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FEDERAL LEGISLATION
COMMENTS DUE APRIL 13 FOR PROPOSED NUTRITION STANDARDS

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 about the this 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

(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.   

In your comments, please ask the USDA to address/include the following in the final regulations for school meals (the words in bold get across the point, if you need additional explanation, read the un-bolded words). These points are all included in the sample letter link above.  

• Require that water be available by the cup at breakfast and lunch. Availability of a water fountain should not be acceptable for this purpose, the water should be available in the serving line of the cafeteria.
• 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) and 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, and any concern about the protein content is unfounded, as protein is not considered to be a "nutrient of concern".
• Remove requirement to offer 1 - 2 meat/meat alternates from breakfast. Our concern is that most schools won't be serving beans for breakfast (beans are the only whole food plant protein component other than peanut butter that counts 100% toward the component). This could lead to an actual increase in meat consumption. 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 51% whole grains (at least). 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 said to get "several" of a minimum of 6 servings as whole grains. So we don't feel like we should need to wait for 13 years till we get to 50% whole grains from when these recommendations were first made.   
• 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 at every meal for all students to choose from. 60% of the worlds population is lactose intolerant, especially persons of color. Children end up with belly aches and discomfort and find it hard to study, and 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. Though additional funding beyond the 6 cents per lunch meal may be realized as a result of raising the cost of paid lunches to eventually be the same as the reimbursement costs for free lunches (because the money intended for free and reduced price meals has been subsidizing the meals of children who pay full price), and from other changes that may result in less costs to the child nutrition program from the school districts, 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 30 minutes to actually eat their lunch. We are aware of many schools with lunch periods such that the students only have 10 minutes to eat once 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. While we have no problem with organic corn (most corn is genetically modified, organic is not) or peas, many schools rely on these as the vegetable to the exclusion of healthier vegetables, and most of them are canned. Most potato products are deep fried. 
• Specific requirements for dark green and orange vegetables, and legumes.  
• Minimum and maximum calories.
• Reduced sodium, with a too long implementation period of 10 years, though immediate small reductions are required. 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.  

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 (4/13/2011)

New York Residents*, call:

Senator Kirstin Gillibrand: 202-224-4451 (Washington, DC) and 212-688-6262 (NY) - to thank and express concerns
Senator Charles Schumer: 202-224-6542 (Washington, DC) and 212-486-4430 (NY) - to thank and express concerns
Your Congress Person: (for NYS or other states) : Click for phone number and to email.
* If you live outside of NYS, you can contact your Senators here.

After you call, please follow up with an email letter to your Senators and Congressperson. We want to flood their telephone lines and email boxes!
You can see a sample letter here. You can get the email address or contact forms for your Senators or Congress Person by clicking on the links above.

When you are done doing this be sure to share this link with all of your friends, relatives, and colleagues who care about this issue. Please also email us by clicking here to let us know you called.

We are part of a strong coalition called the NYC Alliance for Child Nutrition Authorization. Check out their website for a much more thorough review of the Child Nutrition Reauthorization Act.

STATE LEGISLATION

Family and Consumer Science classes are in jeopardy of losing their status as mandated classes in middle school. Click here to read the letter NYCHSF sent to the Board of Regents, expressing our concern. To express your concern, contact the NYS Board of Regents

LOCAL ACTION

While federal and state legislation would help to prevent massive hours of efforts across the state and the country, as of yet meaningful legislation has not been passed to address meals and competitive foods. At the local level, you can get involved in your schools Local Wellness Policy effort.

Each school that participates in the federal school meal program must have a federally mandated Local Wellness Policy, which includes ongoing efforts to ensure implementation. Many schools have committees that address the policies mandates, while many other schools do not. Creating change in school only happens because people like you who care get involved.

• Federal Legislation
• State Legislation
• Local Action

Ted Barnett, MD, makes a statement of concern at the 2008 NYS PTA Convention

Stepping Up to A Healthier Harlem Conference Attendee signs up for the NYCHSF email list

Real Food Display at Baum Forum Conference