Menu ENN Search
Language: English Français

Your opinion sought on draft guidance to regulate marketing of Ready to Use Supplemental Foods

This question was posted the Prevention and treatment of moderate acute malnutrition forum area and has 12 replies. You can also reply via email – be sure to leave the subject unchanged.

» Post a reply

Marie McGrath

ENN

Forum moderator

19 Apr 2011, 12:30

Ready to use supplemental foods (RUSFs) are receiving increasing attention by agencies working to alleviate problems of malnutrition. In late 2010, members of the NGO/Civil Society Organisation Constituency of the UNSCN, together with expert contributors, drafted a set of guidelines regarding the regulation of marketing of RUSF targeted at children. Modelled on the International Code for Marketing of Breastmilk Substitutes (BMS), the objective of the draft guidance is to take steps to prevent the unethical marketing that has been widespread for BMS.

The draft guidance is available at http://www.ennonline.net/resources/768

We are sharing the draft guidelines on the en-net forum, for your opinions on the content and need for this draft guidance. Do you agree that such guidance is needed? Is this guidance relevant to emergency contexts? How would you improve on this guidance?

We will summarise substantive en-net postings and discussions in Field Exchange 41.

If you would like to submit a more substantial viewpoint for consideration to print in Field Exchange 41, then send your written article (1000 words maximum) to Marie McGrath, Field Exchange Sub-Editor, marie@ennonline.net

If you would like to submit detailed feedback on the draft guidance for the attention of the working group, then send to Ted Greiner, NGO CSO Constituency Chair, email: tedgreiner@yahoo.com

Mark Myatt

Consultant Epideomiologist

Frequent user

19 Apr 2011, 12:44

It would be nice to have this in PDF or ODT format rather than a proprietary commercial format.

Marie McGrath

ENN

Forum moderator

19 Apr 2011, 14:23

Fair enough. I've created it as a pdf, also available at the same link,
http://www.ennonline.net/resources/768

Best regards
Marie

Marie McGrath

ENN

Forum moderator

20 Apr 2011, 08:30

Dear All,
Below is a cover letter drafted by Ted Greiner & contributors (listed) of the NGO/CSO Constituency of the UNSCN, regarding the Guidelines for the Marketing of Ready to Use Supplemental Foods for Children shared above. This sets out the general consensus of the group regarding RUSF use with reference to the draft guidance.

Introduction

These guidelines have been developed over a period of two years by members of the United Nations System Standing Committee on Nutrition (SCN) NGO/CSO constituency with assistance from others. This process included a series of meetings held on the occasion of the 2009 International Conference on Nutrition in Bangkok

Ready to use supplemental foods (RUSFs) are receiving increasing attention by agencies working to alleviate problems of malnutrition. One reason for this is the fact that water does not need to be added to these foods, reducing their risk of contamination. However, the potential benefit may not be as great as expected. Due to their low water content and high renal solute load, RUSFs actually increase the child's need for safe water compared to diets based on foods cooked with water, where heating automatically eliminates its pathogens.

RUSFs should represent only a small proportion of any child's diet and be used for a relatively short period of time to provide some missing nutrients. Indeed, the very need for RUSFs in a given location should be seen by governments and donors as an indication that nutritious foods are likely to be out of reach of many families, and also that breastfeeding patterns are likely not to be optimal. Thus, in such situations, the provision of RUSFs should not be a stand-alone approach but combined with measures to protect and support breastfeeding, complementary feeding and household food security.

We do not believe that RUSFs for children should be marketed to the general public. Nor do we believe that either these foods or Ready to Use Therapeutic Foods (RUTFs) should be used in programs for prevention, rather than treatment, of malnutrition. However, commercial marketing of these foods is already being studied and discussed by manufacturers and other interested parties. It is therefore necessary to take steps to prevent the unethical marketing that has been widespread for breast milk substitutes. While RUSF may not be intended by manufacturers to replace breastmilk, we know that there are risks of them being marketed and widely used in ways that displace breast milk.

We propose that UN agencies with mandates to generate international normative guidelines to achieve good nutrition and health for infants and children, in particular Codex Alimentarius, continue the process of refining and obtaining widespread agreement on food marketing guidelines.

