A study on regulatory requirements for food fortification in the Pacific (A report by Dave Clarke, Amelia Carter and Brigid Borlase - Allen & Clarke, Policy and Regulatory Specialists Limited prepared for WHO Western Pacific Regional Office)
Deficiency of micronutrients in national diets is one of the key nutrition-related health problems facing Pacific Island Countries (PICs). Studies of micronutrient status within the Western Pacific Region have found significant instances of iron, vitamin A and/or calcium deficiencies in at least 11 PICs. Fortification is a key strategy in addressing such problems, and so improving population health status.
This report considers the legal, policy and trade issues associated with establishing a sub-regional programme for wheat flour fortification in the Western Pacific. In addition, it offers an overview analysis of non-regulatory policy strategies (such as nutrition-related policies and monitoring of nutrition status) which can support a regulatory programme for food fortification.
General principles of food fortification are recognized internationally. Incorporating these into domestic law requires a clear understanding of the nutrition problem involved, so that a sustainable, enforceable, and technically sound programme can be implemented to best meet the needs involved. Systems for enforcement and monitoring will form part of such a programme, but best practice also requires that fortification forms part of a broader strategy for addressing micronutrient deficiencies. Such a strategy will include non-regulatory mechanisms, and must involve participants from the public and private sectors, and from the wider community.
While fortified flour, and foods manufactured from fortified flour, are available throughout the Pacific, only Fiji operates a systematic fortification policy. Thus, although there may be haphazard health benefits from the spread of fortified products in the region, PICs should adopt deliberate and mandatory fortification regulations, operating on the basis of a regional fortification standard. Since many PICs face similar nutritional issues, and since most will require resource assistance in implementing and monitoring food fortification regulations, a regional approach, supported by international organizations, best meets the health needs of the region. For this purpose, Fiji’s Food Safety legislation offers a useful template for how regional fortification standards could be incorporated into domestic law. Work in this direction should be aligned with current WHO/FAO work to establish regional food standards for the Pacific.
A regional approach to food fortification would enable PICs to face trade issues with confidence, with only a slight risk of successful challenge to a fortification programme on trade grounds.
We recommend that:
· WHO should help establish and maintain a regional fortification standard that addresses the key micronutrient deficiencies in the Western Pacific region.
· Where appropriate, individual Pacific Island countries should be encouraged and assisted to incorporate the regional fortification standard into their domestic law.
· Linkages should be built to integrate the WHO/FAO-sponsored food standards project and the present WHO work on fortification.
· Individual Pacific countries be assisted to strengthen and/or share their existing food control structures, including their personnel, and inspection and laboratory services.
· WHO sponsor ongoing nutritional surveys in the region to monitor and evaluate the fortification programme, and then align the fortification standard with the results of the surveys. Such surveys should be integrated as appropriate to other data collection exercises.
· WHO continue to assist countries to create a non-regulatory environment that supports public health initiatives, expanding to include support for fortification. As appropriate to local conditions, this will include such things as assisting with education, technical assistance, design of National Plan of Actions on Nutrition (NPAN), establishing nutrition committees, forming links to other health programmes, collaborating with industry and international groups, etc.
· WHO assess whether the STEPs survey instrument would provide a useful means of monitoring the effectiveness of food fortification programmes in the region.