[Ip-health] joint letter on Proposed Amendments to Rules Governing NSA Interaction (EB146/33)

Jaume Vidal jaume at haiweb.org
Mon Feb 3 08:56:39 PST 2020

Dear all,
Find below a letter that Health Action International (HAI), together with organizations from a diverse and  geographical range, is sending to WHO DG in connection with the discussion during the EB146 of the document EB146/33 containing a set of proposals to amend the current rules of engagement of Non-State Actors in WHO governing bodies. We express our concern and hope that a proper consultation is organized in order to guarantee participation and inclusiveness in global health governance.
Thanks to those who contributed, those who signed and those who could not due a too short deadline.

Here is the link if you want to help spread the word

Dr. Tedros Adhanom Ghebreyesus

cc: Dr Hiroki Nakatani, Chairman of the Executive Board
Dear Dr. Tedros,
RE: Proposed Amendments to Rules Governing NSA Interaction (EB146/33)

There are serious repercussions for the effectiveness and legitimacy of World Health Organization (WHO) meetings in the attached proposals to amend the rules on non-State Actor (NSA) interactions with governing bodies (EB146/33). The changes will curtail the mandated contribution that civil society makes to governing bodies, technical briefings and all other WHO forums.

As representatives of eight civil society organisations, we have the following specific concerns regarding the proposed changes:

In the case of governing bodies, while we acknowledge that the current model of NSA participation is insufficient and is not inclusive and democratic, it is hard to see how the suggested changes would improve overall inclusion of legitimate stakeholders in global health.

The proposal to divide NSAs into three different constituencies seems both impractical and difficult to implement. Some NSAs, such as Product Development Partnerships (PDP), would be compelled to identify with only one part of their mission. Non-governmental organisations would be competing amongst each other in a crowded space, and only the largest and most vocal NGOs would be heard. Meanwhile, according to the proposition, industry and philanthropic foundations, who enjoy a far less densely occupied space, receive a supremely generous proportion of time allocation. We would like to know on what evidence this time allocation is made. Overall, constituency intervention will return the World Health Assembly (WHA) to a silo mentality, which had been successfully replaced by a fluid collaboration and cooperation between stakeholders. It is crucial for the attainment of SDG 3, that stakeholder voices are diverse, included and heard.

Re-structuring NSA interventions at WHA governing bodies by constituency, and allowing only three interventions per legitimate organisation, not only limits the richness of debate, but introduces competition for limited space. This would be prejudicial to organisations from low- and middle-income countries, for which coming to Geneva for meetings is already logistically challenging. At a time when those voices are needed more than ever, this kind of marginalisation is unacceptable.

We agree there is a clear and present need for reform of NSA participation within the framework of WHO work in global health. Reform should serve the purpose of streamlining meetings but cannot ever be at the expense of transparency and NSA engagement. Under no circumstances should changes in the rules of engagement result in a reduction of meaningful contributions from stakeholders. Discussions and approval of the milestone resolution on transparency at the 72nd WHA are examples of civil society collaboration with Member States to reach consensus on a complicated and sensitive issue.

While we commend the secretariat for their consideration of the issue, EB146/33 does not offer a solution to the perceived problems inherent in the existing arrangement, which, as stated above, we agree requires amendment. Change is necessary, not because the existing arrangement is time consuming and cumbersome, but because it is undemocratic and does not engender meaningful participation of stakeholders. As a result, change must acknowledge the unique contribution that civil society brings to global health and accommodate their views. The goal must be to encourage interaction that stimulates fruitful dialogue on shared objectives for the improvement of global health, not because of time limitation.

We call on WHO to organise a technical briefing before any actions or pilot strategies are introduced—either before or during the next WHA—to discuss the issue with those most affected in consultation with NSA. We ask the EB146 to endorse this proposition.

We appreciate your due consideration of this matter and eagerly await your response.

Yours sincerely,
Health Action International
Just Treatment
Access treatment Group
Health Gap
International Treatment Preparedness Campaign  Latin American and Caribbean Networks (ITPC LATCA)
Public Eye
Salud por Derecho
​Cancer Alliance
Fundación Ifarma

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