This document summarizes efforts to revise wheat flour fortification standards in Indonesia to be more aligned with WHO guidelines and ensure implementation of the revised standards. It discusses how the revision process occurred from 2016-2018 with advocacy and studies. It then outlines the objectives and methods used by Nutrition International to support the Indonesian government in implementing the revised standards, including technical assistance, training, monitoring, and ensuring adequate premix supply. Results included the revised standard being reinstated in 2021, training of millers and inspectors, and adequate fortified wheat flour reaching 41 million additional people. Ongoing support is needed for enforcement, monitoring, industry support, and addressing anemia.
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Revision of the wheat flour fortification standard in Indonesia and disruption in its implementation due to COVID-19
1. DELIVERING FOR NUTRITION IN SOUTH ASIA
Implementation Research in the Context of COVID-19
2nd December 2021
Rozy Afrial Jafar
Nutrition International
Revision of the wheat flour fortification
standard in Indonesia and disruption in
its implementation due to COVID-19
2. • 22.7% adolescent girls, 16.6% adolescent boys and 48.9% pregnant mothers are anemic (1)
• Food fortification:
• Safe, cost-effective nutrition intervention,
• Demonstrated health, economic and social benefits (2, 3, 4),
• Vital intervention before, during, and after COVID-19 pandemic in low- and middle-income
countries (3)
• Wheat flour fortification (WFF)
• Mandatory since 2002,
• Electrolytic iron (low bio-availability) was used earlier,
• In 2016, Nutrition International (NI), GAIN, UNICEF and FFI advocated with the
Government of Indonesia (GoI) to align the Indonesian National Standard (SNI) with the
WHO guidelines,
• Revised standard (SNI 3751:2018) mandates the use of more bioavailable iron, viz.
ferrous fumarate or ferrous suphate or NaFeEDTA
Rationale
1. Prof Endang L. Achadi, Advocacy Workshop on National IFA Supplementation Program During Covid-19 Pandemic. NI Zoom Webinar, 20 Oct2020
2. Save Lives — Food Fortification Initiative (ffinetwork.org)
3. Olson, R., Gavin-Smith, B., Ferraboschi, C. and Kraemer, K., 2021. Food Fortification: The Advantages, Disadvantages and Lessons from Sight and Life Programs. Nutrients, 13(4), p.1118.
3. Objectives
Broad objective:
Support the GoI to undertake WFF following revised SNI in alignment with WHO recommendation
Specific objectives:
Provide technical assistance (TA) to GoI in legislation process for issuing the revised SNI
Train/ build capacity of wheat flour millers
Provide TA to develop capacity of government monitoring agencies
Ensure production of adequately fortified wheat flour
4. Methods/ Analysis
•Mandatory
fortification
started using
electrolytic iron
2002
•NI coordinates
stakeholder
meeting with
Ministry of
Health (MoH)
2016
•Expert
meetings
•Organoleptic
study conducted
2017
•Revised SNI
released
•Risk assessment
analysis conducted
2018
•Protocol to
identify the type
of iron
developed
2019
•Revised SNI
suspended from
April-December
2020
•Revised SNI
reinstated
•Effective
implementation
started w.e.f.
September
2021
5. Methods/ Analysis (Contd.)
Technical
assistance
Regulatory impact analysis
on implementation of SNI
3751:2018
NI provided support to MoI
in developing technical
guidelines
Training/ Capacity
building
Developed an audio-visual training
aid in 2020, an audio-visual training
aid
(Training Module: Testing fortified
wheat flour – YouTube)
Training conducted for government
inspection agency and lab
personnel in 2021
Virtual capacity building of
government monitoring inspectors,
laboratory personnel and millers on
quality assurance (QA) and quality
control (QC)
Monitoring
NI developed strong QA/QC
protocols. This protocol is in
use to support government
departments in setting up
monitoring protocol
External and internal
monitoring done by NI’s
extenders
Protocol for testing the type of
iron adopted and included in
the legislation by the GoI.
