Pakistan’s legislative gap in nutrition

Author: Akhtar Hussain Syed

Pakistan has appalling nutrition statistics and is losing more than 1.229 trillion rupees (2-3% GDP) annually. A significant proportion of the population is unable to meet its dietary needs as nearly 39 percent of people are living in multidimensional poverty. A great many are not able to provide a glass of milk, an apple daily and fruits to every member of the family. As a result, half of Pakistani women and up to 97% of children in major urban areas are suffering from micronutrient deficiencies. Vitamin A, vitamin D, zinc, folic acid and iron deficiency, as well as anemia in Pakistan represent a severe public health problem with significant impacts on morbidity and mortality rates, including more than 50,000 deaths of children younger than 5. The consequences of micronutrient deficiencies include slow physical and cognitive development, worse school performance and decreases in productivity among adults.

The National Nutrition Survey (NNS) of 2011 revealed very high rates of micronutrient deficiencies, 51% of pregnant women are anemic, 37% of non-pregnant women are iron deficient, 46% are deficient in vitamin A, and 69% in vitamin D. The problem repeats itself in children with 62% of under fives suffering from anemia and 54% from vitamin A deficiency. However PDHS 2017-18 shows that 23% of children under 5 are underweight and 38% of children are stunted. The newborn death rate is 42 per 1000 while the childhood death rate is 74 per 1000. Malnourishment also affects cognitive and physical development, ultimately leading to reduced learning abilities and lower productivity in adulthood. Pakistan’s rates of malnutrition are stagnating compared to reductions seen in neighboring countries.

So what to do? How can we provide nutritious food to the public that is affordable and accessible? The answer is food fortification; one of the effective, affordable and safe measures to lower the burden of micronutrient deficiency. Fortification means adding vitamins and minerals to foods like cooking oil and wheat flour at the production stage to prevent nutritional deficiencies. Fortification of edible oil and wheat flour is essential because these products are consumed by the public on a daily basis and are easily available to consumers. This would help in preventing diseases, strengthen immune systems, improve productivity, cognitive development, and increase school performance of the children and reduce economic consequences.

As for as food standards are concerns, fight is ongoing between Pakistan Quality and Standards Control Authority and provincial food authorities on the issue of mandate to formulate standards, as PQSCA claims that it has exclusive right to formulate standards and provinces have to follow them. There is a need to develop a harmonize system for development of the standards which are acceptable to all the parties

So far, a number of initiatives have started to reduce micronutrient deficiencies in Pakistan. After the 18th constitutional amendment (President’s Assent Received on April 19, 2010), food subject was transferred to provinces. Federal laws can be adopted and enacted until the provincial laws are made. After devolution in 2010, provincial nutrition strategies have been developed. Provinces have made some progress by establishing Food Authorities that are responsible for regulating food business and ensuring compliance in their respective provinces. In doing so, Punjab has taken a lead in introducing the Punjab food authority act in 2011. KP government enacted it in 2014. Baluchistan has a food authority act but rules are yet not developed. Balochistan government needs to consider this matter and fix it to regulate food business, food monitoring and the provision of healthy food for the general public. However, the Sindh assembly passed the Sindh food authority act in 2017. These acts provide fundamentals for food authority and their function that includes the licensing of food business, improvement notices, prohibition orders, and notification of food poisoning, food recall procedures, and establishment of food laboratories and also posed penalties to the food businesses that are not meet the obligation of the law. One of the best features of all these acts is involving the consumers’ associations and chamber of commerce as members of food authority groups. Three policy makers from the provincial assembly are also part of the food authority in three provinces except KP.

Food Fortification of edible oil and ghee with vitamin A and D is mandatory, and food authorities are ensuring compliance to standards in all provinces except Baluchistan. Wheat flour fortification is mandatory only in Punjab; the rest of the provinces must act now to make wheat flour fortification mandatory.

To deal with the preparation and sale of foods, a separate legislation is available that is called pure food ordinance. Punjab and Balochistan have had pure food ordinance since 1960, Sindh and KP adopted the West Pakistan pure food ordinance 1960 and all the four provinces have developed rules of the said ordinance. Provincial food authorities are also responsible for ensuring compliance of the ordinance in their respective jurisdictions.

As far as food standards are concerned, the fight is ongoing between Pakistan Quality and Standards Control Authority and provincial food authorities on the issue of the mandate to formulate standards. PQSCA claims that it has the exclusive right to formulate standards and the provinces have to follow them. There is a need to develop a system for the creation of standards which are acceptable to all the parties.

When this subject comes to the federal level, no legislation has been made to establish food authority. However, a federal level nutrition strategy aligned with the Pakistan Vision 2025 has been developed that involves health, education, social protection and civil society actors. To assess the current state of nutrition, the National Nutrition Survey will provide insight data at district level. It would help to reshape our roadmap from the ground up. The federal government has allocated 10 billion rupees for PSDP in 2018-19.

Despite the fact that the federal government is trying to reduce the nutrition crisis, it is still lagging behind the provinces in making fortification mandatory. The Federal government has more responsibility to reduce micronutrient deficiencies as PM Imran Khan has mentioned this matter in his very first speech. It has linked with UN Sustainable Development Goal 2 to “end hunger” where every citizen will have safe food and adequate nutrition. Civil society and policy makers have a vital role to play in introducing legislation to make fortification mandatory through establishing Islamabad food authority in Federal territory.

The author is a development professional based in Islamabad and an expert in policy advocacy focusing on nutrition, tobacco control and consumers rights

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