Comments re: Interim Report. General Comments:
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- Maria Manning
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1 Comments re: Interim Report General Comments: 1. Countries differ in their capacities in engaging the private sector and at the same time safeguarding public health from conflicts of interest. In addition, countries have also varying degrees of capacities in putting in place policies and regulations, ensuring compliance and imposing sanctions when needed. These countries have to be capacitated and technical assistance provided. The Philippines respectfully requests that it be included in the roster of countries to be prioritized for technical assistance. 2. The recommendations and the facts and arguments in the interim report are very valid, we have experienced a lot of them in our pursuit for effective nutrition interventions to address NCDs. Following are some of our experiences: The Philippines tried to engage the private sector particularly the professional organizations of physicians, nutritionists-dieticians, researchers, academe and some food manufacturers to advocate for two things: 1) to encourage the food manufacturers to reformulate their products to comply with the Codex Alimentarius standards for salt, sugar and fat and WHO recommendations; 2) to agree on the front-of-pack labels for processed foods as a tool for informing the public on healthier food choices. The Result: The food manufacturers do not want to reformulate their products and do not want the DOH and NDAP s proposal on the wise eat seal to be awarded to food products that comply to our standards because they are afraid that their products will be labeled healthy or unhealthy, thus, sales or profit may be reduced. Some of the professional organizations that joined the DOH have conflict-of-interest because they have current partnerships or engagement with the food manufacturers and therefore cannot fully support the advocacy of DOH. The food manufacturers managed to push for an FDA Circular on voluntary front-of-pack label bearing only the number of calories in a barrel type label using black font with the promise that eventually they will also put front-of-pack labels for sugar, salt and fat on a voluntary basis. This is an indication that the food manufacturers do not want government regulation and have worked for self-regulation. Our regulatory and statutory bodies have yet to use regulation as a tool for improving the nutrition of the Filipino populace. At the time we are working on the front-of-pack labeling, the back labels are still voluntary and last year the FDA issued an Administrative Order requiring mandatory food labels to all food products, but is yet to be implemented. The barrel type of front-of-pack labels is a region-wide (Asia) move of food manufacturers so they will have consistent labels throughout the region. In this case, the advocacy for a more effective front-of-pack happening in more developed countries should also be advocated in low and middle income countries as part of a global advocacy.
2 3. For salt reduction The salt reduction efforts in the country still need to be leveled up to have bigger impact. We have not yet reached the level of Korea where they have a campaign to switch from noodles to rice and to reduce the serving portion sizes of noodles to reduce salt consumption. Ours is more on education and giving guidelines for reduced salt consumption. We also tried to include in the Food Safety Law Implementing Rules and Regulations the labeling at least, of fast food products with regard to calories, salt, sugar and fat. However, FDA does not want to take on the responsibility of regulating the fast foods claiming that they do not have jurisdiction over them but the Local Government Units. So, we settled to put in the guidelines a phrase saying that the DOH and the FDA shall issue guidelines on how the Local Government Units will regulate the fast foods and other food institutions like the cafeteria and restaurants 4. For legislations We have a pending bill on the taxation of sugar sweetened beverages and banning of selling soda in schools. Our problem is the lack of local studies to link sugar with obesity. Existing studies are from other countries and the argument always is, it might be different in the Philippines. We also lack the expertise and skill for legislative advocacy. We also have to consider the conflict-of- interest among legislators who may have engagement or projects being sponsored by the food manufacturers..
3 Interim Report WHO Global Coordination Mechanisms on NCDs Areas in which commitment has been made: 1. Reduce the impact of the marketing of unhealthy foods and nonalcoholic beverages to children 2. Reformulating products to provide healthier options (nutrition facts and labeling standards) 3. Promote and create an enabling environment for healthy behaviors among workers (tobacco-free workplaces, safe and health working environments) 4. Reducing the use of salt in the food industry in order to lower sodium consumption 5. Improve access to and affordability of medicines and technologies As far as the recommendations and actions are concerned, may we share what the Philippines has done as a concrete example of how and what one country is taking forward the recommendations. And from the experience, it is clear that engaging the private sector is full of challenges and need to be balanced with broader considerations of trade, economics and investments. Recommendations Heads of State and Government should clarify the role of the private sector in strengthening its contribution to the implementation of national NCD responses Philippine situation The Department of Health in collaboration with the World Health Organization and University of the Philippines College of Public Health has developed The Philippine Multisectoral Action Plan for the Prevention and Control of Non Communicable Diseases (PhilMAP NCD) The key strategy is the multisectoral action uniting the efforts from the different sectors of the society towards the attainment of the goal.
