Comments from Dr. Howell Wechsler on USDA’s School Meal Flexibility Rule

The Alliance for a Healthier Generation respectfully submits 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 opposes weakening school nutrition standards. Nearly all schools that participate in the National School Lunch and Breakfast Programs are making great progress toward serving healthier meals with less sodium, more whole grains, more fruits and vegetables, no trans-fat, and fewer sugary drinks and unhealthy snack foods. [1] The USDA’s 2012 update to school nutrition standards reflect sound science, support for children’s health, and consistency with the 2015-2020 Dietary Guidelines for Americans (DGA)[2] and the National Academies of Science, Engineering, and Medicine (formerly, Institute of Medicine) 2009 report School Meals: Building Blocks for Healthy Children.[3] 

The Harvard University T.H. Chan School of Public Health concluded that the 2012 update to school nutrition standards is “one of the most important national obesity prevention policy achievements in recent decades.”[1] 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 ages 2 to 19 years is overweight or obese^[2],[3] and children consume one-third to one-half of daily calories during the school day.^[4] Contrary to supporting schools and children’s health, the proposed changes in the IFR could jeopardize this progress.

Further, parents are supportive of the improved 2012 nutrition standards. In Kentucky[5] and Alabama[6], over 70 percent of public school parents back the National School Lunch Program’s enhanced nutritional guidelines. In Louisiana, 75 percent of parents of K-12 public school students favored requiring public schools to meet these national nutrition standards for school meals.[7] In North Carolina, 75 percent of registered voters agreed that public schools should be required to provide foods made from whole grains.[1] This is a snapshot of the positive public sentiment reflected across the country in support of improved nutrition standards for foods served to students in schools.

A three-year delay in the second sodium reduction levels will harm children’s health

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 higher levels of sodium for children. Unfortunately, nine out of ten children consume too much sodium,[2] increasing their risk of high blood pressure, heart disease, and stroke.[3] Many schools, food service companies, and industry players are working toward or already providing nutritious and appealing foods with less sodium. We recommend that the USDA address remaining challenges that schools are facing with targeted training and technical assistance. By delaying the second phase of sodium reduction, children will consume an extra 84 to 98 teaspoons of salt (over the course of the three-year delay).[4]  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 during School Year 2022-2023. 

Continuing the whole-grains waiver is unnecessary

According to the USDA, “whole grains give kids B vitamins, minerals, and fiber to help them feel full longer so they stay alert to concentrate at school.”[5] Additionally, the USDA’s MyPlate food guidance encourage individuals to “make at least half your grains whole grains” and cites whole grains as a source of magnesium - a mineral used in building bones and particularly important for growing youth. Whole grains provide a variety of essential nutrients, including iron and folate. When consumed as part of an overall healthy diet, consumption of whole grains can help reduce the risk of some chronic diseases such as heart disease, obesity, and Type 2 diabetes.[6] For all these reasons, it is paramount that the whole grain-rich nutrition standards remain a requirement in the National School Lunch and School Breakfast Programs.  

Not only do whole grain-rich product provide great health benefits, they are also readily available to schools and appealing to students. As of January 2018, the Alliance for a Healthier Generation’s Smart Food Planner, an online database that features food and beverage products that align with federal nutrition standards, showed that, at a minimum, more than 874 whole grain-rich products are currently available for purchase by schools.[7] Further, the USDA website states, “there are many products that meet the whole grain-rich criteria that are already available to schools to make foods such as rice bowls, sandwiches, wraps, and more.”[8] National organizations that work directly with schools have seen this data come to life through meals planned and served by schools across the country. Many schools across the U.S. are offering whole grain-rich products on their menus that students enjoy. Successful strategies for encouraging students to eat more whole grains include student surveys, samples and taste tests, experimenting with new products and recipes, and peer-to-peer sharing of food preparation techniques.

The IFR reverses the great progress schools have already made in promoting a healthier lifestyle, a healthy weight, and health equity for every child. Schools need federal guidance and support to continue offering meals that nourish students, an investment in our children’s health that will prepare the next generation for success. Instead of lowering standards for all schools, the USDA should provide additional training and technical assistance to the minority of districts that receive waivers and are having difficulty meeting the whole grain-rich requirements.

Allowing flavored low-fat milk is inconsistent with dietary advice and school needs

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.^[1]  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, “reducing the intake of added sugars” such as those in flavored milk.^[2]  Similarly, the Robert Wood Johnson Foundation’s Healthier Beverage Guidelines recommend only plain fat-free and low-fat milk for children and adolescents.[3] 

Conclusion

We oppose further delay of the sodium reduction targets (both Target 2 and Target 3), the continuation of the whole-grains waiver, and allowing flavored low-fat milk. Rather than weakening school nutrition standards, we urge the administration to support efforts to achieve healthier school meals. Thank you for your dedication and commitment to improving children’s health in the school setting.

Sincerely,

Howell Wechsler, EdD, MPH
Chief Executive Officer
Alliance for a Healthier Generation

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[1] U.S. Department of Agriculture. School Meal Certification Data (as of September 2016). Washington, DC: USDA; 2017.

