Nutrition Standards and Meal Requirements for National School Lunch and Breakfast Programs: Phase I. Proposed Approach for Recommending Revisions (2008)

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3 Working Principles and Criteria for the Committee’s Approach to Proposing Revisions The members of the Committee on Nutrition Standards for National School Lunch and Breakfast Programs developed working principles and criteria to assist them with developing recommendations for revisions to the Nutrition Standards and Meal Requirements of the school meal programs. The working principles are intended to guide committee deliberations, and the proposed set of criteria will be applied during the development of the committee’s recommendations for revision. This chapter presents these principles, the proposed criteria, and an overview of the proposed approach to developing recommendations for revisions. WORKING PRINCIPLES The working principles shown in Box 3-1 take into account the committee’s task (stated in Chapter 1), an array of background information on the need for the revisions (summarized in Chapter 1), topics relevant to revising the standards (summarized in Chapter 2), and the critical areas for consideration listed in Appendix E. 55 

56 NUTRITION STANDARDS AND MEAL REQUIREMENTS BOX 3-1 Working Principles for Determining Recommendations for Revisions to the Nutrition Standards and Meal Requirements for School Meals 1. The present and future health and well-being of schoolchildren are profoundly affected by their food and nutrient intakes and the maintenance of healthy body weight. a. School meals, when they are consumed, should improve food and nutrient intakes, and those intakes that are inadequate or excessive in school-age children should specifically be targeted. b. School meals are targeted to children ages 4 through 17 years, but younger children and children of all ages with special needs may be affected by the standards set for the general population. c. Recognition will be given to health effects of foods (including beverages) that go beyond those related to their nutrient content. 2. School lunch and breakfast programs, which may contribute to more than 50 percent of the caloric intake by children on school days, offer opportunities to promote the health and well- being of children. a. School meals can contribute to beneficial health and dietary patterns and are uniquely positioned to provide a model for healthy meals and to provide opportunities to model and reinforce healthy eating behaviors. b. School meals can provide a platform for education in nutrition, environmental responsibility, and food safety. c. School meals can be a positive environment for pleasant social interactions. d. For children in families characterized by limited resources and food insecurity, school meals provide a critical safety net in meeting their nutritional needs and reducing the adverse effects of food insecurity. 3. School lunch and breakfast programs operate in a challenging and changing environment. a. School food service environments (such as facilities, equipment, labor, and skills) are complex and highly varied across the nation as well as from school to school within school districts. b. Challenges include the need to meet food safety standards, offer appetizing foods to an increasingly diverse population, adjust to the changes in the available food supply, improve the image and appeal of the program, and achieve a sound financial operation. c. Food costs, other direct costs, and indirect costs related to program operation are outpacing the available resources. d. In addition to promoting the health and well-being of children, high rates of participation may support the financial stability of school meal programs. e. Efforts to change the current school nutrition environments vary, with some districts already making significant strides and others just starting the process of change. 4. Because scientific findings and authoritative recommendations related to the nutrition of children evolve over time, the process of developing recommendations for revisions should be transparent and designed to take into account new evidence-based findings and recommendations. 

WORKING PRINCIPLES AND CRITERIA 57 CRITERIA On the basis of the evidence considered during its Phase I activities, the committee proposes four criteria that can be used to derive and evaluate the recommendations that will be made during Phase II of the study. The criteria are identified and discussed below. CRITERION 1 THE NUTRITION STANDARDS AND MEAL REQUIREMENTS WILL BE CONSISTENT WITH CURRENT DIETARY GUIDANCE AND NUTRITION RECOMMENDATIONS TO PROMOTE HEALTH—AS EXEMPLIFIED BY THE DIETARY GUIDELINES FOR AMERICANS AND THE DIETARY REFERENCE INTAKES—WITH THE ULTIMATE GOAL OF IMPROVING CHILDREN’S DIETS BY REDUCING THE APPARENT PREVALENCE OF INADEQUATE AND EXCESSIVE INTAKES OF FOOD, NUTRIENTS, AND CALORIES. MyPyramid, which is based on the 2005 Dietary Guidelines for Americans (HHS/USDA, 2005), provides concrete recommendations for food intakes; and the Dietary Reference Intakes provide reference values for nutrient intakes. However, because school meals are provided to groups of children with a range of ages, body sizes, and activity levels, the committee cannot apply the values and recommendations directly to the Nutrition Standards and Meal Requirements. In deriving the recommendations, the committee will give special attention to the following aspects of providing healthful amounts of food groups, food subgroups, and nutrients, as requested by USDA: • appropriate levels of total fat, saturated fat, cholesterol, and trans fat in school meals; • the inclusion of specific foods whose consumptions should be encouraged on the basis of the recommendations of the Dietary Guidelines for Americans, that is, fruit, vegetables, whole grains, and nonfat or low-fat milk products; • provisions for healthful levels of sodium and fiber; • nutrients and other dietary components of concern, as identified in the assessment of intakes by schoolchildren; and • calorie levels provided at lunch and breakfast that are sufficient to meet the child’s energy needs at those meals but that do not promote excessive energy intake. To help reduce the possibility of excessive energy intake, maximum calorie levels for school meals will be considered. Criterion 1 refers to the “apparent prevalence of inadequate and excessive intakes” because adequacy, inadequacy, and excessive intake cannot be determined from dietary assessment alone. Throughout this report, terms such as “adequate intake,” “excessive intake,” and “nutrient intake” are used. The reader should recognize that phrases such as “apparently adequate intake” and “apparent nutrient inadequacy” would be more precise. We have omitted the qualifier for ease of reading. If some of the nutrients or other dietary components of concern differ from the nutrients whose amounts are required to be listed on food labels, in accordance with the provisions of the Nutrition Labeling and Education Act (P.L. 101-535, 1990), the committee will consider the most effective ways to address labeling for these nutrients in implementing the recommendations for revisions to Nutrient Standards and Meal Requirements. 

