A/HRC/28/35 11. “Safety net approaches” do not offer wider social protection systems, but rather tend to consist of isolated programmes, often fragmented and insufficiently coordinated. That fragmentation makes it more difficult for individual rights-holders to identify who is accountable for a programme’s implementation and may lead to gaps in coverage, exclusion errors, or create risks of activities in one sector creating negative unforeseen effects in another.7 12. The concept of the Social Protection Floor Initiative is based on shared principles of social justice and refers to the Universal Declaration of Human Rights and the International Covenant on Economic, Social and Cultural Rights for the realization of the rights to social security, adequate standard of living, health, education, food and housing.8 The Social Protection Floor Initiative and human rights standards are complementary, as the first provides the policy space while the latter provides the normative framework in which States should develop social protection floors. While social protection floors represent States’ policy commitments, human rights norms translate into concrete rights for specific rightsholders, and therefore into concrete legal obligations for States. III. Human rights norms and principles and social protection floors 13. ILO Recommendation 202 lays down the guiding principles that should be observed in creating national social protection floors. In its preamble, it reaffirms that the right to social security is a human right and an important tool not only to “prevent and reduce poverty, inequality, social exclusion and social insecurity” but also “to promote equal opportunity and gender and racial equality”. 14. The preamble of ILO Recommendation 202 also explicitly mentions the Universal Declaration of Human Rights (arts. 22 and 25) and the International Covenant on Economic, Social and Cultural Rights (arts. 9, 11 and 12). The recommendation refers to a number of human rights norms and principles, such as the universality of protection; entitlements prescribed by law; non-discrimination, gender equality, responsiveness to special needs; respect for the rights and dignity of people covered by the social security guarantees; progressive realization; transparency and accountability; remedies; and respect for the rights of collective bargain and freedom of association for all workers. 15. Those principles are drawn from States’ human rights obligations. The Committee on Economic, Social and Cultural Rights, the authoritative interpretative body of rights and obligations of the Covenant, in paragraph 2 of its general comment No. 19 (2007) on the right to social security (art. 9) (hereinafter, general comment No. 19), clarified that the right to social security encompasses the right to access benefits without discrimination in order to secure protection from, inter alia, a lack of a work-related income due to sickness, disability, maternity, employment injury, unemployment, old age or death of a family member, unaffordable access to health care or insufficient family support. The Committee further stresses that States must provide social protection to all individuals, guaranteeing universal coverage, reasonable, proportionate and transparent eligibility criteria; 7 8 Joint report of the Independent Expert on the question of human rights and extreme poverty, Magdalena Sepúlveda Carmona, and the Independent Expert on the issue of human rights obligations related to access to safe drinking water and sanitation, Catarina de Albuquerque, A/HRC/15/55, paras. 109–112. ILO, “The right to social protection”. Available from www.social-protection.org/gimi/gess/ ShowTheme.action;jsessionid=fe733a52c755391a07baca70ac9a28494407ab58cddcee3c990e4d62c2b edd28.e3aTbhuLbNmSe34MchaRah8Tchr0?th.themeId=2566. 5