VRG Nutrition Advisor Suzanne Havala, MS, RD, was interviewed on
a San Antonio radio program, "Eye on Health," about nutrition aspects of
vegetarian diets. She was also interviewed by Vegetarian Times magazine
for two upcoming articles. Reed Mangels, PhD, RD, was interviewed by Parade
Magazine for an article on diets.
September 11, 1998
Shanthy Bowman, PhD
US Department of Agriculture
Agricultural Research Service
Nutrient Data Laboratory
4700 River Road, Unit 89
Riverdale, MD 20737
Dear Ms. Bowman:
On behalf of the nonprofit Vegetarian Resource Group, I am pleased to
submit the following comments regarding the upcoming revision of the Dietary
Guidelines for Americans. Specifically, the VRG would like the Dietary
Guidelines Advisory Committee to consider these suggestions:
Thank you very much for considering these remarks.
Sincerely,
Suzanne Havala, MS, RD, LDN, FADA
Nutrition Advisor
Long awaited, progressive revisions to federal school meals regulations
were substantially weakened when school food service groups and others
lobbied and won legislation that superceded USDA's regulations and now
permits schools to continue to use the traditional meal planning approach
that had been in place for the past 50 years. Though school menus are mandated
to adhere to the Dietary Guidelines for Americans, which call for lower
intakes of total fat, saturated fat, and cholesterol, and higher intakes
of fruits, vegetables, and whole grains, the Agriculture Department itself
suggests that schools using the traditional menu planning approach will
find it difficult to meet these current nutrition standards. Traditional
school meals everywhere in the country have been found to be excessively
high in sodium, total fat, saturated fat, and cholesterol, and too low
in dietary fiber, fruits, vegetables, and whole grains. Nevertheless, the
Department now has to revise its school meal regulations to accommodate
the new legislation.
Included in the new legislation is a provision that permits schools
to use "any reasonable approach" in planning menus to meet nutrition standards.
Consumer groups and others have stated that the "any reasonable approach"
ruling will further weaken schools' accountability for meeting current
nutrition standards. The Department sought public comments on the interpretation
of "any reasonable approach." The following is a copy of comments submitted
to the Agriculture Department on behalf of VRG by Nutrition Advisor Suzanne
Havala. The call for comments and proposed rule changes were published
in the Federal Register, May 15, 1998 (volume 63, number 94), pages 27161-20118,
and are available from the Federal Register Online via GPO Access at http://wais.access.gpo.gov/ Mr. Robert Eadie, Chief
Re: National School Lunch Program and School Breakfast Program: Additional
Menu Planning Alternatives
Dear Mr. Eadie:
On behalf of the nonprofit Vegetarian Resource Group, I am pleased to
offer the following comments concerning the proposed regulations for "any
reasonable approach" to menu planning. Underlying VRG's comments is priority
consideration for maximizing flexibility in meal planning while favoring
conditions that will help to improve the nutritional quality of school
meals.
Single Age/Grade Grouping
Schools that opt to use the traditional approach to menu planning will
find it challenging to meet the Dietary Guidelines. Use of a single age/grade
grouping in this approach would further decrease the likelihood that traditional
school menus would meet nutrition standards. For this reason, the Department
should consider requiring traditional meal patterns to adhere to the same
age/grade groupings approach that is used in the Department's enhanced
food-based menu planning alternative.
Grain/Bread Requirement and Dessert Allowance
We feel that it would be inappropriate to permit credit of a grain-based
dessert as a daily serving of grains/breads in the traditional food-based
menu planning alternative. Considering the relatively small number of grain/bread
servings included in the traditional approach, we feel that a child selecting
dessert daily would be nutritionally disadvantaged by the displacement
of a valuable grain/bread serving for a less nutrient-dense food.
A compromise that might be considered would be to require that desserts
credited as grain servings must be at least 50 percent whole grain in composition
(oatmeal cookies or banana bread made with whole wheat flour, for instance).
In practice, however, this may be difficult to implement; thus our original
statement.
Weekly Meat/Meat Alternative Quantity Standard
For schools using the traditional food-based menu planning alternative,
we favor the allowance of flexibility to vary the quantity of meat/meat
alternate on a daily basis as currently proposed by the Department. The
requirement that a minimum of one ounce or its equivalent of meat/meat
alternate be offered daily is reasonable and will allow a wider range of
appealing entrees to be served.
We recognize the potential complication, in schools offering more than
one entree, that some children may choose items over the week that do not
equal the full weekly meat component requirement. We feel that the advantages
conferred by the flexibility to vary the quantity of meat/meat alternate
outweigh the potential disadvantages for the following reasons:
1) The flexibility provision will promote a wider selection of appealing
entrees, increasing the likelihood that children will eat the meal and
diminish problems of plate waste.
2) The meat/meat alternate component of the meal is one of the major
contributors to excessive amounts of total fat, saturated fat, and cholesterol
in school meals. Any nutritional disadvantage to a child eating less of
this component will likely be offset by the advantages of a concomitant
decrease in total fat, saturated fat, and cholesterol intake and an increased
intake of dietary fiber and nutrients associated with the foods that are
served in its place.
State Agency-Developed Systems
The VRG strongly favors the proposed requirement for a public announcement
when State agencies opt to develop their own menu planning alternatives
or make extensive changes to an existing system and remain an active and
on-going partner with the school food authorities. The announcement should
be followed by a comment period during which community members are encouraged
to submit written comments expressing their views. Additionally, we feel
that State agencies should be encouraged but not necessarily required to
hold public hearings on these alternative approaches.
Regulations for planning school meals are put into place in large part
to ensure the health and well-being of children in communities. Critical
to the successful implementation of community nutrition programs, including
school meals programs, is the involvement of a range of people from the
community. In particular, the community that is being served should have
a voice in the development of the programs that serve it. Students, parents,
interested health professionals, and others within the community must be
given an opportunity to participate in the process. The practice of including
the community in assessing its needs and developing policies to address
them is fundamental to good public health practice.
Monitoring Provisions
As the Department has acknowledged, use of the traditional menu planning
approach is likely to increase the difficulty of meeting Dietary Guidelines
and nutrient standards. For this reason, we feel it is imperative that
schools using the traditional alternative are monitored closely for compliance.
We are in agreement with the Department that monitoring provisions pertaining
to reviews of the enhanced food-based menu planning option should be extended
to reviews of schools using the traditional meal pattern.
Appendix A
In the context of the current proposed regulation changes, the VRG would
like to raise the question of the provisions of Appendix A in regulations
concerning the traditional menu planning approach. Appendix A requires
that foods fulfilling the meat/meat alternates requirement not contain
more than 30% of total weight from soy. This proscription is at odds with
current nutrition knowledge and is no longer in place in NSMP and ANSMP.
We recommend that Appendix A be deleted from regulations for the traditional
pattern.
We would like to see the Department consider crediting soy foods as
meat/meat alternate servings much the same way that yogurt was given credit
as a meat/meat alternate choice.
The VRG appreciates the opportunity to express these viewpoints and
thanks the Department for its consideration of our remarks.
Sincerely,
Suzanne Havala, MS, RD, FADA
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