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Proposed Meal Pattern Standards

SNA Seeks Comments on Proposed Meal Pattern Standards

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USDA issued a rule on the proposed meal pattern standards on January 13, 2011, starting a 90 day comment period.  All comments on the proposed meal pattern requirements are due by April 13, 2011.  SNA is currently drafting official comments to submit prior to the April 13th deadline.

SNA has convened an 11 person task force, headed by President elect Helen Phillips, to review, discuss and draft SNA’s official comments on the proposed meal pattern requirements.  The Task Force on Nutrition Standards in the National School Lunch and School Breakfast Programs met from February 15-16th, to begin this process.

There are several opportunities for you to contribute to SNA’s official comments.  Please leave your thoughts and concerns in the comments section below this story.  Task Force members will continually monitor the comments submitted. 

There will also be two opportunities at LAC for you to voice your ideas.  SNA members will be able to address attending LAC Task Force members during the timeframe of 5:30-6:30 PM (Rayburn Room of the J.W. Marriott) on Sunday, March 6th.  During the closing general session on Wednesday, March 9th, LAC attendees will have an opportunity to speak with Secretary of Agriculture Tom Vilsack and other USDA officials on the issues affecting the proposed meal pattern standards.  In addition, over 6 hours of general session time will be dedicated to discussing the proposed meal pattern standards and the new Child Nutrition Reauthorization law.

SNA members will also have an opportunity to remark on the draft comments, expected to be posted in mid-March. 

Below are links to several resources that will help you understand the proposed meal pattern requirements.

Proposed Meal Pattern Standards


If students are not taking enough fruits and vegetables, I think it would make more sense to offer more choices, not larger serving sizes. I would suggest requiring 2 fruit/veggie choices at breakfast, 1/2 cup each, student must select one. Require offering 3 fruit/veggie choices at lunch (1/4 -1/2 cup each), student must choose one, but could take 2.
Posted by: Deborah Egeland at 2/25/2011 1:13 PM


Requiring flavored milk to be only skim will stop children from choosing milk at all. I would rather see them consume 1% flavored thatn no milk at all
Posted by: Dawn Fronius at 2/25/2011 1:52 PM


I posted this on the other page, but have copied it here.

The funding available to support the proposed guidelines has to be taken into account. There is no way that most programs will be able to stay afloat with the small increase in funding but giant increase in required offerings.

Making a child take a fruit or vegetable is not going to make that child eat it. If they are forced to take things they don't want, it will go directly into the trash...money in the trash.

The proposed requirement of 1 cup each of fruits and vegetables at the high school level is excessive, in my opinion. Again, we may as well toss our money directly into the garbage.

Lastly, we have to remember that if the students don't take the food, it does no good to prepare it, no matter how wonderful it is for them. Unfortunately, society has gotten completely off track as far as diet and we can't expect abrupt changes to be accepted well. Proper nutrition education is key, and until parents begin the process of healthy eating at home, we are fighting a losing battle. If we want to keep students participating in our programs, we have to make changes gradually.

Just a quick comment to Ms. Fronius above, our best selling milk is fat-free chocolate. The kids are fine with the fact that it is skim.
Posted by: Crystal Thill at 2/25/2011 2:09 PM


I have been in School Food Service for 25 years, 7 years as a main dish cook in our High School and 18 years as an Elementary Manager. This year my elementary school received a grant to feed a fresh fruit or fresh vegetable to all 360 student every day. Half in the morning and half in the afternoon. This program wouldn't work without the teacher's involment. And I think these new standards, while good, won't work either without teacher's getting involved. I tried for years to get our school to let our students have recess first then eat lunch. We did this for nearly a year and we had much less food going in the garbage plus we had to prepare more fruits and vegtables because the students were taking the time to eat them. To make a long story short our teacher's didn't like this change for various reasons even though there were many benefits for our students. We are now again feeding them first with recess directly after lunch. And again much of the fresh fruits and vegetables that our school lunch program already provides are going in the trash. I agree with the others who believe that costs will go up while much of the fresh fruits and vegetables will end up in the garbage unless we can get everyone in our school systems to realize the importance of feeding our students and making sure they have enough time to enjoy their food. We give our students only 20 minutes to get through the line, sit down, eat and dispose of their waste until it is time to go out for recess. It is rare that students will choose to stay in and finish their lunch so they throw their food away and go out to play. Again we need more than someone who wants to tell us who work in food service the obvious (students need to eat more fruits and vegetables) to make this work. Regulating without any other changes or using education opportunities for our students will only make us feel better but have no value for the extra cost.
Posted by: Susan Byers at 2/25/2011 6:44 PM


