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In 1981 representatives of the world's
governments met at the World Health Assembly and adopted Resolution
WHA 34.22. This included the International Code of Marketing
of Breastmilk Substitutes as a "minimum requirement"
to be implemented "in its entirety" to protect healthy
practices in respect of infant and young child feeding. Since
1982 additional Resolutions clarifying and amplifying the International
Code have been adopted every two years. Under Article 11.4 of
the International Code NGO's are assigned the role of monitoring
and reporting the activities of the manufacturers and distributors
of baby foods, bottles and teats.
Why monitor the International Code?
The International Code was adopted by the
1981 World Health Assembly (WHA) to protect infant health by
stopping all forms of promotion of breastmilk substitutes and
bottle-fed complementary foods. The 1996 Resolution WHA 49.15
calls for all complementary foods to be marketed or used in ways
that do not undermine exclusive and sustained breastfeeding.
While governments are called on to implement the International
Code and subsequent, relevant Resolutions, companies are called
on to abide by the Code independently of any other measures taken
to implement it. Monitoring around the world shows that widespread
violations continue. The accurate collection and reporting of
examples of violations is essential if the irresponsible marketing
practices which encourage mothers and health professionals to
favour artificial infant feeding is to be stopped.
Information provided by monitoring helps
international organisations such as UNICEF (the United Nations
Children's Fund), WHO (the World Health Organisation), aid agencies
and IBFAN in their work to protect infant health. IBFAN reports
on company tactics, as an independent audit of implementation
of the International Code and Resolutions. These reports demonstrate
the need for transparent, independent and effective controls
on the marketing of the baby food and bottle and teat companies.
You can help by observing the infant feeding situation in hospitals,
clinics, shops and in public in your area.
It is also possible to stop specific violations
if your country has implemented some or all of the measures of
the International Code and Resolutions in laws or other regulations.
If this is not the case pressure can be applied to companies
by raising public awareness and encouraging people to take action
by, for example, writing directly to the Chief Executive Officer
or supporting a boycott of the company's other products.
How to monitor
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"UNICEF proposes that
IBFAN and other NGOs that regularly fulfil the monitoring
role assigned by the World Health Assembly to NGOs be
given renewed encouragement to continue monitoring compliance
with the International Code....UNICEF views this as
an issue of great consequence....It speaks, quite simply,
to child survival and development. There is too much
at stake for the International Code to be ignored."
UNICEF, 14 January,
1997
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Monitoring involves investigation, observation
and recording of information. Be inquisitive and persistent,
but also sensitive.
- Prepare carefully: familiarise yourself
with the main points of the International Code and Resolutions
and any national measures. Find out the names of baby milk
companies and their brand names in your country (ask in
a pharmacy).
- Pay close attention to detail: in all
your notes, make a careful record of dates, company and
brand names, name and address of hospital, clinic, store,
etc. name and position of person giving information, descriptions
of posters, displays, etc. (take photographs if possible).
- Protect confidentiality: assure the person
giving information that his or her name will not be published
or disclosed to a superior or company.
NB: we are monitoring company practices,
not policing hospitals. This work is to support health workers,
not to undermine them.
Collect evidence
You will find it useful to equip yourself
with the following items when you are monitoring:
- Pens
- Notepad
- If possible, a camera.
Auto-focus cameras with a built-in flash
unit are good because they are small and quick. Try to take good
quality pictures, however, as they may later be published in
reports. You can use colour or black and white film.
Obtain copies of code violations wherever
possible. Examples of brochures, booklets or labels may be available
or you may be able to take photocopies or photographs. Make sure
you have a clear record of where and when such items were found.
If you write on the items be careful not to deface them.
Monitoring in hospitals and clinics
If you are a health worker or a mother-to-be
it will be straightforward to examine what happens in the hospital
or clinic that you attend. If you are visiting a friend or relative
you may come across violations. Otherwise, it may be best simply
to contact or visit the facility, introduce yourself to the staff
and explain that you are researching the support and protection
of breastfeeding.
At the hospital, try to visit the maternity
ward, nursery, milk kitchen, paediatric ward, malnutrition ward,
rehydration unit and offices of paediatricians, obstetricians,
nurses and administrators. Asking the same questions of different
people will increase your chances of finding the true situation.
Be aware that some hospital officials,
doctors and health workers have direct contact with the companies,
sometimes depending on them for financial support. This can mean
that talking to you creates a dilemma for them. It is important
to be sensitive to this. However health workers all want to ensure
the well being of the patients, and if they are confident that
the purpose of your research is for infant health, most will
want to help you. Some may be keen to talk, but uncomfortable
to do so while on duty. If this is the case arrange to meet afterwards
and leave a card with your contact details.
While it is important to get documentary
evidence to support your research, it is also important to protect
the confidentiality of health workers who need it, especially
when they give you sensitive information. You may even have to
withhold the names of people and hospitals from the rest of IBFAN
- other groups can confirm details with you personally if necessary.
