New USDA School Lunch Rules Limit Even Healthy Choices

by Dana Woldow on August 7, 2012

All news from London this week seems to have an Olympics connection, but London makes me think of food. Specifically, I think of two chains of soup-salad-and-sandwich takeaway shops which set a high bar for providing quick, healthy and reasonably priced meals. Frequent meals from these shops on a recent London visit got me thinking – could this be a new model for school lunch?

The two chains are Pret A Manger and EAT. Their shops, which are plentiful in London, carry a large variety of choices for breakfast, lunch and quick light dinners. The food at both chains is addictively fresh and delicious. A school lunch menu wouldn’t have to offer the same large variety; the key is the freshness of the ingredients. Still, the soup-salad-sandwich model could provide a much greater degree of choice than students currently have, especially at elementary schools.

The USDA nutritional requirements for school meals have changed as of July 1, requiring additional and more varied vegetables, more fruit, and more whole grains. But nothing in the voluminous requirements of the Healthy Hunger Free Kids Act mandates that school lunch must always be hot.

Here’s my vision for a new style school lunch menu. The cafeteria would offer a daily choice of two or three sandwiches, cut in half with each half packaged separately. A daily soup, and choice of two or three salads, each in a half portion, would also be offered, along with fruit and milk.

Each entree choice – every half sandwich, small cup of soup or salad – would fulfill half of the nutritional requirements for meat (or meat alternative), grain, and vegetable. Students must choose two entree portions, along with their fruit and milk, and since each entree portion fulfills half the requirements, their choice of two means that all requirements are covered.

But the choice is entirely up to the student! One student might choose half a sandwich and a serving of soup, while another chooses two different salad portions, and yet another selects two sandwich halves. Even with a minimum offering of two sandwich varieties, two salads and one soup, elementary school students would have 15 different possible choices for their lunch; in my school district, elementary school students currently have only one choice (although a vegetarian option can be preordered.)

For over 100 years, school lunch programs have focused on providing a hot meal. But is that really necessary? So many of the complaints about school lunch – the “what-the-heck-is-it” mystery meat, the mushy texture of the cooked veggies, the too-frequent use of sodium, artificial ingredients, and preservatives – are all problems which could vanish with the introduction of a made-fresh-daily lunch menu based entirely on the sandwiches / soups / salads model of the successful British chains.

I’ve criticized people who suggest that to fix school food, schools should “just” do this or that one thing, which they claim would be easy and inexpensive, because those EZ fixes rarely turn out to be feasible. To determine if my new style school lunch idea was a “just do this easy thing” non-starters, I spoke with Sophie Johnson, menu planner for Choicelunch, a healthy school lunch provider based in Northern California. I explained my idea and asked her if she thought such a plan would be workable under the new USDA lunch regulations.

She responded: “Yes, I think with very careful planning it could be done. The fruit and milk are simple and check the boxes. The salads, soups and sandwiches are trickier, but doable. Each one of the half portions would have to be EXACTLY 1 serving of grain and 1 serving of protein, with the rest being veggies (or fruit), and all of the sub veggies would have to be met.”

However, she explained that the regulations set both minimum and maximum amounts for grains and meat (or meat alternative, such as beans or tofu, which as of July is for the first time allowed to be counted as a protein in school meals.) For grains, the weekly maximum for elementary students is 9 one-ounce servings. This means that my idea would only work for elementary school students if it were limited to 4 days per week; with each entree portion containing an ounce of grain, taking 2 entree portions per day over 5 days would mean students would be choosing 10 grain servings over the course of the week, exceeding the maximum allowed.

This maximum amount of grains and meat which could be offered over the course of the week will likely be news to most people. After the Healthy Hunger Free Kids Act was finalized, the media swarmed all over the famous “pizza as a vegetable” and unlimited potatoes provisions. Also mentioned were the requirements for more fruits and vegetables, phasing in whole grains, limiting fat content in milk, and setting a first-time-ever maximum on calories.

What the general public is unaware of, but school nutrition directors are coming to realize, is that the limits on grains and meat may result in meals which look a bit, well, skimpy to students used to larger servings.

Choicelunch’s Johnson, who follows USDA regulations closely, says that it wasn’t until she read the guidance memo from the USDA dated April 27, 2012, that she became aware of just how tight those limits are. She explains that for K-5 students, total portions per week must come in at no less than 8 oz and no more than 9 oz for grain, and at no less than 8 oz and no more than 10 oz for meat/alternative. Consider that the smallest size commercially produced hamburger patty is 3 oz – that’s almost ⅓ of a child’s maximum allowable weekly meat right there.