We have a healthier US school in our district and have been very successful with Nutrient Standard Manu Planning to produce high quality, healthy school meals. I hate to see that option go away. We serve a variety of fresh fruit and vegetables and we do serve potatoes (we're from IDAHO!) I think the starcy vegetable limit is over the top. Fresh locally grown corn on the cob, Idaho baked potatoes, and fresh sugar snap peas are menued in our schools and contain valuable nutrients students need. I have looked at my menus, we served french fries ONCE this month. We served a baby oven roasted potato twice this month, mashed potatoes once and we offer a fresh baked potato bar twice a week. You tell me, what is wrong with that? Our baked potato option is very popular with students, I hate the thought of taking the option away from our kids and risk a drop in participation. Our potato bar has changed in the last year. We no longer offer butter, we use low sodium products, we have include fresh ingredients, and offer from scratch items in addition to everthing else. As usual it seems meals are the focus. What about new regulations on physical activity? Can't there be requirements for ALL schools to have recess and daily Physical Education programs?
Posted by: Angela Baumann, COM, CFPP at 2/28/2011 10:47 AM


I'm sure the intentions were good, but the end result is that we are encouraging students to take food and throw it away. Offer vs serve goes away as soon as students are required to put a specific food on their tray. We offer 2 veggies and 4 fruits every day at each of our schools. Requiring students to take 1 is not going to encourage them to eat it. A larger serving of veggies is not going to encourage students to eat more veggies. It's going to cost us more money, and more grief when our community sees what we are throwing away at the end of the day. We will have to purchase new trays to fit the new serving sizes. The 6 cents we are going to get (eventually) will come nowhere near covering our costs. Six cents will buy 1 slice of real whole grain bread. It will not buy more fresh fruits or more veggies. Do we really want to take away the favorite veggies, corn, because of a fear of starch? What about the fact that the students will TAKE and EAT the corn? Are we losing sight of the most improtant part of good nutrition? The students have to eat it in order for them to get any nutrition! With the 1% or 2% milk issue, do we seriously want to be taking all choices away form the students? How will they learn how to make choices if we keep taking the choices away? Most of our students drink chocolate milk, then 2%. Why take the 2% milk choice away? Not everyone needs to cut calories! 1% and skim are not acceptable to many, they do not taste the same. Must we do away with potato bars now? Too much starch?? We finally come up with a good food bar line, and we may have to get rid of it because of this new rule. I have to believe that bread and other grains also have a lot of starch, but they are required daily. Drinking water available where meals are served--who pays for this? NSLP? It is not part of NSLP and is actually competing with NSLP. Why take milk when you can get free water. Fund raisers--this is telling students (and their parents) that cookies, cakes, ice cream, etc are only "bad" for you if they come from the NSLP! We need a fund raiser! How about if we sell cookies, and tell the kids not to eat them until they are out of school? This makes no sense at all. Please, someone look at this bill realistically!
Posted by: Robyn Wood at 2/28/2011 12:15 PM


We have as many children who look under weight as over weight. We also were doing recess first and administration changed it back and offered 10 minutes extra recess if they were good and had their tables clean. I did get them to split the 10 and give 5 back. Needless to say we have more packers and more food in the garbage.
Posted by: Brenda Elliott at 3/10/2011 8:21 AM


making the kids eat healthy is a good thought but some kids are not going to do it. they will pack or just bring in the food that we don't serve. I have tried to go healthy choices and taking certain items away and my lunch count has went down by 50 to 75 kids. so what good is it if the kids won't eat it. I agree fries and starchy foods are not that good for you but this is what they want. How can we change their lifetime eating habits in 30 minutes 180 days a year.
Posted by: Frances Williams at 3/10/2011 8:28 AM