The following members of the drafting group have consented to the use of their names as supporters of these guidelines: Hanifa Bachou, Geoffrey Cannon, Wenche Barth Eide, Alke Friedrichs, Catherine Geissler, Ted Greiner, Irmgard Jordan, Silvia Kaufmann, George Kent, Peggy Koniz-Booher, Harriet Kuhnlein, Michael Krawinkel, Michael Latham, Irene Lausberg, Pamela Morrison, Chris Mulford, Veronika Scherbaum, Claudio Schuftan, and Carol Williams.

Ted Greiner, Chair
Nongovernmental Organization/Civil Society Organization Constituency
United Nations System Standing Committee on Nutrition
October 27, 2010

massimo serventi

Paediatrician

Normal user

21 Apr 2011, 13:49

I do agree with the statement: RUFT should be used for a short period, in case of an exceptional event. What you write is all correct.I say so after experience of many years working in African and Asian countries.

RUFT risk to become 'dangerous' like the BMS, true.

I'd add a third 'trojan horse' that I've been witnessing in recent years: the introduction in a poor country of new drugs, new molecules, often expensive, sometimes obsolete in Europe, not strictly necessary for the majority of treatments in children. Not only antibiotics, but also antidiarrhoeic like actapulgite,smecta, loperamide,yeast.... liberally prescribed: their introduction make the use of ORS out of fashion, not anymore prescribed by doctors and rejected by the mothers. Cough syrups,anticholic 'waters',antiemetic drugs...all not necessary, but prescribed and bought by mothers. Who are poor and should buy food instead of drugs!
The fatc is that pharmaceutical companies (from Europe,but not only) are on the way to penetrate the market in African countries.They do not find much impediments to do so.... as it happened for the producers of formula milk.
Suffice to get in an ordinary pharmacy (they are many!!) of a town in Africa to see tins of powder milk on the shelves, attractive wallpapers promoting new drugs and remedies that provide 'health and relief'.
I underline the fact that: whenever a new drug is accepted in a country it will be prescribed, soon or later: it is a matter of time. Therefore the barrier should be established at the level of importation.

Marie McGrath

ENN

Forum moderator

21 Apr 2011, 21:50

Dear All
I wish to share with you a document highlighted to us, in response to the draft guidance posted here.

Entitled 'GAIN using the Code to guide marketing of complementary foods working paper no. 3, 2010'.

It is available at: http://www.ennonline.net/resources/769

Thanks to Mary Arimond for highlighting this (iLiNS Project Manager (www.ilins.org)
Program in International and Community Nutrition, University of California, Davis

André BRIEND

Frequent user

22 Apr 2011, 10:09

Dear Marie,

Thanks for sharing these documents. There is a need indeed to make sure that RUSF (= LNS) or any other supplement given during the complementary feeding period (ie after 6 mo) are safely used and do not harm breast feeding.

A short comment. Section 4.2 the document says:

"Information material. should include the financial implications of its use and the fact that the nutrients contained in RUSFs can be obtained from natural foods."

I am afraid this sentence misses the point that LNS are designed to provide at lower cost nutrients missing in poor children diets or those present in absorbable form only in animal foods too expensive for poor families. Studies are currently going on to test whether LNS (and other supplelents such as MN powders) are able to do that, i.e. providing expensive nutrients at lower cost in an effective way. The statement, as it is, assumes that current research will show that these attempts will fail. A more prudent attitude would be to wait until we have more data before having a strong opinion on this. In any case, we should not dismiss in advance efforts which are made to make accessible to children from poor families high quality diet with all needed nutrients at low cost.

I want also to comment a point raised by Ted Greiner and colleague's letter that need qualification.

The letter says:

"Due to their low water content and high renal solute load, RUSFs actually increase the child's need for safe water compared to diets based on foods cooked with water, where heating automatically eliminates its pathogens".

