Make a difference for our kids! – Last call for public comments on Nutrition Standards in National School Lunch & Breakfast Programs

9 Apr

Please read the following letter from Amie Hamlin, the Director ot the NY Coalition for Healthy School Food, and submit your comments today:

Dear School Food Advocates,

The Child Nutrition Reauthorization Act (CNR) passed in December of 2010. This law is renewed every 5 years. “Nutrition Standards in the National School Lunch and School Breakfast Programs, Proposed Rule”for the law were put forth in January. The United States Department of Agriculture (USDA) wants comments from the public on the proposed rule.

This is our chance to make a difference. Please don’t delay – submit your comments today – the deadline is Wednesday!

Submit comments on the regulations here

(This link takes you to a form where you can submit comments of up to 2000 characters and/or upload a document.)

Click here for a sample letter that you can modify

and upload to the above link.
Comments are due no later than

Wednesday, April 13th.

In your comments, please ask the USDA to address/include the following in the final regulations for school meals. You can include the words in bold to get across the point. If you need additional explanation, read the un-bolded words. These points are all included in the sample letter link, however the un-bolded part has been slightly modified to make it appropriate for submission, whereas the points below are intended as an explanation for you. 

  • Require that the legumes count as a protein, rather than a vegetable component. In the school meal program, legumes can count as a meat/meat alternate or a vegetable. Legumes are the healthiest way to get concentrated protein. But they shouldn’t replace healthy vegetables such as broccoli, collard greens, and sweet potatoes. They should replace meat and cheese.
  • Require a daily plant-based entree as a healthy option.Legumes and tofu are healthy proteins which would bring the cholesterol and saturated fat content of a meal down and the fiber content up. Research is clear that Americans eat too much meat and cheese, and all recommendations tell us to eat less. They just don’t say it directly, they say less cholesterol and saturated fat. Reducing these items is the primary way to reduce cholesterol and saturated fat.
  • Include tofu as a meat/meat alternate. This would allow a wider range of healthy entrees. Any concern about the protein content is unfounded, as protein is not considered to be a “nutrient of concern“, and most Americans get too much.
  • Remove the requirement to offer 1 – 2 meat/meat alternates for breakfast. This is a major concern because cholesterol is only found in animal foods (meat, cheese, eggs, fish/seafood) and they are the primary source of saturated fat in the diet. The current requirement is 2 grains or 2 meats or 1 of each. If the school chose 2 grains, then there would be no meat requirement. Thus, schools currently are not required to offer meat/meat alternates for breakfast but would be under the new rule.
  • Ask that 50% of grains be “whole grain” NOT “whole grain rich”. The US Dietary Guidelines, which the school meal programs are supposed to emulate, state that our grain intake should be 50% whole grain. Now there is a new terminology, called “whole grain rich”. A whole grain rich product contains at least 51% whole grains. The rules ask that for the first 2 years post implementation, that 50% of grains be “whole grain rich” and what this really means is that only about 26% of grain products will actually be whole grain. Two years post implementation 100% of grains should be “whole grain rich”. That means students would only be getting 50% of their grains as whole grains 3 years from now. There’s no reason that schools can’t offer a full 50% of their grains as whole grains, not “whole grain rich”, and further, that 2 years post implementation, the percentage could move to 75% whole grain. The recommendation to get 50% of our grains as whole grains is not new, it was included in the 2005 Dietary Guidelines, and the 2000 Dietary Guidelines say to get “several” of a minimum of 6 servings as whole grains. We believe we should not wait for 13 years from when these recommendations were first made until we get to 50% whole grains.
  • Eliminate all deep fried and flash fried products. There is no reason that children need to be eating chicken nuggets, mozzarella sticks, or French fries at school.
  • Eliminate all artificial colors, artificial flavors, preservatives, artificial sweeteners, and corn syrup from school food. These ingredients are the hallmarks of processed foods. They do nothing to contribute to health, and their main purpose is for corporate profit – replacing the color and flavor lost by processing foods, allowing them to be shelf stable for long periods of time, trick customers into thinking they will be aided in losing weight,and providing a cheap sweetener, respectively.
  • Eliminate ALL transfats. The rule states that the nutrition label or manufacturer specs must state “0” grams per serving. However, due to food industry influence, “0” grams per serving actually means up to 1/2 gram per serving. How do you know if a food contains transfat? Look on the ingredient list for the words “partially hydrogenated”.  Our request is to eliminate all “partially-hydrogenated” oils from school meals.
  • Offer non-dairy milk as a choice at every meal. Sixty percent of the world’s population is lactose intolerant. Persons of African, Asian, Latino, and Native American descent have high rates of lactose intolerance. Children end up with belly aches and discomfort and find it hard to study. They don’t even know it’s caused by a meal component that is required to be offered. A non-dairy equivalent should regularly be available to all students.

Additional programmatic recommendations:

  • Increased funding. The new regulations provide six cents additional per lunch meal. Though additional funding may be realized as a result of other changes, it’s not enough. If we want to feed our children healthfully, we’ve got to pay for it! An increase of 50 cents for food costs would make a tremendous difference for the quality of food served. Additional monies are needed for staff, training, and equipment.
  • Ask that all schools offer meal periods that are between the hours of 11 – 1. It is simply unacceptable that schools cannot find a way to feed children lunch at a reasonable hour. We work with schools that start their lunch periods at a few minutes after 9 am, and many that start their lunch periods at 10 or 10:30.
  • Ask that all children have at least 30 minutes to actually eat their lunch. We are aware of many schools with lunch periods where students only have 10 minutes to eat after they get through the lunch line. We can’t expect children to eat (or digest) healthfully in 10 minutes!

What they got right:

  • Increase of fruits at breakfast from 1/2 cup to 1 cup.
  • Increase of fruits and vegetables at lunch from 1/2 cup to 1 cup fruits and vegetables combined, to 3/4 – 1 cup of vegetables, and 1/2 – 1 cup of fruit.
  • Reduction of starchy vegetables such as corn, peas, and potatoes. We agree with this because many schools heavily rely on these as the vegetable to the exclusion of other vegetables, and most of them are canned. Most potato products are deep fried. (We have no problem with organic corn – most corn is genetically modified, organic is not – or peas, except when it is to the exclusion of other  vegetables).
  • Specific requirements for dark green and orange vegetables, and legumes.
  • Minimum and maximum calories.
  • Reduced sodium. We understand the need to do it gradually, but don’t think 10 years is needed to achieve the goals.
  • A reduction in the meat/meat alternate for lunch. This reduction is very small, from an average of 2.25 ounces to 2 ounces per day, however, it is a step in the right direction. However the increase of meat at breakfast may offset this decrease.

Please submit your comments now. Thank you for your attention to this very important matter.

Wishing you well,Amie Hamlin

Executive Director


PS – we got the law passed in December, but without strong nutrition standards, it won’t mean a whole lot. Please submit your comments today! Your chance to comment will be gone after this coming Wednesday.

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