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Appendix C
Critical Issues for Consideration by the Committee on Nutrition Standards for National School Lunch and Breakfast Programs, as Submitted by the U.S. Department of Agriculture1

There are a number of important issues on which USDA particularly seeks guidance. In the descriptions below, we have raised a number of questions and concerns, as well as tentative policy concepts for IOM’s critical review. These are intended to clarify the scope of the committee’s charge, but not to constrain or pre-determine its recommendations. We also ask the committee to consider such operational factors as market conditions, impacts on student acceptability of meals, and the decision to participate in the program, in making recommendations in each of these areas.1

Calorie requirements:

Since the establishment of the school meal programs, the dietary concerns for children have shifted from preventing hunger and nutritional deficiencies to recognizing the increase of childhood overweight/obesity rates while enhancing cognitive performance and academic achievement. FNS requests that the committee provide recommendations for calorie levels in consideration of the best scientific information available (including the DRIs) that reflect the diversity of energy needs in today’s school children. FNS would like the IOM committee to provide minimum calorie requirements, and consider also recommending maximum calorie levels for reimbursable meals that take into consideration age-grade groupings.

1

Provided by USDA to the committee.



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Appendix C Critical Issues for Consideration by the Committee on Nutrition Standards for National School Lunch and Breakfast Programs, as Submitted by the U.S. Department of Agriculture1 There are a number of important issues on which USDA particularly seeks guidance. In the descriptions below, we have raised a number of questions and concerns, as well as tentative policy concepts for IOM’s critical review. These are intended to clarify the scope of the committee’s charge, but not to constrain or pre-determine its recommendations. We also ask the com- mittee to consider such operational factors as market conditions, impacts on student acceptability of meals, and the decision to participate in the program, in making recommendations in each of these areas.1 Calorie requirements: Since the establishment of the school meal programs, the dietary concerns for children have shifted from preventing hunger and nutritional deficien- cies to recognizing the increase of childhood overweight/obesity rates while enhancing cognitive performance and academic achievement. FNS requests that the committee provide recommendations for calorie levels in consid- eration of the best scientific information available (including the DRIs) that reflect the diversity of energy needs in today’s school children. FNS would like the IOM committee to provide minimum calorie requirements, and consider also recommending maximum calorie levels for reimbursable meals that take into consideration age-grade groupings. 1 Provided by USDA to the committee. 

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 SCHOOL MEALS Age-grade groups: The NSLP and SBP provide meals for children age two and older (generally, under 21). The meal programs group children according to age-grade and establish meal patterns with minimum portion sizes and servings to help menu planners design meals that are age-appropriate and meet the diverse nutritional needs of school children. Nutrient and calorie requirements are also determined for each age-grade groups. In light of the childhood obesity trend, FNS is concerned that school meals provide age-appropriate portion sizes and promote the development of healthy eating behaviors. We request that the committee recommend age-grade groups that are consistent for all menu planning approaches and reflect the stages of growth and develop- ment in children and adolescents. School grade structures and meal service operations must be considered to ensure that age-grade group recommendations can be successfully imple- mented. 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 1⁄3 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 recog- nizes 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 pro- grams. Program operators are currently required to reduce sodium and cho- lesterol 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

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 APPENDIX C 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. Aailable 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 includ- ing potassium, magnesium, and vitamin E, would be a burden to Program operators and administrators. FNS requests that nutrient standard recom- mendations take into consideration the availability of nutrient information on food labels and product specifications. Sodium standard: It is well-recognized that the current intake of sodium for most individuals in the U.S., including school-age children, greatly exceeds the DGA recom- mendation to consume less than 2300 milligrams (mg) of sodium per day. FNS has encouraged schools to reduce sodium in the NSLP and SBP since the implementation of the School Meals Initiative (SMI) in 1995; however, the School Nutrition Dietary Assessment Studies (SNDA I–III) consistently indicate that the efforts since 1995 have not resulted in any significant re- duction of sodium levels in school meals, on average. FNS is concerned that the challenge of reducing sodium levels in school meals extends beyond the efforts of Program operators and administrators alone. At present, sodium is a common addition to processed foods and convenience items which are commonly used in school meal programs to save time and reduce labor costs. Additionally, the availability of high so-

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0 SCHOOL MEALS dium foods at home, at restaurants, and at other locations in and outside of the school meals programs has resulted in a taste preference for salty foods which impacts student acceptability of school meals and Program participa- tion. Furthermore, it takes time to change children’s taste preferences and for industry to respond to a need for low-sodium products in schools and the general market. The USDA requests that the committee consider student acceptability, Program participation, and market conditions when making recommen- dations for sodium levels in school meals. Additionally, the Department requests that the committee consider a recommendation that would allow for a progressive or gradual reduction of sodium levels in school meals, such as interim targets, to ultimately meet a standard based on the DGA recommendation over a realistic period of time without adversely affecting program participation. Vitamin A standard: Current regulations require that school meals meet minimum levels of vitamin A expressed in Retinol Equivalents (RE), as specified in the 1989 RDAs. The nutrition facts panel on food products provides vitamin A levels in International Units (IU). The most recent DRI standards for vitamin A are quantified in Retinol Activity Equivalents (RAE). FNS is concerned that there is no direct conversion from the DRI recommendations in RAE to IU. FNS requests that the committee recommend a vitamin A standard that addresses the fact that Program operators and administrators rely both on values in nutrient analysis software (which may be in RAE, RE and/or IU) and on food labels and product specifications that quantify vitamin A in IU (i.e., percent of Daily Value in International Units). FNS recognizes that a conversion from levels expressed in RAE to IU may need to be based on representation of a mixed diet for school-aged children. Menu planning approaches: FNS would like the committee to examine the adequacy of the current menu planning approaches in meeting the applicable DRIs and DGAs. We are concerned that the structure of the current menu planning approaches, such as the Traditional FBMP and NSMP, may no longer be adequate to provide school meals that reflect the 2005 DGAs. Furthermore, FNS would like recommendations for a single food-based menu planning and a single nutrient standard menu planning approach. FNS requests that the IOM recommendations result in age-appropriate meals and reflect the applicable DRIs and 2005 DGAs under any menu planning approach.