This statement would be true if foods were given to the child shortly after boiling. This does not happen in real life though when families do not have the facility to boil the foods several times a day. And in poor communities, liquid foods are typically more frequently and more heavily contaminated than water even when cooked. For instance in a classical study in rural Bangladesh, contamination of complementary food was about 10 times higher than for water (Black RE, Brown KH, Becker S, Alim AR, Merson MH. Contamination of weaning foods and transmission of enterotoxigenic Escherichia coli diarrhoea in children in rural Bangladesh. Trans R Soc Trop Med Hyg. 1982;76(2):259-64.). Even higher differences (several orders of magnitudes) were reported in another later study (Henry FJ, Patwary Y, Huttly SR, Aziz KM. Bacterial contamination of weaning foods and drinking water in rural Bangladesh. Epidemiol Infect. 1990 Feb;104(1):79-85.).

Food represent the main source of ingested pathogens in poor communities, not contaminated water. See a review of this issue in: Motarjemi Y, Käferstein F, Moy G, Quevedo F. Contaminated weaning food: a major risk factor for diarrhoea and associated malnutrition. Bull World Health Organ. 1993;71(1):79-92.

Wet foods, such as porridges are the main concern, as bacteria need water to grow and grow exponentially in wet infant foods.

I also note that the letter says that the authors believe (sic) that RUSF or similar foods should not be used for prevention. Some evidence presented at the last LNS meeting (which I did not attend, but minutes are now available on the web at http://ilins.org/lns-research-network/lns-research-network/minutes) suggest though that LNS may reduce malnutrition or even mortality is some situations. Arguably, current data have important limitations, their results should be considered carefully, and we can call for more studies before making statements, but I would suggest that decision in this field should be based on data, not on belief.

massimo serventi

Paediatrician

Normal user

22 Apr 2011, 17:47

Dear Dr. Briend, the good quality of RUFT, the effectiveness of RUFT are not in question:they represent the best way to treat or even to prevent SAM, your data suffice.
The question is:
are RUFTs a sustainable, durable, culturally accepted way of treating/preventing SAM?
1) Sustainable? surely not, can we sustain the treatment of 8 million indian children with plumpynut? plus the extra mllions from Africa? how many containers? for how many years?
2) Durable? surely not, what will happen to the child that has been 'rescued' from SAM with RUFT? he will go back to the same family , with the same problems of poverty,lack of food or lack of enough nutritional knowledge.
3) Culturally accepted? certainly not, RUFT are manufactured in France to feed African children. Were African nutritionists involved in the process of 'inventing' such miracle food?
How do the mothers perceive RUFT? something like a drug? coming from 'rich and fat' whitemen? did we ask them what they think of RUFT?

I have no data...but let me question:
the child has become malnourished after a long period of lack of adequate nutrition. Something wrong happened to him, to his family, maybe he has been weaned too early, or left with his granmother or....well, the question is: was the mother informed early enough that her child was on the way to become malnourished? was the mother able to see on the growth card that the curve of her child's growth was deflecting?
In my opinion, SAM should be prevented and all money available should go there...not on manufacturing and shipping containers of RUFT. Parents, african, indian parents, whatever poor they are, should be made responsible for the nutrition of their children, under any circumstance, escept of course in case of severe famine,war or catastrophe.
The only way to inform the mother that SAM is starting to affect her child is to put him on a scale and show to her his position on the card curve. If the body weight is 'bad' she should receive adequate nutrition orientation and requested to come back after 15 days.....to re-check the body weight...and again. The community , the village leaders should be informed that in their amidst there are children with SAM.....most of time they do not know.
Growth monitoring, on monthly basis, for the first 2 years of life. Local food, that is available, culturally accepted. Community involvement.
Breast feeding for 2 years, a must!
Thanks.
Massimo from Bangui

