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Response to the interim ﬁnal rule, “Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements”
NOVEMBER 30, 2017
We are disappointed by the recent USDA rule to relax school nutrition standards. This move is an unnecessary threat to children’s health, given that widespread evidence indicates that healthier school meals have actually reduced plate waste without reducing school meal participation in many districts. Despite Secretary Perdue’s comments to the contrary, students today are eating, and enjoying, whole grain foods. Relaxing nutrition guidelines that are already being met is a pointless exercise, and September 2016 data from the USDA show that the vast majority of school districts are certiﬁed as complying with the school nutrition standards. This includes 100% certiﬁcation in states such as Alabama, Kentucky, and Mississippi — states that often don’t receive acknowledgement for meeting nutritional guidelines.
This announcement comes at a particularly troubling time, as a Harvard study published today in the New England Journal of Medicine estimates that 57% of today’s children will be obese by age 35. Our lunchrooms are a place to nurture students’ appetites for healthy food and properly fuel their growing brains and bodies. Thus, we urge policy makers to prioritize the health and wellbeing of the next generation, and to not backpedal on existing successes.
Response to the National Academies’ reports, Redesigning the Process for Establishing the Dietary Guidelines for Americans (September 2017), and Optimizing the Process for Establishing the Dietary Guidelines for Americans: The Selection Process (February 2017)
SEPTEMBER 22, 2017
We wholeheartedly support the National Academies’ suggestions to enhance transparency, manage biases, and promote sound science. That said, we feel it’s important to clarify that the widespread critiques of the DGA do not translate to a critique of the DGSAC (Dietary Guidelines Scientiﬁc Advisory Committee). The 2015 DGSAC report was met with widespread support from those immersed in nutrition research, as well as respected organizations including the Academy of Nutrition and Dietetics, the National WIC Association, the Union of Concerned Scientists, and the Center for Science in the Public Interest. Scientists from vegan to Paleo, and from low-fat to Mediterranean, pushed aside personal interests and lent strong, collective support to the DGSAC report at Oldways’ Finding Common Ground conference.
The National Academies reports devote numerous pages to the need for DGSAC to be free of bias, yet it is the translation from science to policy that deserves the most scrutiny. Although the DGSAC report is intended to serve as the scientiﬁc basis for the DGA, the translation from DGSAC report to DGA has repeatedly watered down the integrity of the ﬁnal report, as the policy writers, more so than the scientists, are subject to the most bias from industry stakeholders. We concur with the National Academies, that “If the DGA omits or only accepts parts of the conclusions in the DGSAC report, a clear explanation has to be given as to why.”
JANUARY 26, 2017
We believe strongly that overall diet determines health, rather than individual foods or speciﬁc nutrients. No matter what combination of nutrient criteria FDA might mandate as healthy, it’s inevitable that a reductionist approach will result in eﬀorts to “game” the system with fortiﬁed manufactured foods, while some whole, natural foods may fail to qualify. For instance, under the “current thinking” outlined in FDA’s September 2016 guidance, brown rice wouldn’t qualify to be labeled healthy – while the highest fat hamburger meat commonly sold (70% lean/30% fat) would qualify, as would the bun typically eaten with it.
In our comments, we advised FDA to follow either of two paths: 1) Don’t allow the use of “healthy” at all on packaging, or 2) Allow it only on whole plant foods. If FDA does allow use of the word “healthy,” Oldways recommends using it to highlight whole or minimally processed plant foods, which are especially encouraged in the 2015-2020 Dietary Guidelines for Americans – instead of tying use of the word “healthy” to a formula of nutrients.