The new proposed meal pattern standards have too many changes at one time. They need to made gradually. Healthy eating needs to start at home. How can we change lifetime eating habits in 30 min? It is like fighting a losing battle. Corn and potatoes are starchy vegetables but they also have nutritional value. Students take these vegetables and eat them. Having students take extra vegetables or vegetables they won't eat is costly and they get no nutritional value from food that is thrown into the garbage.It makes no sense to prepare food that students will not eat.
Posted by: Edna Eash at 3/14/2011 10:13 AM


I would like consideration to maintain at least a modified version of nutrient standard menu planning. The complete elimination of that menu planning option removes a tool that many directors do use to provide high quality, healthy school meals. Specifically, a modified version of NSMP that allowed us to provide grams of protein instead of meat/meat alternate would allow us to continue to serve children grilled cheese sandwiches with only 1 oz of cheese, spaghetti with marinara sauce, pb&j with a palatable amount of peanut butter, etc. These items are lower in fat and better meet the taste preferences of students without compromising on the amount of protein needed for a healthful diet. I’d be happy to follow the food based model for all of the other components, but would love some consideration on the meat/meat alternate component.
Posted by: Megan Schaper at 3/15/2011 12:45 PM


I could go on and on, but I'll offer only a few comments & concerns:
1. I strongly support a requirement to offer more and/or larger serving of fruits & veg, but I'm against forcing students to take fruit if they don't want it. Feeding the trash can leads to a decrease in public support for our program, as well as increased costs. If the recommendation goes forward as written, I would like to see the OVS provision adjusted accordingly so that its original intent is preserved.

2. NuMenus is a viable menu planning option used successfully by several very large districts. Why not keep it as an option and add a fiber requirement to address the fruit/veg issue?

3. The recommendation for starchy veg is prohibitive, confusing and does not take into account cultural/regional food preferences. If the intent is to decrease fat intake by eliminating or reducing consumption of fried or par-fried foods, why not just say that? Is there a science-based reason to severly restrict corn, peas and lima beans? I don't see that anywhere in the DGA...

4. I welcome national nutrition standards, but I think the timelines for compliance may be unreasonable, especially in regards to sodium. Is it even possible to meet the 10-yr goal?
Posted by: Lisa Winter at 3/15/2011 2:24 PM


SNA should request that USDA continue to allow students to select the foods that they will eat within the guidelines of OVS and not require that the tray continue a piece of fruit or vegetable for the meal to be reimbursable.

While attending LAC one of the participants on the IOM's panel on school meals could not tell the audience the evidence as to the reason why this recommendation should be established. The proposed rule includes USDA's own estimate that 50% of high school students do not take a serving of fruit/vegetable. For my district more than 10,000 may not be reimbursable. If students must take the fruit/vegetable I believe that there will be greater waste as many students will just toss the unwanted item into the trash.
Posted by: Sharon Briel at 3/15/2011 5:17 PM


SNA position on the proposed rules should include its concerns that the proposed meal pattern has not been piloted to determine costs and affects on meal participation.

USDA piloted NSMP for more than 10 years before the meal pattern was released for use by schools. USDA needs to pilot the proposed meal pattern on a small scale throughout the United States so that actual data can be studied and the meal pattern adjusted before implementation nationwide.
Posted by: Sharon Briel at 3/15/2011 5:22 PM


SNA should include in its position paper that USDA provide a 5 year delay to implement weighted averages to determine compliance with saturated fat, sodium and calorie range. The 5 year delay will allow state agencies time to assist schools with menu planning techniques to comply with the proposed meal pattern.