If you are passing on information that should be treated sensitively,
make sure documents are clearly labelled as "CONFIDENTIAL".
In hospitals and health facilities ask
permission to talk to mothers with newborn babies. Mothers often
have a very different perspective on hospital procedures and
it is important that their experiences are taken into account.
They may also suggest other useful places to visit. If possible,
talk to some mothers who are about to go home since this is when
many practices which violate the Code and Resolutions occur.
Interview techniques
Start interviews with basic questions about
breastfeeding rates, the number of babies born, etc This will
provide valuable background information.
When you come to ask about artificial feeding
and marketing practices, do not ask questions which are judgemental.
For example, do not ask "when was the last time you
got a bribe from a company?" Saying that you heard
that some companies used to give money and presents to doctors
and nurses, and asking if the health worker knows if this
still goes on, will get a clearer reply.
Listen - don't argue. You want to collect
information, not get into a debate. So even if the health worker
says something with which you disagree, listen politely. You
can go back another time to discuss breastfeeding practices.
Take accurate notes throughout the whole
interview, not just when someone tells you something particularly
sensitive.
Direct observation
In hospitals and clinics, look for evidence
of milk company influence such as:
- free tins of baby milk
- posters, charts and similar
- booklets for mothers or health workers
gifts - any size, from clocks and fridges to pens and pads
company representatives
It is important to observe the different
rooms of the hospital: you may even be able to see things which
contradict some of the information you have been given. Take
photographs if possible. Write down all details about such items:
e.g. does a poster advertise a milk brand or just the company?
which brand? which company? what does it show? where is it? when
was it given to the hospital?
Monitoring at the point of sale
Visiting shops, supermarkets, pharmacies
and other locations where baby milks and feeding bottles are
sold will enable you to check for special displays, leaflets,
posters, special prices and other promotions. Interview an employee
and ask to see examples of any literature provided by the companies.
Check product labels: buy a tin or pack
of any product when labels are severe violations of the code.
If the information is printed directly on to a tin you could
photograph it for your records or flatten it out and photocopy
it.
In a large supermarket, check the labels
first and then interview an employee if possible. In a small
shop, where you will be noticed immediately, introduce yourself
to the owner and explain that you are researching infant feeding
practices and are interested in the milks on sale in the shop.
Interview the owner first and then check labels on the shelves.
Do not arrive at the busiest times or just as the shop is about
to close.
Monitoring the media and other direct
consumer advertising
Checking the media for advertisements is
easy - look particularly in magazines for parents and also check
publications imported from other countries. Radio and TV may
also broadcast advertisements.
Check to see if any products are advertised
for use before they are nutritionally necessary: e.g. whole milk
powder is sometimes promoted for babies from birth or the early
months, baby foods and drinks are often advertised for use before
the baby is 6 months old.
Looking in relevant trade journals - magazines
aimed at the shops and pharmacies which sell baby products -
may expose violations. Look for information about breastmilk
substitutes or advertisements: they may give details of sales
inducements, tie-in sales, special offers, discounts or competitions
for shop owners and pharmacists.
Other direct advertising can include advertising hoardings (billboards),
direct mail to consumers, displays at public events and baby
shows. Keep an eye out for bottle feeding promotion at all times.
ALWAYS RECORD AS MUCH DETAIL AS POSSIBLE.
Collect information on anything which undermines
breastfeeding even if you are uncertain whether it violates the
International Code and Resolutions.
Reporting your findings
The information you gather will firstly
strengthen your campaign work. If you have specific examples
of malpractice it will demonstrate there is a real problem that
needs to be addressed.
If there is a law or other regulatory framework
implementing the International Code and Resolutions then report
violations to the appropriate body. This may be the Ministry
of Health.
You may wish to complain directly to the
company Chief Executive Officer in your country and its head
office. However, it is the company's responsibility to ensure
that it abides by the International Code and Resolutions. It
may be more appropriate to ask the company to change its policy
so that it no longer allows activities which violate the International
Code and Resolutions. Even so, companies sometimes criticise
monitoring if their violations are brought to the attention of
others without the company being notified first.
IBFAN has mechanisms for recording details
of violations so that international action can be taken (contact
your nearest IBFAN group):
The International Code Documentation Centre
(ICDC) in Penang, Malaysia, is IBFAN's central record library
of violations and should be kept informed of monitoring exercises.
If you think it appropriate you can also
send details to the following groups. Remember to keep copies
yourself and build up your own library.
The Dutch IBFAN group, WEMOS, records violations
by companies manufacturing within the European Union (even when
the products have been exported outside the Union - see the sheet
Reporting Violations Using EU Measures).
Baby Milk Action, the IBFAN group in the
UK, publicises violations through its Campaign for Ethical Marketing
mailings and on the Internet to encourage the general public
to complain to companies.
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