Submit your comment to the USDA

The USDA announced new school lunch guidelines back in January. The new USDA guidelines would:

  • Establish the first calorie limits for school meals.
  • Gradually reduce the amount of sodium in the meals over 10 years, with the eventual goal of reducing sodium by more than half.
  • Ban most trans fats.  
  • Require more servings of fruits and vegetables (including green leafy vegetables).
  • Require all milk served to be low fat or nonfat, and require all flavored milks to be nonfat.
  • Incrementally increase the amount of whole grains required, eventually requiring most grains to be whole grains.
  • Improve school breakfasts by requiring schools to serve a grain and a protein, instead of one or the other. (Source and Source)

The new rules have also been published in the Federal Register. Right now we have an opportunity to submit feedback to the USDA during the comment period. If you would like to submit a comment about the new proposed rules, you only have until April 13th to do it. Here’s how:

1) Go to regulations.gov

What’s Hot = LOL

You will notice that under “What’s Hot” (bottom left) the top two bills are related to child nutrition.

2) Click on one of the two options. I checked out this website a few days ago and there weren’t two options so I don’t know what kind of shenanigans have taken place…

Scroll down at your own risk

The next screen is a text file of the proposed regulation. You can peruse it, but it’s very long.

3) Click on “Submit Comment”

It’s like the payment screen on Amazon…

 This is where you tell them where you live and type your comment.

If you scroll down, notice that you can even upload a file. I could upload a picture of one of the school lunches I ate last year! Of course then I would out myself, but that would be super fun.

For the record, the School Nutrition Association has come out against the new rules for a variety of reasons. I think I agree with them on one count — where’s the money? Food costs are rising dramatically. New regulations without additional funds amount to unfunded mandates. I’m not a big fan of unfunded mandates in education.

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11 Responses to Submit your comment to the USDA

  1. Anonymous April 7, 2011 at 5:59 am #

    Very interesting. Some of their complaints, like their dislike of the decreased starch proposal and their support for processed meat products, makes me raise an eyebrow, as does their argument that children should be OFFERED legumes and colorful veggies, not SERVED.

    However, they also make an excellent point about not giving schools enough time to adjust to the new regulations. I can only imagine schools with limited kitchens trying to figure out how to prepare food according to some of these guidelines, but at the same time, if the food-service companies they outsource to offer squash cubes the way they offer corn kernels, or white-meat chicken tenders the way they offer mystery patties, then really it's all just heat-and-serve anyway, isn't it? Except with more variety?

    Also, their comments about sodium:
    "SNA also said it will be difficult to meet the USDA requirement to reduce sodium in school meals by more than 50 percent within ten years, because low-sodium canned goods are not widely available"
    Um… isn't that the whole point? To eliminate schools' dependence on overcooked, nutrient-poor, flavorless canned food? :\

    *shakes head in confusion*

  2. Central Restaurant Products April 7, 2011 at 12:33 pm #

    Is there a restriction on the type of fruits and vegetables being served? So many schools serve canned versions most of which are pretty unhealthy, but cheap and fit the bill.

  3. Anonymous April 7, 2011 at 12:56 pm #

    Anonymous at 12:59 has it wrong…eliminating dependence on canned food is not the whole point. The point is bringing school lunches in line with the latest recommendations for proper nutrition.

    If you read the full SNA letter, they are concerned because some districts, at some times, don't always have access to fresh, affordable produce. Remember that storing fresh produce, even overnight, requires sufficient refrigeration. A freeze down South can send budgets around the country into shock. The rules on how you count salad bar vegatables aren't clear. The district where I am does not use canned vegetables except in an emergency (fridge breaks down) but the new rules could make this a violation.

    As to sodium, the sodium that is naturally in milk isn't going to leave much available for the rest of the meal. And let's face it, salt does enhance flavor.

  4. Dana Woldow April 7, 2011 at 1:02 pm #

    Being a parent volunteer, I am not a member of the SNA, and can't speak on their behalf. However, I suspect that most of their other concens about the proposed rule stem from the lack of sufficient funding to implement it.

    The concern that too much food will be wasted, that kids used to hot dogs and tater tots will reject grilled chicken breast and butternut squash, and that schools used to serving commodity canned veggies may have to switch to more expensive fresh produce, all can be traced back to fear of red ink in the school meal program.

    With school budgets tighter than ever, and schools under increasing pressure to produce higher test scores even as class size increases, is it any wonder that those in charge of the cafeteria (which is supposed to be self sufficient financially) are unwilling to risk losing customers and generating debt to implement new meal standards which will drive already-skyrocketing food prices even higher?

