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Vegetarian Journal Mar/Apr 1999

Notes From The Scientific Department



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.

VRG Presents at Dietary Guidelines Summit

The Summit on the Dietary Guidelines 2000: Issues for the Fifth Edition was held in Arlington, VA, on September 18, 1998, and was sponsored by Georgetown University Medical Center and the Physicians Committee for Responsible Medicine. Vegetarian Resource Group nutrition advisor Suzanne Havala presented a session titled "Separating Nutritional and Commercial Issues in Nutrition: the Example of Dairy." The summit was held only weeks before the Dietary Guidelines committee members met to begin discussions about possible revisions to the recommendations, which serve as the cornerstone of all Federal nutrition programs. A public comment period preceded the meeting; comments submitted by VRG are reprinted below:

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.


Suzanne Havala, MS, RD, LDN, FADA
Nutrition Advisor

School Meals Advocacy Continues

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regulations were substantially weakened when school food service groups and others lobbied and won legislation that superceded USDA's regulations and now permits schools to continue to use the traditional meal planning approach that had been in place for the past 50 years.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

Mr. Robert Eadie, Chief
Policy and Program Development Branch
Child Nutrition Division
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Alexandria, VA 22302

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.


Suzanne Havala, MS, RD, FADA
Nutrition Advisor

Excerpts from the Mar/Apr Issue

The Vegetarian Journal published here is not the complete issue, but these are excerpts from the published magazine. Anyone wanting to see everything should subscribe to the magazine.

This article was converted to HTML by Jeanie Freeman

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