WPHNA World Public Health Nutrition Association

Our editorial was unfair and inaccurate

Sir: Your May editorial. (Anon. ‘Marketing food products to children: Are the UN agencies helpless?’) contains inaccurate statements on both process and fact in relation to the World Health Organization (WHO), the development within WHO of a set of recommendations on Marketing of Foods and Non-Alcoholic Beverages to Children, and on the UN Standing Committee on Nutrition (SCN).

The WHO rules and processes

First, Dr Corinna Hawkes was appointed by the WHO Director-General as a member of the ad-hoc expert group on Marketing of Food and Non-Alcoholic Beverages to Children. Dr Hawkes was not appointed Chair by the WHO Director-General. Rather, she was elected by the other members of the group to chair the meeting, held in Geneva in December 2008. As is stipulated in the basic documents of WHO, the Director-General has discretion to disband an ad-hoc expert group, and this was done on 1 November 2009 following the completion of the work of the group.

Second, again as is stipulated in the basic documents of WHO, an expert group reports to the Director-General, and is established to provide advice to WHO only. In this case, the report prepared by the group was used by the WHO secretariat, in combination with other evidence and information (see below), to develop a working paper. The resultant working paper informed consultations on the issue. WHO Member States provided their views, comments and concerns to the secretariat. The input provided by Member States was the basis for the formulation of the recommendations.

How recommendations are formulated

Third, the WHO secretariat conducted an extensive series of dialogues, as mandated by the World Health Assembly’s Resolution WHA60.23. These included the private sector and a wide variety of nongovernmental organisations. The NGOs included some in official relations with WHO, and others that, while not in official relations, were deemed to have a particular interest or expertise in the topic.

Fourth, the draft set of recommendations presented to the Executive Board of WHO in January 2010 were developed by the secretariat after considering:
the report which the ad-hoc expert group submitted to the Director-General, also the consultations at regional and national levels carried out on the working paper, and also the dialogues conducted with the NGOs and the private sector.

The draft recommendations were discussed by the WHO Executive Board at its 126th session and were passed, with some changes, to the 63rd World Health Assembly which took place this May.

The report of the ad-hoc expert group is unfortunately cited as a reference in your editorial. As indicated above, this report was not the only source of information used to formulate the recommendations. As mandated by the WHA resolution, the recommendations were formulated in collaboration with Member States and in consultation with other stakeholders.

Yes, governments should lead

The draft recommendations presented to the 2010 World Health Assembly have been misrepresented in the editorial in relation to the role of government. The editorial inaccurately states that the recommendations ‘omit the point that government should make policy’. The central role of government is emphasised in recommendation 4. This states: ‘Governments should set clear definitions for the key components of the policy, thereby allowing for a standard implementation process’. The role of government is further emphasised in recommendation 6. This states: ‘Governments should be the key stakeholders in the development of policy and provide leadership, through a multi-stakeholder platform, for implementation, monitoring and evaluation’.

Further, recommendation 3 gives the opportunity to Member States to use either statutory or other formal regulation or co-regulation (which could include monitoring and enforcement). This is reinforced in recommendation 10, which states: ‘All policy frameworks should include a monitoring system to ensure compliance with the objectives set out in the national policy, using clearly defined indicators’. Further, recommendation 11 states: ‘The policy frameworks should also include a system to evaluate the impact and effectiveness of the policy on the overall aim, using clearly defined indicators’. The WHO secretariat and the Member States defined the importance of monitoring in paragraphs 26 to 34 of the recommendations, which is inconsistent with the editorial's assertion that they are ‘rather vague about mechanisms for audit’.

All the recommendations were discussed by the World Health Assembly and were supported on 21 May 2010. Many Member States and nongovernmental
organisations commended the Secretariat for the comprehensive and
multi-stakeholder consultation process through which the recommendations were developed. The resolution on the recommendations was unanimously passed by Member States.

The UNSCN and industry

Your editorial indicates that ‘The UN Standing Committee on Nutrition, set up to strengthen and harmonise joint UN policies and programmes, is currently out of funds, and its governing body proposes to admit industry – which in practice means transnational food and drink processors – as full partners’.

The SCN Steering Committee has not made a proposition to admit industry
as full partners. There has been a public discussion, still ongoing, on whether and how to engage with the private sector. Currently the SCN is under reform and is aiming at a structure that will ensure full dialogue with all constituencies while retaining its original function of a UN coordination mechanism.

Finally, your editorial states that ‘From the point of view of protection of child health there are a number of reasons not to be cheerful about what will happen this month at the World Health Assembly’. I argue to the contrary, and invite you and your readers to look at the resolutions on the Marketing of Foods and Non-alcoholic Beverages to Children, and on Infant and Young Child Nutrition, which were unanimously endorsed by Member States at the 2010 World Health Assembly.

Ala Alwan
Assistant Director-General
Noncommunicable Diseases and Mental Health
World Health Organization.
Geneva 27, Switzerland
Email: alwana@who.int

Please cite as: Alwan A. Your editorial was unfair and inaccurate. [Letter] World Nutrition, July 2010, 1, 3: 174-177. Obtainable at www.wphna.org

Editor’s note. Dr Alwan’s letter arrived too late to include in our June issue. This contains a letter from Alexander Müller, chair of the UNSCN, which also points out that the SCN steering committee has not yet made a decision on the relationship between the SCN and ‘the private sector’ – which unfortunately in practice so far has meant transnational food and drink manufacturers and allied industries whose interests are in direct conflict with those of public health. We accept that our editorial understated the role of national governments in implementing the recommendations on marketing of food products to children, which are now accepted by member states, and published within our June news story. We think that not making the ad hoc expert group’s report available on the WHO website was an error of judgement. We accept Dr Alwan’s main points. The information we had at the time our editorial was written did indeed incline us to pessimism, whereas the outcome justifies considerable optimism. Our news story, published in the June issue of our website, salutes the WHO secretariat in this area headed by Dr Alwan for their outstanding diplomatic work and for the positive results achieved at the WHO WHA in May. We trust this has made amends.