Please  tweet  your MP and the following people to ask the UK to support a strong  Resolution next week. Remind them that the protection of breastfeeding and conflict of Interest safeguards are urgently needed for babies everywhere. http://www.babymilkaction.org/archives/17081

Penny Mordaunt   @PennyMordaunt    Secretary of State for  and Minister for .

Jeremy Hunt Health Secretary    @Jeremy_Hunt   jeremyhunt.org

Boris Johnson@BorisJohnson  Secretary of State for Foreign & Commonwealth Affairs.

 

The 71st World Health Assembly (WHA) will take place on  21-26th May and IBFAN and many NGOs and Member States are calling for a new Resolution that will protect infants and young children.

NEW DRAFT RESOLUTION:  Under the leadership of Ecuador, Member States have met three times to discuss a proposed Resolution on infant and young child feeding. The resulting ‘final’ draft will be taken to the Assembly for adoption (21-26th May).  Despite the opposition of some rich producer countries the draft has become stronger (in parts) over time (weaker in some) and includes several important recommendations about marketing and infant feeding in emergencies. Ecuador must be congratulated for managing this very difficult task.  However, there are still several problematic sections and omissions.  Please contact your government (see a few Twitter suggestions above) and ask that they support the adoption of the most child health protective Resolution possible.  

FINAL CONSENSUS TEXT 14 May 2018 – Infant and young child feeding – WH… (002)

Rationale for IYCF resolution 24 April 2018

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Since 1981 (when the International Code of Marketing of Breastmilk Substitutes was adopted) the Assembly has debated infant and young child feeding every two years and adopted 17 or so new Resolutions.  Click Here  It is important that resolutions keep pace with the new marketing tactics, especially those that are fuelling baby feeding products sales.(1) Meanwhile, companies continue to pretend that they are behaving well and should be trusted as partners in nutrition policy setting (2) (3)

The new Draft Resolution highlights the importance of WHO’s  Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children (A69/7 Add.1)  adopted in 2016 includes some important recommendations about sponsorship and marketing. For example it states clearly that all milks marketed for babies 0-36 months function as breastmilk substitutes and should not be promoted and that cross branding should end.The baby feeding industry is now referring to formulas as ‘Nutritional Supplements’  and stretching the infant formula brand name to  children 3 years and older.  see example from Hong Kong below).
Here are some important points that should be highlighted in a new Resolution:
  1. Monitoring and enforcement mechanisms must be free from commercial influence (This safeguard is embedded in the 996 WHA Resolution 49.15 but not specifically highlighted in the new draft.Possible addition: add the following to OP1.3: “…to implement and/or strengthen national monitoring and enforcement mechanisms  that are transparent, independent, and free from commercial influence…”
  2. Policy makers, public sector institutions and all those working in infant and young child feeding need COI safeguards.   The Draft Resolution mentions conflicts of interest three times. However it does so by mentioning WHO documents that appear to be helpful, but also open the door to inappropriate relationships /partnerships with the Private Sector (4).   IBFAN does not believe that they provide adequate safeguards for infants and young children (see below).  The draft Resolution note the WHO tools, but also refers to “noting the ongoing process to develop tools to safeguard against possible conflicts of interest…”  leaving room for strengthening of this document, which is important. 
  3. Baby feeding products should not carry promotional claims (for example convenience claims) This would be safer than forbidding just health and nutrition claims.
  4. There should be no cross-promotion of breastmilk substitutes indirectly via the promotion of any product.  The 2016 Guidance refers to milks 6-36 months. However companies are using cross branding from infant formulas to promote milks for children OVER 3 years, baby foods and formulas for pregnant women (see example above). Possible addition:It would be sensible to catch this loophole in the Resolution. 
  5. Footnote 17 of the Resolution states that Member States can take additional action to end inappropriate promotion of foods for infants and young children.  This is important in relation to trade for countries such as India, that forbids all promotion of all baby feeding products 0-24 months.
  6. The Draft Resolution highlights the revised Operational Guidance on Infant and Young Child Feeding in emergencies  Possible addition: It could also state that appeals for humanitarian aid should stress breastfeeding’s resilience and not undermine it or promote infant and young child feeding products.
  7. The Resolution highlight World Breastfeeding Week. Possible addition: mention IBFAN’s World Breastfeeding Trends Initiative (WBTi).  (IBFAN is hosting a side event on the WBTi at the Assembly on Thursday 24th May.)

Why IBFAN is so concerned about WHO’s redefining of Conflicts of Interest. (Thanks to Lida Lhotska)
A key problem is that WHO has attempted to redefine traditional legal CoI concepts in order to fit the ‘stakeholderisation’ of our public nutrition and health. WHO’s Tools for Safeguarding against possible Conflicts of Interest  in Nutrition Programmes and its Framework for Engagement with Non State Actors (FENSA) both follow the problematic CoI Guidance that was devised for the Scaling Up Nutrition initiative (SUN), as does WHO’s 13th Global Plan of Work. While on a superficial level, all these documents appear to address conflicts of interest, they contain weaknesses that instead promote inappropriate relationships /partnerships with the Private Sector.
One confusing aspect of all these documents is that they keep referring to conflicts being BETWEEN entities – rather than WITHIN a person or an entity. The fact is COI can arise WITHIN people, governments or any institution BECAUSE of inappropriate interactions with the private sector.
Para 44 of the Global Strategy on Infant and Young Child feeding tries to prevent inappropriate interactions by assigning to companies TWO roles and TWO roles only: 1: to make safe products and 2: to comply with the Code and WHA resolutions. Companies could make a positive contribution to child health by focusing on doing these two things well.  We all fall into a trap and make things more problematic when we give them other roles or more responsibilities such as education or breastfeeding promotion.  (CLICK HERE  for one example – Nestlé new Breastfeeding Campaign )
Worse still, when we invite them into policy-making spheres.
So while WHO’s CoI Guidance/tools contain some interesting and important information, they are not adequate safeguards against CoI or other forms of undue influence – safeguards that we need at national level to protect policy making and programme implementation. They may in fact undermine any existing safeguards.  It is not helpful to ask governments to follow a CoI guidance that will not prevent entanglements and instead increases risks of CoI (and institutional corruption) at national level.

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(1) Spotlight on infant formula: coordinated global action needed McFadden, Alison et al. The Lancet , Volume 387 , Issue 10017 , 413 – 415

 The active and aggressive promotion of BMS by their manufacturers and distributors continues to be a substantial global barrier to breastfeeding.6, 7 The reach and influence of the BMS industry is growing fast. The retail value of the industry is projected to reach US$70·6 billion by 2019.4 In many low-income and middle-income countries, growth in sales of BMS exceeds 10% annually.8 Global sales of milk formula (including infant formula and follow-on milks) have increased from a value of about $2 billion in 19879 to about $40 billion in 2013,10 and account for two-thirds of all baby food sales internationally.1

(3) Breaking the Rules, Stretching the Rules 2017 IBFAN-ICDC 11th Global Monitoring Report  
(4)  IBFAN has submitted concerns about WHO’s report (mentioned in the first Para and not yet finalised) Safeguarding against possible conflicts of interest in nutrition programmes and the Framework for Engagement with Non State Actors (FENSA).  
previous drafts