58 NUTRITION STANDARDS AND MEAL REQUIREMENTS CRITERION 2 THE NUTRITION STANDARDS AND MEAL REQUIREMENTS WILL BE CONSIDERED ON THE BASIS OF AGE-GRADE GROUPS THAT ARE CONSISTENT WITH THE CURRENT AGE-GENDER CATEGORIES USED FOR SPECIFYING REFERENCE VALUES AND WITH WIDELY USED SCHOOL GRADE CONFIGURATIONS. The committee will continue its deliberations and analyses related to the current common configurations for school grade categories and make recommendations for revisions to the Nutrition Standards and Meal Requirements for the appropriate age-grade groups. CRITERION 3 THE NUTRITION STANDARDS AND MEAL REQUIREMENTS WILL RESULT IN THE SIMPLIFICATION OF THE MENU PLANNING AND MONITORING PROCESSES, AND THEY WILL BE COMPATIBLE WITH THE DEVELOPMENT OF MENUS THAT ARE PRACTICAL TO PREPARE AND SERVE AND THAT OFFER NUTRITIOUS FOODS AND BEVERAGES THAT APPEAL TO STUDENTS. The committee recognizes that increasing complexity of program operations and related standards may challenge the success of the programs. The limited resources to both train and manage staff means that the school lunch and breakfast programs will operate best if the requirements and standards are practical and as straightforward as possible. Further, the committee’s intent is to propose revisions that will encourage wide participation in the school meal programs. Included among the key factors that affect menu appeal and acceptability by students are sodium content, the availability of choices, and familiarity with the food on the basis of the student’s cultural background or previous experience consuming the food (such as nonfat or low-fat milk). The committee will give consideration to the as served option in this regard and also to any relevant plate-waste studies. Furthermore, the committee recognizes the challenges that may occur pertaining to student acceptance of meals planned in line with the recommendations—for example, if the menu items offered contain less sodium and saturated fat and more fiber and whole grains. As feasible within the scope of work of this study, the committee will consider these challenges as it develops recommendations for the Nutrition Standards and Meal Requirements. The committee will develop a sample 4-week cycle of menus to ensure that it is possible to meet the nutrient- and food-related recommendations, but also to examine and illustrate the practicality and flexibility of implementation of the Nutrition Standards and Meal Requirements. School districts are ultimately responsible for developing menus and selecting food items that appeal to their students, so practicality and flexibility of implementation are essential. Meal standards apply to diverse school food authorities with widely different physical production plants and other resources. One essential element will be the availability of palatable food products with appropriate nutrient profiles that are in forms that can easily be incorporated into school meals. The committee will also consider the ability to simplify the menu-planning approaches available to school food authorities. 

WORKING PRINCIPLES AND CRITERIA 59 CRITERION 4 THE NUTRITION STANDARDS AND MEAL REQUIREMENTS WILL BE SENSITIVE TO PROGRAM COSTS. Because certain improvements to the Nutrition Standards and Meal Requirements have the potential to increase food costs or other direct or indirect costs of school meals, or both, the committee will explore ways to control program costs. OVERVIEW OF THE COMMITTEE’S PROPOSED APPROACH TO DEVELOPING RECOMMENDATIONS The committee’s proposed approach to developing recommendations for revisions to the Nutrition Standards and Meal Requirements for the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) includes the following four steps: 1. applying the working principles to guide the selection of data and the types of analyses and reviews to be conducted and to focus committee deliberations; 2. assessing the dietary intakes of food groups, food subgroups, and nutrients by schoolchildren to identify the food and nutrient intakes of concern for selected age groups; 3. examining various approaches to planning the nutritional aspects of school meals so that the recommendations for revisions to the Nutrition Standards and the Meal Requirements may be effectively incorporated into the requirements for the meals. The committee plans to use iterative processes to derive the recommendations that best meet all five criteria; and 4. applying the criteria listed above in the development of the committee’s recommendations for revisions to the Nutrition Standards and Meal Requirements. This will include a. incorporating sensitivity analysis to examine the nutritional impacts of the recommended revisions, and b. addressing the cost implications and market effects of the recommended revisions. An initial assessment of food and nutrient needs appears in Chapter 4. The development of a proposed planning model that may be used to develop recommendations for revisions to the NSLP and the SBP is discussed in Chapter 5. Finally, Chapter 6 presents proposals for incorporating the findings of the sensitivity analysis and for addressing cost implications and market effects.