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School grade structures and meal service operations must be considered to ensure that age-grade group recommendations can be successfully implemented. Specifically, in the NSLP, some schools currently use a single age-grade group to plan meals for children and adolescents. The Department is concerned that for lunch meals intended to provide ⅓ of the RDAs without providing excessive calories, this practice may result in meals that fail to meet the nutritional needs of either group. While the same may be true for SBP, where the meals are intended to provide 1/4 of the RDAs, FNS recognizes that there are different operational constraints. In the SBP, children typically participate as they arrive at school, rather than by grade level or other service schedule that would be common in lunch. The single age-grade group currently allowed for SBP menu planning is intended to provide flexibility to meet the needs of the SBP foodservice operation. Also of note, many schools have implemented alternative methods of delivering meals to promote student participation, such as Breakfast in the Classroom or Grab-and-Go Breakfasts. FNS requests that the committee consider the potential impacts that age-grade group requirements may have on the unique aspects of NSLP and SBP meal service, operations, and participation.

Nutrient standards:

FNS requests that in addition to the current required nutrients, the IOM committee consider the DGA recommendations to minimize trans fats, as well as the intake recommendations for sodium, cholesterol, and fiber, which currently do not have quantitative standards in the school meal programs. Program operators are currently required to reduce sodium and cholesterol levels and to increase fibers levels. Monitoring these nutrients has been facilitated by the Nutrition Labeling and Education Act requirement that sodium, cholesterol, and fiber amounts be included on food labels and product specifications. Furthermore, trans fats information is now required to be included on the Nutrition Facts label and on product specifications, which would facilitate the ability of Program operators and administrators to monitor compliance with the trans fats recommendation.

Total fat:

The DGA recommendation for fat is to keep total fat intake between 30 to 35 percent of calories for children 2 to 3 years of age and between 25 to 35 percent of calories daily for children and adolescents 4 to 18 years of age. It should be noted that breakfast meals are often relatively low in fat (below 25 percent). The fat recommendation for each of the meals, in addition to the total daily fat range, should be considered in this process.

Available nutrient information:

Program operators and administrators rely in part on nutrition information provided by food labels and product specifications to plan and assess menus that meet the required nutrient levels. FNS is concerned that establishing requirements for nutrients that are not required to be listed on food labels and product specifications by the Nutrition Labeling and Education Act (NLEA, P.L. 101-535), such as the nutrients of concern for children including potassium, magnesium, and vitamin E, would be a burden to Program operators and administrators. FNS requests that nutrient standard recommendations take into consideration the availability of nutrient information on food labels and product specifications.

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