As Johnson says, “My 4 year old son eats more in one day than what an entire week’s worth of lunches are supposed to contain for grains and meats!” and she concludes “Kids may be seeing more volume in the food because of more fruits and veggies, so I don’t think they are going to think they are being starved, but … I think the servings for meat and grains will really be seen as petite.”

I think what Johnson means is that for elementary students whose favorite lunch is a slice of pizza or a cheeseburger, the sizes of those items may shrink, while the size of the portions of fruits and vegetables served alongside will expand. Students used to skipping the fruit and vegetables (which was allowed in school meal programs operating under a policy, mandatory for high school but optional for younger students, called “offer vs. serve”) will now be required to take at least a ½ cup serving of one or the other. Those who toss the fruit or veg in the trash and eat only the grain and protein may find themselves still hungry at the end of the meal.

Elementary students who love fruits and veggies will have no trouble filling up at lunch time, because cafeterias will be required to offer them at least 3.75 cups of vegetables per week, or 3/4 cup per day. Bad news for those who only love french fries or corn, though – those “starchy” vegetables can comprise only one of those 3.75 cups. The rest have to be dark green (think spinach, romaine, and kale), red/orange (carrots, winter squash), legumes (dried beans and peas), and “other” (tomatoes, green beans, cucumber, etc.), and each of those groups must be served every week. Elementary students will also get at least ½ cup of fruit with lunch.

If the goal was to make sure kids aren’t putting just pizza, cheeseburgers, or hot dogs and french fries on their tray each day, the new rules make sense. Between the tight limits on grains and meat, the enforced variety in vegetables, and the requirement to take at least a minimum serving of fruit or veg each day, we may have seen the last of the daily pizza-and-french-fries school lunch.

However, if the goal was to help students learn how to make healthy choices, and to have some say over what they put on their lunch tray, then the new rules leave something to be desired.

I assumed my model for school lunch choice would include sandwiches garnished with dark leafy greens to meet the vegetable requirement; remember that each sandwich half was supposed to meet half the requirement for grain, meat/alternative, and veg. But according to the USDA guidance, “a ½ cup of Romaine Lettuce contributes [only] ¼ cup toward the ‘dark green’ vegetable subgroup.” In other words, although the required minimum for all other vegetables is ½ cup, the minimum for raw leafy greens is actually a full cup.

To ensure that a student who chose two sandwich halves for their lunch got the required minimum serving of dark leafy greens, each half sandwich would have to contain ½ cup of romaine, literally dwarfing the one ounce of sliced turkey (one or two thin slices) which is the maximum portion of meat allowed in an entree aiming to satisfy half of the meat/alternative requirement.

Then there were those weekly legumes. I planned to meet that requirement by offering hummus in a pita half, garnished with tomato and cucumber, but it turns out that if you count the hummus as a vegetable, then you can’t also count it as a meat alternative in the same meal. A hummus / cucumber / pita half could meet the requirement for meat/alternative, veg, and grain if it contained sufficient cucumber (“other” vegetable) and counted the hummus as a “meat alternative,” but then the hummus couldn’t count as the required weekly legume.

Trying to make this work makes my head spin, and inspires renewed respect for people I already held in high regard: the student nutrition staff who do make these regulations work. It shouldn’t have to be this hard. The old system was easier – a serving of grain, at least 2 oz of protein, a fruit, a veg, milk. But that system was abused, with some schools serving nothing but potatoes or corn for the veg, and lots of fatty meat, and pizza every day. Now we have everything spelled out in detail to make sure the kids get a variety of veggies and limited amounts of pizza and burgers, but it has limited student choice too, and not just bad choices.

Justin Gagnon is the CEO of Choicelunch, and as the name implies, his company is based on providing students and their families with a lot of different healthy choices for their school lunch. He sums up the new USDA rules thus:

“These regulations simply do not support programs that offer choices. Menu planning when you’re using fresh, real ingredients is hard enough. They’re throwing out SO MANY REGS right now, that it is nearly impossible to actually execute on a solid menu with real choices and still nail every single one of their requirements.

When you spend so much time and energy trying to guarantee that bad practices are prohibited, you end up blocking out some really good practices that go against the status quo, but aren’t yet on your radar. It’s not innovation if you’re not breaking rules, and these regs stifle innovation in an industry that desperately needs it.”

Dana Woldow has been a school food advocate since 2002 and shares what she has learned at Follow her on Twitter @nestwife.

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