The waiver to use simple averages expired December 31, 2010. Weighted averages will cause schools to need to limit the amount of animal products (cheese, beef, pork, and poultry - sources of saturated fat) included on their menus which may decrease meal participation. Manufacturers need additional time to adjust their recipes and products.
Posted by: Sharon Briel at 3/15/2011 5:30 PM


Our meal program switched to non-fat flavored milks several years ago and it has been no problem, chocolate is the best seller. I have no problem with the low/no-fat requirements and was happy to see flavored milks remaining as an option in these rules. Elimination of flavored milk would be more devastating to milk consumption than lower fat contents.
The self-serve, unrestricted fruit & vegetable bars we have in our elementary schools have provided many opportunities for children to taste new items. I am always amazed at the variety kids take AND eat when they can make their own decisions, not forced to take something they don't want. The new rule to "serve" one F/V is contrary to the concept of offer vs serve which is beneficial not only for waste reduction but helps keep food costs down. You want to encourage more fruit & vegetable consumption? Then put money into supporting more self-serve fruit/vegetable bars.
I agree with other comments to keep in mind that not all children need calorie reductions. There are many children in our district for whom the school meal program is their sole source of nutritious meals. Obesity is a societal issue, don't harm others because it's politically expedient to focus on school meals.
I also agree with the comment, "if the intent is to decrease fat intake by eliminating or reducing consumption of fried or par-fried foods, why not just say that? Is there a science-based reason to severely restrict corn, peas and lima beans?" This ruling, if it stands, would prevent us from putting peas or corn based salads on the F/V bars if we want to offer a healthy baked potato item during the week...too restrictive and unnecessary.
I have a concern with the push toward more scratch cooking and that the proposed pattern has not been piloted to find out the actual costs and effects to our programs. As all costs, including labor, in-directs and food, continue to rise the implied directive in this ruling to return to scratch cooking is naive and unrealistic. Many recipes I have worked with in school meal programs are as high or higher in fat, salt and sugar than comparable commercially prepared foods. It is good that this ruling will drive a continued reduction of these ingredients in commercial products, society as a whole will benefit, but the time-line for meeting reductions should be reachable and not designed to force programs to invest in remodeling or replacing food preparation equipment because to comply they have to cook from scratch.
Posted by: Janice Dieter at 3/16/2011 4:51 PM


While the effort to improve foods available to students is commendable, workable solutions are critical. Funding is a real-world concern. The dramatic increases in breakfast requirements (and costs) will force many programs to close service, actually reducing the availability of morning nutrition rather than improving nutrient intakes. For lunch, categorizing some vegetables as restricted, and being so prescriptive in types of vegetables required to be served is again counter to the overriding message of consuming MORE and a variety of vegetable servings.

The recommendations do have merit, but need to reflect real-world constraints in addition to science-based suggestions. Again, the IOM report was recommendations, not policy. Policy should blend the most feasible recommendations with the final modifications.
Posted by: Jeff Rowe at 3/16/2011 5:16 PM


I agree with the comments above. The requirement that students must take a whole cup of fruit could be feeding the trash. If students are not taking enough fruits and vegetables, I think it would make more sense to offer more choices, not larger serving sizes. Require 2 fruit/veggie choices at breakfast, 1/2 cup each, student must select one. Require offering 3 fruit/veggie choices at lunch (1/4 -1/2 cup each), student must choose one, but could take 2 or 3 if they want them.
We are encouraging students to take food and throw it away. Offer vs serve means nothing as soon as students are required to put a specific food on their tray. If we offer a larger variety of fruits/veggies that certainly would encourage them to eat what they take. Even a double portion of what they like (which is not allowed at the present-- count as 2) A larger serving of veggies students do not like is not going to encourage students to eat more veggies. It's going to cost us more money, The 6 cents we are going to get (eventually) will come nowhere near covering our costs. Six cents will buy 1 slice of real whole grain bread. It will not buy more fresh fruits or more veggies. Only allowing 1 cup of a starchy vegetable for the entire week? What about those students who are under-fed? Do we really want to take away the favorite veggies, corn, because of a fear of starch? What about the fact that the students will TAKE and EAT the corn? Are we losing sight of the most important part of good nutrition? The students have to eat it in order for them to get any nutrition! I have to believe that bread and other grains also have a lot of starch, but they are required daily. Drinking water available where meals are served--who pays for this? NSLP? It is not part of NSLP and is actually competing with NSLP. Why take milk when you can get free water. Many elementary students will take water just because it is there. They won't drink it, they'll just play with it. ANd many high school students, if they truly want water, will not take tap water. They want bottled water. What about having these new standards gradually introduced into the NSLP by student grade. For example, sodium is an acquired taste. This could be introduced to elementary students fairly easily and let the requirement "grow" into the secondary schools.
Please, someone look at this bill realistically!
Posted by: Shirley Eagle at 3/17/2011 9:44 AM


SNA should request that USDA include in the Food Buying Guide tofu as an meat alternative so that vegan students are not limited to bean dishes only.

