1250 H Street NW, Suite 900 Washington, DC 20005 P: 202.737.4332 F: 202.331.7820 February 12, 2018 WWW.IDFA.ORG Angela Kline, Director Policy and Program Development Child Nutrition Programs Food and Nutrition Service P.O. Box 66740 St. Louis, MO 63166 Submitted electronically via: www.regulations.gov RE: Food Crediting in Child Nutrition Programs: Request for Information [Docket No. FNS- 2017-0044; December 14, 2017] Dear Ms. Kline: The International Dairy Foods Association (IDFA) appreciates the opportunity to provide comments to the Food and Nutrition Service regarding the crediting of food and beverages for Child Nutrition Programs, including school meals and the Child and Adult Care Food Program. We believe these programs are critical to the good nutrition and good health of Americans, particularly children and older adults, and that crediting ensures that the foods and beverages provided through the programs provide excellent nutrition. IDFA, based in Washington, D.C., represents the nation s dairy manufacturing and marketing industry, that employs nearly 1 million skilled individuals, generates more than $39 billion in direct wages and has an overall economic impact of more than $200 billion. IDFA is the umbrella organization for the Milk Industry Foundation (MIF), the National Cheese Institute (NCI) and the International Ice Cream Association (IICA). Our members range from large multinational organizations to single-plant companies. Together they represent more than 85 percent of the milk, cultured products, cheese, ice cream and frozen desserts produced and marketed in the United States and sold throughout the world. Our diverse membership includes numerous food retailers, suppliers and companies that offer infant formula and a wide variety of milk ingredients. Role of Milk, Cheese and Yogurt in Child Nutrition Programs It is vital that the crediting process supports the recommendations of the Dietary Guidelines for Americans (DGAs), to ensure that the Child Nutrition Programs overall align with the DGAs. The 2015-2020 DGAs report continued to advocate an increase in the consumption of low-fat and MAKING A DIFFERENCE FOR DAIRY
fat-free dairy foods by Americans. 1 Most Americans, including most school-aged children, are not consuming the recommended levels of dairy products. Even more concerning is the decline in consumption of milk in school meals. 2 While many preschoolers do consume adequate amounts of dairy, it is vital that programs such as CACFP keep dairy as an important component in order to continue this trend into later stages of childhood and adulthood. Children are a population of particular concern because nutrition during childhood can affect the development of chronic disease later in life and sets dietary preferences that can persist throughout life. Dairy foods have excellent nutrient density. Even those options that contain reasonable amounts of naturally-occurring solid fats, added sugar or sodium, may still have high nutrient density because of the levels of beneficial nutrients they provide. We believe that nutrient density is an important concept to encourage through the crediting process because a single, nutrient-dense food can provide a variety of nutrients that are essential for health. Focusing meals and snacks on nutrient-dense foods allows school food service and care providers to include more nutrients in a lower calorie diet. This focus not only aids in the consumption of beneficial nutrients, but also assists in energy balance and weight control. These issues all point to the important nutritional role of dairy foods, such as milk, yogurt and cheese. The predominance of lactose maldigestion is a real concern for many Americans, especially among certain sub-groups of the population. However, some Americans that have lactose intolerance may incorrectly believe that they cannot consume any dairy products. The 2015-2020 DGAs recommended low lactose or lactose-reduced dairy products, such as lactosereduced milk or yogurt and cheese, as a way for individuals to reduce their intake of lactose, yet still obtain the nutritional benefits of dairy. 3 This advice is doubly important when considering the 2015 DGAC s findings that a diet without dairy is lower in a variety of essential nutrients. Lastly, as pointed out by the 2015 DGAC report Dairy foods are excellent sources of nutrients of public health concern, including vitamin D, calcium, and potassium. Consumption of dairy foods provides numerous health benefits including lower risk of diabetes, metabolic syndrome, cardiovascular disease and obesity. 4 Milk 1 U.S. Department of Agriculture and U.S. Department of Health and Human Services. 2015-2020 Dietary Guidelines for Americans. 8th Edition, December 2015. Available at http://health.gov/dietaryguidelines/2015/guidelines/. 2 Prime Consulting. School Milk Information: From Milk Processor Education Program Data. 2015 Edition. August 2016. 3 U.S. Department of Agriculture and U.S. Department of Health and Human Services. 2015-2020 Dietary Guidelines for Americans. 8th Edition, December 2015. Available at http://health.gov/dietaryguidelines/2015/guidelines/. 4 2015 Dietary Guidelines Advisory Committee. Scientific Report of the 2015 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Health and Human Services and the Secretary of Agriculture. First Print, February 2015. 2