4 Significant efforts are required from Heads of State and Government to establish sound national regulatory frameworks for the shift towards concrete contributions from the private sector to national NCD responses PhilMAP NCD VISION: A Philippines free of the preventable burden of NCDs MISSION: Health in All, Health by All, Health for All GOAL: 25% relative reduction on premature mortality from NCDs (CVD, Cancer, Diabetes Mellitus, CRDs) by 2025 Intermediate Targets The intermediate targets refer to the metabolic risk factors high blood pressure, high blood glucose and overweight and obesity which will be addressed through the different activities and eventually lead to the reduction of premature morbidity and mortality from NCDs primarily the top four NCDs namely CVDs, cancer, diabetes mellitus and CRDs. Primary Targets The primary targets are the behavioral modifiable risk factors namely tobacco use, physical inactivity, harmful alcohol use and unhealthy diet which are targeted to attain the goal of 25% relative reduction in the prevalence of premature morbidity and mortality from NCDs. Thrusts PREVENTION, which aims to reduce the level of exposure of individuals and populations to the common risk factors for NCD namely tobacco, unhealthy diet, physical inactivity, harmful alcohol use and their determinants; SURVEILLANCE, which aims to map out the emerging epidemics of NCDs and to analyze their social, economic, behavioral and political dimensions; and MANAGEMENT, which aims to strengthen the health care delivery system and provide an enabling environment for people with NCDs by developing norms and guidelines for cost-effective interventions. The focus of management shall be the enhancement of capacity building and service delivery.
5 Governments should develop a robust national mechanism to review implementation of the contributions from the private sector to national NCD responses; this mechanism will be essential for implementing national NCD responses and attaining the NCDrelated targets included in the SDGs To shift towards concrete contributions from the private sector to national NCD responses, countries need to share knowledge and data. Also, developed countries need to respond to requests from developing countries to provide them with technical assistance to build national capacities PhilMAP NCD Monitoring and Evaluation In monitoring the progress of NCD prevention and control, indicators will be used to track the improvement of health status of the country and ultimately, the attainment of the objectives of the PhilMAP-NCD. Intermediate Objectives: 25% relative reduction in the prevalence of high blood pressure 0% increase in the prevalence of high blood glucose 0% increase in the prevalence of overweight and obesity among adults 0% increase in the prevalence of high total cholesterol among adults Primary Objectives: 30% relative reduction in the prevalence of current tobacco use among adults 30% relative reduction in the prevalence of current tobacco use among adolescents 30% relative reduction in the prevalence of secondhand smoke exposure 10% relative reduction in the prevalence of binge drinking among adolescents and adults 30% relative reduction in salt/sodium intake 20% increase in the daily mean vegetable and fruit intake 10% relative increase in the prevalence of sufficient physical activity among adults and adolescents DOH Information Systems Strategic Plan (ISSP) for , utilizing ehealth (information and communication technologies (ICT) employed in health) Unified Health Management Information System (UHMIS) which seeks to integrate all DOH information databases and store them in a Central Database Warehouse. Integrated Chronic Non-Communicable Disease Registry System (ICNCDRS) ; a composite index of 5 registries those of cancer, stroke, diabetes, COPD and renal disease.
6 Heads of State and Government must protect their national public health policies for the prevention and control of NCDs from undue influence by any form of vested interest. Real, perceived or potential conflicts of interest must be acknowledged and managed DOH policies AO No.89-A s,1990 or The Philippine Cancer Control Program AO No. 16-A s or The Diabetes Mellitus Prevention and Control Program in the Philippines AO No. 122s, 2003 or A Smoking Cessation Program to support the National Tobacco Control and Healthy Lifestyle Program AO No or The National policy on Strengthening the Prevention and Control of Chronic Lifestyle Related Noncommunicable Diseases AO No or The Implementing Guidelines on the Institutionalization of Philippine Package of Essential NCD Interventions (PhilPEN) on the Integrated Management of Hypertension and Diabetes for Primary Health Care Facilities AO No or The National Policy on the Unified Registry Systems of the Department of Health (Chronic Noncommunicable Diseases, Injury Related Cases, Persons with Disabilities, and Violence Against Women and Children Registry Systems) LEGISLATIONS Sin Tax Law The Graphic Health Warning Law Senate and Congress: SB 3489: Healthy Workforce Act of 2009 SB 3526: Meat Additive Disclosure Act of 2009 SB 3552: Health Empowerment Zone Act of 2009 SB 3558: Food Product Standard Description Act of 2009 HB 4269: Healthy Beverage Options Act HB 3445: Brown Rice Act of 2013 HB 1334: The Diabetic Act of 2013 HB 572: Bicycle Parking Law of the Philippines HB 3365: An Act Imposing a 10% Ad Valorem Tax on softdrinks and Carbonated drinks by inserting a new section in the national internal code, as amended HB 4737: An Act Providing for the Control of Alcoholism, prescribing penalties for violation thereof and appropriating funds therefor
