PHI Letter Opposing the Weakening of School Nutrition Standards
2018 | Download
January 29, 2018
School Programs Branch
Policy and Program Development Division
Food and Nutrition Service
3101 Park Center Drive
Alexandria, Virginia 22302
Re: Docket No. FNS-2017-0021; Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements
The Public Health Institute (PHI) respectfully submit comments in response to the U.S. Department of Agriculture’s (USDA) “Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements” interim final rule (IFR) (82 FR 56703), and oppose weakening school nutrition standards. Virtually all schools (99 percent) participating in the National School Lunch and Breakfast Programs are making great progress toward serving healthier meals for low-income children with less sodium; more whole grains, fruits, and vegetables; and no trans-fat; and removing sugary drinks and unhealthy snack food. The 2012 updates to school nutrition standards reflect sound science, support children’s health, and are consistent with the 2015-2020 Dietary Guidelines for Americans (DGA) and the National Academies of Science, Engineering, and Medicine (formerly, Institute of Medicine) 2009 report School Meals: Building Blocks for Healthy Children.
The Harvard University T.H. Chan School of Public Health concluded that the update to school nutrition standards is “one of the most important national obesity prevention policy achievements in recent decades.” Researchers estimate that these improvements prevent more than 2 million cases of childhood obesity and save up to $792 million in health-care related costs over ten years. Improved school nutrition is critical given that one out of three children and adolescents aged 2 to 19 years is overweight or obese and children consume one-third to one-half of daily calories during the school day. Contrary to supporting schools and children’s health, the proposed changes in the IFR could jeopardize this progress.
We oppose the proposed three-year delay (from School Year 2017-2018 to School Year 2021- 2022) of the second sodium reduction targets (Target 2) for school meals that would lock in unsafe levels of sodium for children. Unfortunately, nine out of ten children consume too much sodium, increasing their risk of high blood pressure, heart disease, and stroke. Many schools, food service companies, and others in industry are working toward or already providing healthy and appealing meals and products with less sodium. USDA should address remaining challenges through training and technical assistance. Delaying the second phase of sodium reduction puts children’s health at risk and would result in children consuming an extra 84 to 98 teaspoons of salt (over the course of the three-year delay). Further, we are opposed to any delay of the third and final phase of sodium reduction for school meals (Target 3 which is supposed to go into effect School Year 2022-2023).
There is no need to continue the whole-grain waivers. USDA concedes in the IFR that 85 percent of schools have not requested waivers and are providing children with appealing wholegrain options. If all schools in Alabama, Idaho, and Montana can serve whole grains to their students, schools in the rest of the states should be able to as well. Eating more whole grains is associated with reduced risk of heart disease, stroke, and diabetes, provides more nutrients, and are a healthful source of fiber. Children, on average, consume too few whole grains and too many refined grains.
We oppose allowing flavored low-fat (1 percent) milk for school meals and as a competitive food. The current standards that allow plain or flavored fat-free milk and plain low-fat milk are based on expert recommendations from the National Academy of Medicine’s 2009 report. The recommendations disallowed flavored low-fat milk because it would provide more calories and likely exceed the calorie maximum for school meals. The 2015 DGA similarly recommended, “increasing the proportion of dairy intake that is fat-free or low-fat milk” and “reducing the intake of added sugars” such as those in flavored milk. Similarly, the Robert Wood Johnson Foundation’s Healthier Beverage Guidelines recommend only plain fat-free and low-fat milk for children and adolescents.
Furthermore, the Robert Wood Johnson Foundation panel recommended that if schools offered flavored low-fat milk, it should be no more than 130 calories per 8 ounces. If USDA allows flavored low-fat milk, we recommend a calorie cap of no more than 130 calories per 8 ounces, consistent with the Robert Wood Johnson Foundation’s Healthier Beverage Guidelines.