[2] U.S. Department of Health and Human Services and U.S. Department of Agriculture. 2015-2020 Dietary Guidelines for Americans, 8th Edition. Washington, DC: U.S. Government Printing Office, 2015.

[3] Institute of Medicine. School Meals: Building Blocks for Healthy Children. Washington, DC: The National Academies Press; 2010.

[5] Gortmaker SL, Wang YC, Long MW, et al. Three Interventions that Reduce Childhood Obesity Are Projected to Save More Than They Cost to Implement. Health Aff. 2015;34:1932-9. doi:10.1377/hlthaff.2015.0631.

[5] Ogden CL, Carroll MD, Fryar CD, Flegal KM. Prevalence of Obesity Among Adults and Youth: United States, 2011-2014. NCHS Data Brief. 2015;219:1-8. 

[6] Ogden CL, Carroll MD, Kit BK, Flegal KM. Prevalence of Childhood and Adult Obesity in the United States, 2011-2012. JAMA. 2014;311:806-14.

[7] U.S. Department of Agriculture. School Nutrition Dietary Assessment Study-III. Washington, DC: USDA; 2007.

[8] Pew Charitable Trusts Kids’ Safe and Healthful Foods Project. Kentucky Poll Shows Strong Support for Healthy School Food Policies. Washington, DC: Pew Charitable Trusts; 2015. http://www.pewtrusts.org/en/about/news-room/press-releases/2015/06/22/kentucky-poll-shows-strong-support-for-healthy-school-food-policies

[9] Pew Charitable Trusts Kids’ Safe and Healthful Foods Project. Alabama Poll Shows Strong Support for Healthy School Food Policies. Washington, DC: Pew Charitable Trusts; 2015. http://www.pewtrusts.org/en/about/news-room/press-releases/2015/06/16/alabama-poll-shows-strong-support-for-healthy-school-food-policies

[10] Pew Charitable Trusts Kids’ Safe and Healthful Foods Project. Louisiana Poll Finds Support for Healthier School Food and Fundraisers. Washington, DC: Pew Charitable Trusts; 2015. http://www.pewtrusts.org/en/research-and-analysis/analysis/2015/12/02/north-carolina-poll-reveals-strong-support-for-healthy-school-food-policies

[11] Pew Charitable Trusts Kids’ Safe and Healthful Foods Project. North Carolina Poll Reveals Strong Support for Healthy School Food Policies. Washington, DC: Pew Charitable Trusts; 2015. http://www.pewtrusts.org/en/research-and-analysis/analysis/2015/12/02/north-carolina-poll-reveals-strong-support-for-healthy-school-food-policies

[12] Jackson SL, King SM, Zhao L, Cogswell ME. Prevalence of Excess Sodium Intake in the United States—NHANES, 2009-2012. MMWR Morb Mortal Wkly Rep. 2016;64:1393-7. doi:10.15585/mmwr.mm6452a1.

[13] Appel LJ, Lichtenstein AH, Callahan EA, Sinaiko A, Van Horn L, Whitsel L. Reducing Sodium Intake in Children: A Public Health Investment. J Clin Hypertens. 2015;17:657-62. doi:10.1111/jch.12615.

[14] Difference between Target 1 and Target 2 sodium levels: grades k-5: 350 mg/day; grades 6-8: 390 mg/day; grades 9-12: 410 mg/day. Three-year delay is equivalent to mg/day x 185 school days x 3 school years (1 teaspoon = 2,325 mg): grades k-5: 194,250 mg (84 teaspoons); grades 6-8: 216,450 mg (93 teaspoons); grades 9-12: 227,550 mg (98 teaspoons).

[15] U.S. Department of Agriculture. Core Nutrition Messages – Whole Grain Messages for Moms. Washington, DC: USDA; 2012. https://fns-prod.azureedge.net/sites/default/files/WholeGrainsAllMessages.pdf

[16] U.S. Department of Agriculture. ChooseMyPlate.gov. Washington, DC: USDA; 2015. https://www.choosemyplate.gov/grains-nutrients-health

[17] Alliance for a Healthier Generation. Smart Food Planner. https://foodplanner.healthiergeneration.org/. Accessed January 2018.

[18] U.S. Department of Agriculture. Tools for Schools: Serving Whole Grain-Rich. Washington, DC: USDA; 2017.   https://www.fns.usda.gov/healthierschoolday/tools-schools-serving-whole-grain-rich

[19] Institute of Medicine. School Meals: Building Blocks for Healthy Children. Washington, DC: The National Academies Press; 2010.

[20] U.S. Department of Health and Human Services and U.S. Department of Agriculture. 2015-2020 Dietary Guidelines for Americans, 8th Edition. Washington, DC: U.S. Government Printing Office, 2015.

[21] Healthy Eating Research. Recommendations for Healthier Beverages. Durham, NC: Robert Wood Johnson Foundation, 2013. http://healthyeatingresearch.org/wp-content/uploads/2013/12/HER-Healthier-Bev-Rec-FINAL-3-25-13.pdf