Dr Francesco Branca
Director Nutrition and Food Safety
World Health Organization
Avenue Appia 20
1211 Geneva 27
21st October 2022
Concerns about the WHO Global Food Safety Strategy
We note that the Global Strategy for Food Safety says that: “Unsafe food disproportionately affects vulnerable groups in society, particularly infants, young children, the elderly and immunocompromised people.” However, despite many requests and submissions by IBFAN, the Strategy makes no mention of breastfeeding at all.
WHO, more than any other agency is aware of that human milk is the safest first food for children and that breastfeeding is resilient, provides food, care and immune support and prevents malnutrition in ALL its forms. WHO also knows that babies are at greatest risk of water-borne diseases, with diarrhoeal disease the second biggest killer of under-fives. As climate-related emergencies increase, water scarcity and contamination are inevitably exacerbated. Breastfeeding in these circumstances is the only lifeline for infants and young children.
WHO has only this year published important exposés of the predatory marketing that continues to undermine breastfeeding and fuel the growth of the global market for all manner of ultra-processed products targeting infants and young children. So, we find this omission astonishing and hard to understand.
Amongst the many problems and good sections in the Strategy we note that:
To make matters worse, during the launch on Monday, in response to our questions, the WHO representative, Dr Simone Moraes Raszl, referred only to the risk of micro-toxins in breastmilk, perhaps not aware that such messages, out of context, might actually undermine breastfeeding. To mention residues measured in breastmilk as a food safety concern and not as an environmental health problem for all, is inconsistent with the work of WHO’s Nutrition Department, that is struggling to protect breastfeeding.
We note that Danone’s Food Safety Director, Angelika Tritscher, joined the call and asked questions about Private Sector involvement. She was referred to as a former WHO colleague but no-one identified her as being from Danone. Aware of the 2019 announcement that Danone and FAO were ‘teaming up’ you can understand why our concerns about the Strategy and its impact are increasing.
This said, we are pleased to see that the Strategy contains several references to Conflicts of Interest, for example, “There should also be mechanisms in place to safeguard the decision-making from potential conflicts of interest that could put corporate interests over public health.”
However, this essential principle is not embedded throughout the Strategic Objectives, and is amongst text that promotes ‘multi-stakeholder platforms’, ‘goals that are mutually reinforcing’ and other ambiguous terms, that leave the door wide open for exploitation by health-harming corporations and their front organisations. We stress the need for a more robust approach to Conflict of Interest safeguards, perhaps citing OECD tools to avoid and manage conflicts of interests and including food safety risk communications and education.
We recognise the need for commercial companies to take Food Safety more seriously during production, handling and marketing and that the Strategy aims to achieve this. However, it is inappropriate for them to fund or influence nutrition or food safety systems. The Strategy should help governments resist such support by devising robust devise robust and independent national surveillance systems and laws that can hold companies accountable for any harm they may cause.
As mentioned before, IBFAN appreciates the many WHO texts that specifically refer to Conflicts of Interest in relation to infant and young child feeding. However, WHO’s inconsistency and ambiguity in other areas of health, for example its co-sponsorship of the World Health Summit, its work on Universal Health Coverage and NCDs, must be problematic for health and safety planners. It demonstrates a lack of policy coherence between WHO Departments. The only clear prohibition for engagement, cited in WHO’s Framework for Engagement with Non State Actors (FENSA) is with manufacturers of tobacco or arms. There are reports from countries of food policy development being done in collaboration with the food industry as ‘stakeholders’. If the Strategy was clearer it would be easier for countries to stop minimise such influence.
We do not know if there will be any opportunities for further changes, but given the crises the world is facing, and as a long established NGO in Official Relations with WHO who is ready to disseminate the document, we strongly advocate that amendments are made. In terms of the much-needed protection for breastfeeding and optimal infant and young child feeding, left as it is the Strategy is a lost opportunity and potential risk and, as mentioned before, highly inconsistent with the work of other parts of the Nutrition and Food Safety Department.
With very best wishes as always
IBFAN Global Council:
Nomajoni Ntombela, Co Chair
Marcos Arana, Co-Chair
Alison Linnecar, Convenor, IBFAN global working group on Environment Climate and Health
Maryse Arendt, BLL-IBFAN Luxembourg
Dr Tedros Ghebreyesus, Director General, WHO
Dr Naoko Yamamoto, Assistant Director General, ADG UHC and Healthier Populations, WHO
QU Dongyu, Director-Gneral Food and Agriculture Organisation