USDA claims that because FDA has not created a standard of identity for tofu it cannot be served. However, tofu is included in the USDA Nutrient Database so it makes no sense why tofu cannot be added to the Food Buying Guide.

Additionally, many in the school industry claim that tofu may contain more bacteria because it is held under water. I did a google search for food borne outbreaks for tofu and could find only one. In contrast, a google of search for food borne outbreak related to beef, poultry, pork or peanuts results in frequent recalls.
Posted by: Sharon Briel at 3/22/2011 4:04 PM


SNA should request that USDA provide a phase in period of 5 years for high school students.

The five year phase in period will allow current students unfamiliar with the new requirements to graduate. As students from primary school graduate to high school, these students will be familiar with the new requirements and more likely to participant.

To implement at the high school level without a phase in period will cause increased food waste and loss of participation. I fear that USDA will cause many self-op high school cafeterias to lose excessive amounts of money and/or be contracted out to a management company. I certainly hope this will not be the case. I am a director at an all high school district with 36,500 high school students.
Posted by: Sharon Briel at 3/22/2011 4:12 PM


I agree with my colleagues above. I think over production will lead to waste. In my 25 years in school food service time is the priority to students and at the middle and high level we have difficulty getting now getting them to take any item other than the entree and one other item and when they do many hand that item over to a friend. Also, why are we in this day and age of obesity are we forcing students to take food they don't want? why can't we have a meal pattern we can offer but they do not have to take a minimum? The child who wants every component can take but if a student only wants a small amount of food why force them to take more than they want? I too am concerned that those of us with outside meal service (grab n go) will be forced to return to ala carte sales not NSLP because we can't ensure the students are taking the required increased F&V components that are proposed. One big circle..alacarte to meals back to ala carte because we can't risk fiscal ruin.
Posted by: Christine Woods at 3/22/2011 5:00 PM


SNA should request USDA to remove the requirement that school meals must comply with nutrition standards for calories, saturated fat and sodium because the recommendation is inconsistent with their proposal for a Food Based Menu Planning System.

IOM and USDA officials both explain that students eat food not nutrients. However, this statement is inconsistent with the proposed regulations which requires that state agencies perform nutrient analysis for calories, % saturated fat and sodium every 3 years. The 2005 and 2010 Dietary Guidelines for Americans do not require that citizens analyze their meals for the amount of calories, % saturated fat and sodium. Instead the DGA makes recommendations in terms of the amount and type of food to eat and the foods to limit. I think that USDA should be consistent with their proposal for a food based system and not include a requirement to analyze the amount of fat, calories and sodium in school meals.
Posted by: Sharon Briel at 3/23/2011 7:44 PM


I challenge USDA to plan a menu to meet these standards. I also challenge them to do this in a way that won't harm participation rates nation-wide.

While I appreciate their efforts, my concerns are many.

If we're going to REQUIRE fruit at breakfast and lunch, let's start by requiring the current serving size.

Let's pilot all of these changes. I fear that programs will be unable to support themselves if these changes are signed into law. We certainly won't be able to depend on Federal, State, or local monies to support us.
Posted by: Laura Parker at 3/24/2011 12:10 PM


USDA should include in regulations that principals cannot limit the type and form of fruit provided to students. Often I hear the following request....please take off whole apples or purchase sliced apples because students are throwing the whole fruit at each other. Or...please stop serving raisins because students are dropping them on the floor and the custodians are unhappy.

If USDA requires that students take a piece of fruit/vegetable at each meal, I expect the number of requests from principals to increase.
Posted by: Sharon Briel at 3/24/2011 7:19 PM



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