Anonymous 81

Public Health Nutritionist

Normal user

24 Apr 2011, 12:17

Dear Massimo,

I was wondering if you clarify your comments by separating RUSF and RUTF. It seems to me that things are mixed. The discussion is about RUSF (Ready-to-use food) which is totally different from RUTF in terms of purpose. Or are you against both products, RUTF and RUSF?
With regard to growth monitoring, according to the publication of lancet series (Lancet 2008: 371: 510-26), stand-alone growth monitoring has not been proven to have a direct effect on udernutrition.
Thanks


massimo serventi

Paediatrician

Normal user

24 Apr 2011, 21:07

Dear Kiross, I confess to ignore the difference between RUSF and RUFT. Trying to guess....I would agree to use F75 and F100 (how do you call them?) in case of a child affected by severe SAM who is hospitalized. Let's offer to him the last chance to revert a process that has reached the final step, it is ethical. In the past we were used to make DISCO, a mix of dry skimmed milk,oil and sugar, kind of F75/F100 but certainly less balanced.
Plumpynut(PN),energetic buiscuits (how do you call them?)...are my 'enemies'.
I fear that the use of them is becoming too liberal, without control, this being an ' expected event' in the reality of Africa, people are poor, food, any food is welcome,please give one PN for my other child at home.... I do not argue the quality and effectiveness of plumpynut : I'm against its (easy) distribution, that will possibly lead to confusion,dependency and delay in the fight against malnutrition.
I'd like to have the opinion of an African nutritionist.
I remember well : 30 years ago in Tanzania we were used to have children affected by SAM.
Local nutritionists (Prof. Malentlema of TFNC) were strict: no imported food was allowed to treat these children. Emphasis was on MCH/Growth Monitoring, systematically done, every month, in all the 3000 dispensaries/health centres distributed in the country. Affluence to clinics was good and still is.
Situation improved (other factors contributed certainly) : today severe SAM is rare in Tanzania.
I know the articles you mentioned on Growth Monitoring(GM).
I personally conducted sessions of GM and I challenge anybody to deny that they reperesent the best, non medical way to have a contact/interaction with the mothers. No drugs are involved...but a simple measurement of a parameter. Yet mothers are eager to see the growth of their children, oh yes, very much. Do it in a correct way, praise those mothers with 'fat' children, separate those with children 'at risk', talk to them, do not blame, encourage breast feeding and local nutritious food, ask to come back after 15 days,mention the importance of mosquito net, talk about a child with dirty eyes..... this is the real PHC in action. Before leaving the village talk to the leaders, tell them that this and that family has a child with poor nutrition, they will involve the father, they will create awareness.
Malnutrition is a community problem and needs a community answer....said many years ago but still valid today. Mind you : you'll be surprised to hear from them that their children are not malnourished but sick, so they'll ask you more drugs. They may have nutritious food but for some reasons they do not use for children.

Would you call this GM as 'stand alone'? deprived of any additional advantage for the mother? if it so why then Tanzanian mothers do come and want to see the growth of their children?
Mothers are the same in Africa as in Europe, they want to see their children eat and grow.
The health sector has the duty to show the real fact: children are maigre, weak and inappetent because they lack food and not because they are sick.
Give plumpynut and mothers will interpret it as a sort of drug, a special 'buiscuit' of the white man (as mothers in Darfur call PN). Give PN and they will understand that their local food is not good for their children.
PN is unethical. Its liberal, unruled distribution deprives the parents of the Responsibility and Right of feeding their children. Food is not a drug, food is life, food is culture. Respect please.

Claire Bader

Health Advisor SCI Sierra Leone.

Normal user

25 Apr 2011, 08:55

Guidance like this would be useful for locations distributing / using RUSF regardless of the context (emergency or not) if nothing else it would help reduce confusion amongst health care workers at all levels.

Although RUSF at present is still directed towards children and PLW, are there any plans to include some guidance for use amongst Adults with more moderate undernutrition or stable undernutrition?

Ted Greiner

retired Professor of Nutrition

Normal user

9 May 2011, 10:58

I am grateful to ENN for facilitating and am pleased to see this discussion getting started. So far there are many excellent comments.

To begin with, I recognize that there are many products that could be included in such guidelines, including commercial complementary foods, fortified blended foods, and a growing array of ready to eat foods that may eventually expand beyond any definition we choose to include in such marketing guidelines. The present ones were intentionally designed only to cover only RUSFs and cover RUTFs only when they are used OUTSIDE the context of treating SAM. (I greatly doubt that treatment of SAM is something anyone would advertise products for, at least to the general public.)