Iron spot test of fortified wheat
flour conducted by our
extenders together with the
millers QC personnel
Production of
adequately fortified
wheat flour
Uninterrupted supply of
premix ensured
6. • GoI/MoI issued MoI decree no 1/2021 on
mandatory regulation of WFF based on
SNI 3751: 2018 which uses more
bioavailable iron, viz. ferrous fumarate or
ferrous sulphate or NaFeEDTA , after 10
months on fortification relaxation
Results
Adequately
fortified
wheat flour
50 ppm of
iron
2 ppm of
folic acid
30 ppm of
zinc oxide
2.5 ppm of
vitamin B1
4 ppm of
vitamin B2
Government
laboratory
personnel
28 Millers QC
personnel
64 Virtual training provided during the
pandemic to ensure the process of
fortification continues
7. • Production of fortified wheat produced from January-October
2021 based on SNI 3751-2018 after legislation was reinstated.
This reached 41 M additional people consuming adequately
fortified wheat
• This is 20 % of the total wheat flour produced during this time-
period
Results (Contd.)
• Government inspection agencies and wheat flour millers capacitated to
monitor wheat flour fortification based on SNI 3751-2018
• Number of wheat mills which started fortifying wheat using
recommended type of iron as per SNI 3751-2018.
18
out of
21
1.2
million
MT
8. Present scenario in implementation of revised SNI
Availability of
premix assurance
by the supplier
25% decrease in
production due to
pandemic
Absence of
physical
monitoring visits
Marginal increase
in production cost
Present
scenario
9. • All 21 millers In Indonesia are complying with revised SNI
• Enforcement by government monitoring agencies started w.e.f. 1 September
2021
• Assurance of sufficient resources and budget allocation to monitor, enforce
and ensure sustainability of the program
• Support to industry/millers internal QA/QC
• Strengthening of integrated monitoring system required
• Address prevention of anemia among vulnerable populations
Policy implications
Editor's Notes
Prevalence of anemia in Indonesian population (1)
Food fortification (FF) is touted as a safe and cost-effective nutrition intervention with demonstrated health, economic and social benefits (3). It is proven to address micronutrient malnutrition/ hidden hunger among the entire age range of individuals, including vulnerable population groups like children, pregnant and breastfeeding mothers, adolescents, etc. (2, 3, 4)
It was observed as a vital intervention before, during, and after COVID-19 pandemic in decreasing the risk of food insecurity and malnutrition (3)
Wheat flour fortification (WFF) is mandatory in Indonesia since 2002. However, electrolytic iron (low bio-availability) was used as a fortificant. In 2016, Nutrition International (NI), GAIN, UNICEF and FFI started advocating with the Government of Indonesia (GoI) to align the Indonesian National Standard (SNI) with the WHO guidelines. The standard was revised in 2018 (SNI 3751:2018) and it mandates the use of more bioavailable iron, viz. ferrous fumarate or ferrous suphate or NaFeEDTA
The legislation was withdrawn from April-December 2020 due to the pandemic and resulting supply chain issues of the premix. It was reinstated in February 2021 along with a six-month grace period for the millers
In 2002 GoI started mandatory program on wheat flour fortification with iron base on Indonesian National Standard SNI for Wheat Flour (SNI 3751:2002) which was then revised with the SNI 3751:2009. This standard enforced fortification of wheat flour with iron, zinc, folic acid, vitamin B1 and B2.
At that time there is no guidance of type of iron should be use in wheat flour fortification, most millers use electrolyte iron since it is the cheapest type of Iron
Based on WHO guidelines on wheat and maize flour fortification (issued on 2009), due to low per capita consumption of wheat flour in Indonesia it is suggested to change the existing use of electrolytic iron with a higher bioavailable iron compound, such as fe fumarate, Fe Sulphate or sodium iron EDTA.
