by clearly defining optimal infant
and young child feeding practices to mean exclusive breastfeeding
during the first six months of life, and continued breastfeeding,
with safe and appropriate complementary foods up to the age
of two years and beyond.
Secondly,
the draft Strategy fails to emphasize continued unethical marketing
of commercially prepared foods at the expense of breastfeeding
and home prepared complementary foods. It does not clearly acknowledge
that baby food manufacturers are still falling short of their
responsibilities under the Code. The many calls for implementation
of the International
Code and subsequent relevant WHA resolutions in the Strategy
are welcome but should not constitute mere rhetoric.
On a
positive note, we are proud to report that IBFAN has continued
with its legal Training
Courses for government officials. They are becoming very
popular and over the past 10 years, 550 officials from 114 countries
have taken part in extensive 8 to 10 day courses. Our latest
Training was for all the Gulf countries last November. A recent
evaluation of our work shows that it has had a direct positive
impact in 75 out of the 114 countries: a record we are pleased
with. Unfortunately, none of this work is reflected in the Secretariat’s
report.
Coming
back to the Global Strategy, IBFAN is concerned that activities
such as sponsorship; secondment of staff; funding for research
and conferences are also not identified as problems. The Strategy
has to reaffirm the concern raised in WHA
Resolution 49.15 (1996) regarding conflict of interests
and recognize it as a recurring threat to the full support for
breastfeeding by many institutions, associations and individuals.
IBFAN
has on many occasions expressed our concern about the need for
independent funding of research, especially on the issue of
HIV/AIDS and infant feeding. We reiterate this once more. The
UN system has a responsibility to ensure that its research programmes
and policies are not influenced by those with vested interest
in the outcome.
Thirdly, in relation to paragraph 16 of the Strategy, the document
should again give effect to the WHA
Resolution 54.2 (2001) which calls for improvements in complementary
feeding practices by recommending the widest possible use of
indigenous nutrient-rich food stuffs, and by ensuring global
compliance with the Code with regard to labelling as well as
all forms of advertising and commercial promotion in all types
of media. In this regard, we are concerned that the first two
paragraphs to the preamble on page 4 of the proposed resolution
EB 109/12 did not reaffirm the health and nutritional benefits
of exclusive breastfeeding. Instead, they emphasize nutritional
deficiencies which would be offset by improving breastfeeding
and optimal infant feeding practices.
The
use of micronutrient interventions should not replace or undermine
support for the sustainable practice of exclusive breastfeeding
and optimal complementary feeding.
Since
the marketing of nutritional supplements has the potential of
undermining a mother’s confidence to breastfeed, the Strategy
should stress that this type of marketing be subject to the
protective provisions of the International Code.
Fourthly,
one of the key points in the Strategy that requires further
strategic reflection is the definition of civil society as defined
in footnote 1, page 8. Commercial enterprises, and trade associations
have entirely different aims and objectives from NGOs, community
based organizations and groups like trade unions. Grouping them
together leads to confusion, adds to lack of transparency and
creates potential conflicts of interest. Therefore, the roles
of individual groups and actors should be clearly spelled out
in all WHO documentation including the Draft Strategy, and terms
such as "constructive dialogues" which serve as a
spring board for the public relations activities of the business
sector should be avoided.
For
the same reason, we are also concerned with the wording in paragraphs
2(4), 3 and 5(4) of the proposed resolution (EB109/12) which
includes a call for Member States to mobilize economic resources
from commercial groups and associations and places them as equal
actors in the implementation of the Strategy.
To end
on a positive note, we are pleased that the draft resolution
in paragraph 2(2) and 2(3) of the operative section contains
provisions for monitoring the implementation of the Global Strategy
and we look forward to lending our support to this endeavour.
Thank
you for your attention.
Yeong Joo Kean
Legal Advisor
IBFAN
----ends
Useful
links
WHO
EB Documentation home page
WHO
Report EB109/11 - Childhood nutrition and progress in implementing
the International Code of Marketing of Breast-milk Substitutes
(PDF)
WHO
Report EB 109/12 - Infant and young child nutrition
Note:
the draft Global Strategy for Infant and Young Child Feeding
is annexed to document EB 109/12.
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