Here I will respond to the comments from my friend Andre Briend. He makes excellent points.

First, we are indeed uncertain whether some way can be found to provide a few of the more difficult to obtain nutrients at lower cost than from the natural foods they contain. However, it is an even more complex question whether doing so will always provide the same health effects as the natural foods themselves do--for example so far we cannot find any way to provide the cancer-lower effects of vegetables in the diet by supplementing with certain nutrients or other substances in them. Many of us are struck by the impact of milk on infant growth, for example. I doubt we'll find a way to match that with non-milk or at least plant food diets, no matter what nutrients they are fortified with (except perhaps soy formula--which is too expensive). That said, I certainly think that some, such as the fatty acids DHA and EPA, deserve a good deal more research. Some groups may well benefit from supplementation, even in rich countries. (The same is likely true for vitamin D, though perhaps not so much in most low-income populations who get a lot of sun.)

Second, I agree that our language about water should be changed. IF mothers provided cooked foods soon after cooking, they would be safe. But the main point is that RUSFs are being inappropriately promoted as a way to reduce the risks of water-born disease and that is probably, on the whole, not among their benefits. Our main point is that while RUSFs do not spoil or get risk dangerous levels of bacterial contamination like most other foods, that is not the same as saying their use will reduce the child's risk of getting sick from bacterial contamination in his/her environment, as many may assume. (And I agree that Andre, Nutriset and others have not used this as an argument.)

While Andre is correct that food is a much better medium for bacterial growth than plain water, the sad fact is that the more nutritious that food, the more rapid and dangerous is said bacterial growth. Plain gruel with no milk or other animal foods added, the main type of food given to infants, does not become dangerous for quite some time, especially if stored with a lid on, not such a difficult behavior to achieve. These thin gruels are NOT good complementary food for infants. But if replaced by RUSF, the water gruels contain will have to be replaced by drinking water, itself often unsafe, especially for infants. Thus I do not on the whole think that our point about water is misleading.

I personally tend to agree with Andre's point about using RUSFs for preventing malnutrition, but that opinion is not shared by others in the group that produced the guidelines.

More importantly, while Andre agrees that these products must be safely used and not harm breastfeeding, he does not address the other issues that the guidelines are intended to address. Will open commercial sales of RUSFs (as opposed to controlled use by NGOs and other organizations), accompanied by advertising and promotion be beneficial? We know from past experience with other products (including drugs, as Massimo mentions) that the free market will exploit the good will toward these products generated through their use in responsible ways by the development community. At the very least, this can lead to poor people spending too much on them.

Trying to find a way to reduce the risks attendant to commercial promotion of these products to the public in low-income countries is the main purpose of the guidelines. The debatable points rightly raised by Andre can, if necessary, simply be left out of any future marketing guidelines without reducing their importance or effectiveness.

If harmful marketing is simply allowed to happen; if nothing is done to prevent this, then it is only a matter of time until someone documents resulting harm. A polarized situation will result, just as in the case of infant formula companies. Then manufacturers and organizations associated with these products may end up being called the "bad guys" in simplistic media reports. This would be unfortunate and harmful to all concerned.

Thus I would be interested in hearing Nutriset's response to the guidelines (which should be considered separately from the cover letter that ENN published separately). I sent the guidelines for comment to another RUTF manufacturer and they wrote back to me that they found the guidelines to be constructive, well-worded and easy to follow. Their only warning was that not too much information can fit on labels of products that may be sold in quite small amounts. (Other solutions can be found of course.)

Marie McGrath

ENN

Forum moderator

17 Jan 2012, 12:06

The SCN News 39 edition has just been published online and focuses on the topic
'Nutrition and Business: How to engage?' Download at: http://www.unscn.org/files/Publications/SCN_News/SCNNEWS39_10.01_low_def.pdf

It features a range of papers with examples of public-private engagement where interest converged but also examining and presenting insights on the potential risks, challenges and opportunities that such engagement brings. Examples of a number of organisations' engagement frameworks are included.

Linked to the edition, the UNSCN has featured the draft guidance and comments on their website, and invited further contributions from the SCN readership to this forum. Welcome!


Back to top

» Post a reply