In 2015 there was an analysis of the Family Life Surveys data series on anaemia concluded that “Wheat flour fortification does not appear to have significantly contributed to the reduction in prevalence of anaemia among women of child-bearing age in Indonesia.
In 2016 NI then started its advocacy and TA to change the WFF standard, by organizing stakeholder meeting with MoH on the importance to change the standard.
There was request for efficacy study on the proposed type of Iron. NI advocated that there were already many global evidence on the efficacious and effectiveness of the recommended type of iron, no need to undertake local study.
In 2017 NI organize expert meetings on iron safety review as well as provided TA for organoleptic study to ensure the recommended iron do not have significant effect on taste, colour and aroma of wheat flour end product (ie. Bread, noddle, cookies, pao etc)
NI also provided TA for the task force to formulate the new standard ie. SNI 3751-2018 as well as TA to undertake RIA, The SNI the released in 2018 which stated ferrous fumarate or sodium iron NDTA as option iron to be use for WFF
Technical assistance: Regulatory impact analysis on implementation of SNI 3751:2018
NI provided support to MoI in developing technical guidelines to implement and monitor the revised SNI for WFF
Training/ Capacity building: In 2020, an audio-visual training aid was developed to train millers on the protocol to identify the type of iron used as a fortificant in wheat flour
(Training Module: Testing fortified wheat flour – YouTube)
In 2021, training conducted for government inspection agency and lab personnel on identification of the type of iron being used as a fortificant
Further, capacity building of government monitoring inspectors, laboratory personnel and millers on quality assurance (QA) and quality control (QC) maintained virtually throughout the pandemic
Monitoring: Active involvement of NI in developing strong QA/QC protocols and supporting government departments in setting up monitoring protocol
External and internal monitoring done by NI’s extenders
Protocol for testing the type of iron developed by NI with support from Iowa State University adopted and included in the legislation by the GoI.
Iron spot test of fortified wheat flour is conducted by our extenders together with the millers QC personnel (3 samples/ miller * 18 millers= 54 samples tested monthly) along with external support by the GoI
Production of adequately fortified wheat flour: Uninterrupted supply of premix is ensured for production of adequately fortified wheat flour (NI meeting with the millers, premix suppliers and GoI)
The legislation was withdrawn from April-December 2020 due to the pandemic and resulting supply chain issues of the premix. It was reinstated in February 2021 along with a six-month grace period for the millers
There are several micronutrients and vitamin fortified to wheat flour according to the SNI 3758, they are:
Iron deficiency is the most common deficiency. Symptoms include tiredness, fatigue, paleness of skin, shortness of breath among others
Folic acid deficiency can lead to spina bifida which is a neural tube defect, i.e., when the spinal cord does not form properly.
Zinc deficiency is characterized by growth retardation and impaired immune function. In more severe cases, zinc deficiency causes hair loss, diarrhea, and eye and skin lesions
Vitamin B1 and B2 help convert food into energy. Vitamin B1 has neurological benefits and vitamin B2 helps maintain proper eyesight.
21 wheat flour millers produce on average 6.5 Mio MT/year
1.2 million MT of adequately fortified wheat flour is equivalent to 38 million additional people additional people ( 15% of total population) consuming adequately fortified flour
COVID-19 induced restrictions on import of premix
All 21 millers In Indonesia will fully comply with fortification of wheat flour as stated by SNI 3751: 2018- will ensure this from regular monitoring and data from BPOM.
Enforcement by government monitoring agencies has started from 1 September 2021
Implementation of revised standard and its mandatory regulation will ensure GoI provide sufficient resources and budget allocation to monitor, enforce and ensure sustainability of the program
Support the industry/millers internal QA/QC
Strengthening of integrated monitoring system is required to sustain this implementation
The implementation of the revised standard and its regulation and enforcement is important to ensure prevention of anemia among vulnerable populations