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 APPENDIX C Fruit, egetables, whole grains and low-fat/fat-free milk products: The Child Nutrition and WIC Reauthorization Act of 2004 amended the NSLA to require increased consumption of foods that are specifically rec- ommended in the most recent DGAs. FNS is requesting recommendations to increase the availability of the food groups encouraged by the 2005 DGAs. FNS wishes to apply requirements for these food groups to ensure that all students in the NSLP and SBP have access to adequate amounts of these recommended foods, regardless of the menu planning approach used by their school foodservice authority. Current NSLP regulations require that minimum servings of fruits and/or vegetables, fluid milk, and whole grain or enriched sources of grains/breads be offered daily in the food-based menu planning approaches. In the nutri- ent standard menu planning approaches, fluid milk is the only required food item to be offered and minimum serving requirements are not established. Under all menu planning approaches, whole grains are encouraged but not required. Additionally, all schools must provide a variety of fluid milk types (a minimum of two); regulations do not place restrictions on offering any milk-fat or flavored varieties. In the SBP, meal patterns and menu structures have been designed to pro- vide schools with flexibility to provide meals that reflect a typical breakfast meal and avoid unnecessary burden on school foodservice operations. FNS requests that the committee consider such differences between NSLP and SBP meal service operations when making recommendations to increase the food groups encouraged by the 2005 DGAs in the FBMP breakfast meal pattern and the NSMP menu structure. Special considerations for whole grains: • In order to incorporate whole grains into the menus, schools must be able to accurately identify a creditable whole-grain product. An issue for FNS is helping schools easily identify whole grain products that provide a significant level of whole grains. At this time, the FDA has not published a definition of a whole-grain product, or a whole-grain serving. USDA wishes to establish a consistent defini- tion for all the FNS Special Nutrition Programs (including NSLP, SBP, Child and Adult Care Food Program, the Summer Food Ser- vice Program (SFSP), WIC, and the FNS commodity programs).

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 SCHOOL MEALS Special considerations for fluid milk: • The NSLA and program regulations require that lunches include fluid milk and allow fluid milk in a variety of fat contents and flavors. Fluid milk may not be substituted by another beverage or dairy product, except when a disability precludes milk consump- tion.2 Under the FBMP approaches, a minimum of eight fluid ounces is required for school-age children and a minimum of six fluid ounces is required for preschoolers. No minimum quantity is required under the NSMP approaches. Since calcium is a nutrient of concern for children and milk is a primary food source of nutri- ents for children, FNS is seeking recommendations to implement the recommendations of the DGAs and DRIs. When considering this, the IOM expert committee should also address concerns that offering different quantity for the various age-grade groups in the NSLP and SBP may be operationally difficult to implement at the local school level due to procurement logistics and economies of scale. Meat/Meat Alternate: The current meat/meat alternate requirements in the NSLP meal patterns exceed the recommended quantities in the USDA Food Guide, the food pattern that illustrates the recommendations of the DGAs. The School Nutrition Dietary Assessment (SNDA) studies show that current meal pat- terns require more than adequate amounts of meat/meat alternate to meet the nutritional (protein and iron) needs of children and adolescents. There may be adjustments to existing meat/meat alternate requirements that could help schools limit food costs while still meeting the nutritional needs of par- ticipants. Schools could meet the meat/meat alternate requirement over the course of the week as long as a minimum serving of meat/meat alternate is offered daily. Consistent with the DGAs, schools should offer low-fat, lean meat/meal alternates to help children limit the intakes of saturated fat, total fat, and cholesterol. In addition, there is public interest in incorporating nutrient-dense meat alternatives such as soy-based products in the NSLP. 2 Current regulations require milk substitutions for students with disabilities when supported by a statement from a physician. Substitutions for students with special or other dietary needs are optional and must be supported by a statement from a medical authority such as a nurse. USDA issued a proposal on November 6, 2006 to allow schools to accept a parent statement in lieu of a statement from a medical authority. The proposed rule also specified nutrient standards for the non-dairy milk substitutes offered to students with special or other dietary needs. A final rule is in development.

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 APPENDIX C Offer ersus Sere: The IOM committee may need to be aware of Offer versus Serve, a statu- tory requirement intended to reduce plate waste in the lunch program. The NSLA requires that high school students be allowed to decline foods they do not intend to eat. Offer versus Serve may be implemented at lower grades at the option of the local school district. Program regulations require that students select at least three of the five food items offered in a food- based menu. For nutrient-based menus, the regulations require that students select the entrée. If three items are offered, students may decline one; if four or more items are offered, students may decline two. Attainable recommendations: The majority of schools prepare meals on-site with a small staff and re- stricted budget. Food purchasing, planning, preparation and service are often carried out by employees with no formal food service or management training. Changes to the meal patterns and nutrition standards must be feasible for school foodservice operators, and should not jeopardize student and school participation in the meal programs. To ensure that the combined set of recommendations are attainable, the Department requests IOM to include in the report separately for NSLP and SBP a set of four-week cycle menus for each of the recommended age groups that meet all recommenda- tions, are relatively cost neutral and would not likely have an adverse effect on program participation.

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