    Not saying this is an excuse to oppose the new regs, just an explanation for why there is opposition. I bet that if this legislation were properly funded, the SNA would be the first to get behind it.

  5. Justin April 7, 2011 at 2:07 pm #

    Wow. I'm pretty appalled that the SNA thinks the timeline for sodium reduction is "too long." At a time span of 10 years, I felt just the opposite. Who are they representing? The kids or the food manufacturers.

    Food manufacturers have no problem rushing new formulas out the door when there's a buck to be made or lost. They do it all the time. Just wander your supermarket and look at all the foods with "whole grain" logos and flashy claims about having been reformulated with more fiber, less fat, earth friendly ingredients, and whatever else the current fad is. If they can do it at the supermarket, they can sure do it for the bulk stuff they sell to schools and they'll have to if the schools aren't allowed to purchase the products as-is.

    I'm a big fan of change for the better and taking it in small steps, but reducing sodium levels in packaged foods by half is not a step that needs to be taken slowly, nor are there any real funding requirements to make it happen. The tools are there. The parties involved just need a little kick in the butt to make it a reality. Most packaged foods have 3 to 4 times the sodium necessary to make it taste good or to preserve it.

    Studies have been done showing that most Americans have developed a tolerance for salt because of the amount consumed that makes it so you require more and more in order for it to taste right–similar to those who develop tolerances to spicy food and who progressively reach for bottles of hotter and hotter stuff. The neat thing about salt is that if you reduce your intake, your taste buds return to normal and the previously bland food tastes too salty. Also related to that, if you salt and taste food as you cook it, there's usually no reason to put a shaker on the table and you'll end-up using less because the salt is cooked INTO the food rather than on top of it.

  6. Anonymous April 7, 2011 at 2:11 pm #

    Mrs. Q – You are awesome!!

  7. Anonymous April 7, 2011 at 3:29 pm #

    I just wish they would tackle the issue of hidding fruit in things like adding juice or applesauce to jello and calling a serving of fruit. Thats crap its desert not fruit.

  8. Mrs. Q April 8, 2011 at 3:07 am #

    Thanks for all the terrific comments!

  9. SNA President Nancy Rice April 8, 2011 at 4:54 pm #

    School Nutrition Association supports strengthening standards for school meals, and our members are already working hard to offer healthier choices in school cafeterias (visit http://www.TrayTalk.org for examples).

    But new standards must take into account the reality of schools’ limited resources. USDA’s proposed standards would increase the cost of preparing a school lunch by 15 cents and a school breakfast by 51 cents. Yet, school cafeterias have just six cents to purchase additional ingredients for each meal. No additional support is being provided to schools that struggle with limited and antiquated equipment for preparation and storage, and high labor and training costs. Even the best nutrition standards will fall flat if schools cannot afford to meet them.

    SNA’s comments to the proposed rule still support requiring significant improvements to school meals, but at a pace and a price tag that are more realistic and achievable. For more information, visit http://www.schoolnutrition.org/Blog.aspx?id=15197&blogid=564.

    School Nutrition Association President Nancy Rice, M.Ed., RD, LD, SNS

  10. SNA President Nancy Rice April 8, 2011 at 8:25 pm #

    School Nutrition Association supports strengthening standards for school meals, and our members are already working hard to offer healthier choices in school cafeterias (visit http://www.TrayTalk.org for examples).

    But new standards must take into account the reality of schools’ limited resources. USDA’s proposed standards would increase the cost of preparing a school lunch by 15 cents and a school breakfast by 51 cents. Yet, school cafeterias have just six cents to purchase additional ingredients for each meal. No additional support is being provided to schools that struggle with limited and antiquated equipment for preparation and storage, and high labor and training costs. Even the best nutrition standards will fall flat if schools cannot afford to meet them.

    SNA’s comments to the proposed rule still support requiring significant improvements to school meals, but at a pace and a price tag that are more realistic and achievable. For more information, visit http://www.schoolnutrition.org/Blog.aspx?id=15197&blogid=564.

    School Nutrition Association President Nancy Rice, M.Ed., RD, LD, SNS

  11. Anonymous April 22, 2011 at 2:43 am #

    I don't like the requirement for lowfat or skim milk only. The fat in whole milk is great for the developing brains and growing bodies of children. Allowing flavored (aka sugar-filled) nonfat milk but disallowing wholesome whole milk is crazy. I hate the USDA's top down approach of designing guidelines based on the current crop of government approved nutritional wisdom. Look at how much more harm than good government policies did with the low-fat (high sugar/carb) debacle.

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