7 Governments (as the key stakeholders in the development of policy) should provide leadership through establishing a multi-stakeholder platform for implementation, monitoring and evaluation that involves all relevant stakeholders Governments should ensure that multi-national industry pledges are applied consistently across the world, not just in highincome countries, and are tailored for local relevance DOH The Philippine Multisectoral Action Plan for the Prevention and Control of Non Communicable Diseases (PhilMAP NCD) LIST OF STAKEHOLDERS A. GOVERNMENT Civil Service Commission Commission on Higher Education Department of Agriculture Department of Education Department of Environment and Natural Resources Department of Finance Department of Interior and Local Government Department of Labor and Employment Department of Public Works and Highways Department of Trade and Industry Food and Nutrition Research Institute Department of Science and Technology League of Provinces of the Philippines Metropolitan Manila development Authority National Economic Development Authority Philippine Council for Health research and Development Philippine Health Insurance Company Philippine Information Agency Philippine Statistics Authority B. NON-GOVERNMENT/PRIVATE/PROFESSIONAL SECTOR Diabetes Philippines Employers Confederation of the Philippines Framework Convention on Tobacco Control Alliance, Philippines Kapisanan ng mga Brodkaster ng Pilipinas Movie and Television Review and Classification Board Philippine Association for National Advertisers Philippine Cancer Society Philippine Chamber of Food Manufacturers, Inc. Philippine Heart Association World Bank World Health Organization
8 Governments should ensure: The availability of appropriate health promotion and education of the public, private sector and politicians, to improve understanding of the harms of products high in salt, sugar and fats; and That messages are consistent, coherent, simple and clear (e.g. with respect to the harms of high salt intake) Governments should reaffirm that the private sector can be a significant player in producing and promoting more food products consistent with a healthy diet, and could partner with governments and NGOs in implementing national NCD responses Governments are encouraged to consult with stakeholders on policy from the outset Governments should consider market incentives (e.g. price incentives), to ensure greater availability and affordability of food products that contribute to a healthy diet, including in important settings for health promotion, such as public institutions DOH Health Promotion, education and advocacy through the Belly Gud for Health Control of modifiable risk factors for NCD through Pilipinas Go 4 Health National Nutrition Council Philippine Plan of Action for Nutrition (PPAN) Barangay Nutrition Scholar Promoting Good Nutrition Annual celebration of Nutrition Month Radyo Mo sa Nutrisyon Workplace health promotion Hakbang Para sa Tamang Timbang
9 Governments should require and incentivize the private sector to implement accurate, standardized, comprehensible and readable front-of-pack labeling that provides information on the content of food items, needed for making healthy choices DOH Healthy Canteen Certification Program Pinggan ng Kalusugan (Healthy Plate) Voluntary Healthy Food Certification Program AO No. 88-B s 1984 or the Rules and Regulations Governing the Labeling of Prepackaged Food Products Distributed in the Philippines FDA Circular No of the Guidelines on Voluntary Declaration of the Front of Pack Labeling (Energy or Calorie Content) on the Labels of Processed Food Products Governments can show leadership by including salt reduction programmes for processed and restaurant foods as part of an overall strategy to promote initiatives by the food industry to reduce the fat, sugar and salt content of processed foods and portion sizes. Initiatives could consider additional measures to encourage the reduction of salt content of processed foods by setting clear targets on product reformulation, public awareness raising and education, and monitoring and reporting DOH Policy for the Unhealthy Diet as a risk factor for NCD is under development Governments should engage with the food industry to elicit meaningful commitments aligned with national public health goals to reduce the use of salt in processed foods; specific timelines for such commitments should be agreed
10 Governments should recognize and deliver on existing international obligations to protect workers health in workplaces, and implement a strong regulatory framework to support this. Governments should also consider establishing an international alliance to synergize global workplace health efforts, and support greater coherence for national workplace health initiatives Department of Labor and Employment Department Circular No. 1 08: Policy Guidelines Governing the Occupational Safety and Health (OSH) of Workers in the Call Center Industry Promoting Company Values and Healthy Lifestyle in the BPO industry Smoke-free Workplace Policy Alcohol-Free Workplace Policy Governments should stimulate the development of comprehensive workplace health programmes in the private sector by providing regulatory and financial incentives, to give people the opportunity to make healthy choices in the workplace. This will help to reduce employees exposure to risk, and help to facilitate social marketing, monitoring, dissemination of information and innovations, and exchange of experience
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