Milk provides nine essential nutrients, including three of the four nutrients identified as nutrients of concern in the 2015-2020 DGAs calcium, vitamin D and potassium. 5 In the 2015 DGAC report, modeling showed that replacing milk with other beverages significantly reduced diet quality. As an example of what occurs when milk is replaced by other beverages, the DGAC indicated that when milk and milk products are removed from sample diets in the USDA Food Patterns, levels of intake of calcium, vitamin A, vitamin D, choline, magnesium, phosphorus, and potassium become inadequate. 6 Flavored milks provide all of the same nutrients as white milk, but with a flavor that many children prefer. Flavored milks, like all cow s milk, are a source of 11 essential nutrients, including calcium, vitamin D and potassium. In a position paper from the American Academy of Pediatrics (AAP) about foods and beverages in schools, the AAP s Council on School Health and Committee on Nutrition declared that [c]onsideration of a beverage such as flavored milk provides a good example of the balance needed to limit added sugars and yet promote nutrient-rich foods. As the AAP paper on school foods highlights, schools that completely eliminated flavored milk found that less milk was consumed, meaning that kids were missing out on the nutrients from milk. 7 IDFA strongly supports fluid milk, both flavored and unflavored, remaining as an essential component of the Child Nutrition Programs including the National School Lunch Program and School Breakfast Program. Fluid milk should continue to be credited based on a volume basis. Cheese Cheese, like fluid milk and yogurt, is a nutrient-dense food, providing a good source of protein, calcium and phosphorous to children. Due to the high quality naturally occurring protein in cheese, it is included as a meat alternate in the Child Nutrition Programs. In addition to being a nutritious and healthy snack, cheese is also naturally low in lactose. Cheese is an excellent way of providing the nutrition of dairy foods to students who may not regularly consume fluid milk products because of their lactose content. One important benefit of cheese that cannot be overlooked is that it can help increase consumption of other nutrient-dense foods. A study of children s consumption of foods in a school cafeteria setting demonstrated that visible cheese served with another food, such as a 5 U.S. Department of Agriculture and U.S. Department of Health and Human Services. 2015-2020 Dietary Guidelines for Americans. 8th Edition, December 2015. Available at http://health.gov/dietaryguidelines/2015/guidelines/. 6 2015 Dietary Guidelines Advisory Committee. Scientific Report of the 2015 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Health and Human Services and the Secretary of Agriculture. First Print, February 2015. 7 Council on School Health and Committee on Nutrition. Snacks, Sweetened Beverages, Added Sugars, and Schools Pediatrics 2015; 135: 575; originally published online February 23, 2015. 3
vegetable, increased consumption of that food. While foods to encourage were increased during the study, the overall caloric intake in the meal was not increased. 8 Cheese should continue as an option within the meat and meat alternate group. It is a versatile food that can be served on its own as either a snack or side, or as an ingredient of a main dish for breakfast, lunch or dinner. It is a source of high-quality protein, while also contributing to dairy intake. Yogurt Yogurt is another nutrient-dense, natural source of high-quality protein. Most yogurt varieties available in the United States are either low-fat or fat-free. In addition to protein, yogurt can also be a good source of calcium, potassium, riboflavin, vitamin B12, and phosphorous. Some yogurts have vitamin D added. Additionally, yogurt is naturally low in lactose as a result of the culturing (fermentation) process. Many individuals who have trouble consuming large amounts of fluid milk, due to lactose intolerance/malabsorption, can usually enjoy yogurt comfortably, making this a food that is nutritious and appropriate for many children and adults. The nutrient profile and quality of the milk protein present in yogurt makes it an ideal component of the meat and meat alternate group in the meal and snack meal patterns. Yogurt is a nutrient dense food for both children and adults, even when there is some sugar added. For many people, added flavors and sweeteners make yogurt more attractive, meaning that they are more likely to increase their consumption of calcium, protein, potassium, vitamins A and D and other important nutrients present in each serving of yogurt. IDFA supports the continued inclusion of yogurt as a meat/meat alternate in the Child Nutrition Programs. However, at this time, IDFA is not providing comments on the level of crediting for yogurt. Fortification Should Continue to be Encouraged in Foods Eligible in the Child Nutrition Programs We agree with the food-based approach of crediting of foods in the Child Nutrition Programs but want to reinforce the key role that fortified foods play in helping children meet their nutrient needs including shortfall nutrients. Fortification should not disqualify foods from crediting. Fortified foods have a strong record in addressing the needs of the population by providing essential and shortfall nutrients to children such as calcium, vitamin D, and iron. Dairy foods, especially those fortified with vitamins A and D, play a unique role in providing shortfall nutrients. Fortified dairy foods should continue to be acceptable for Child Nutrition Programs as 8 Joseph E. Donnelly, EdD; Debra K. Sullivan, PhD, RD, LD; Bryan K. Smith, PhD; et al J Child Nutrition and Management, Vol 34:1, Spring 2010. The Effects of Visible Cheese on the Selection and Consumption of Food Groups to Encourage in Middle School Students. 4
long as they are consistent with FDA s fortification policy and the product meets all other nutrition standards. Foods are not credited based on their nutrient content in the current food-based system. Fortified foods provide a significant amount of nutrients, often added nutritional benefits, to foods and beverages that people are already familiar with and enjoy. In many cases, this fortification is governed by the standard of identity or other regulation. Low-fat milk is one such example, with vitamin D traditionally added to milk at levels set in the standard, and vitamin A fortification required so that the low-fat version is not nutritionally inferior to whole milk. Therefore, fortification should not exclude a food from crediting. Reduced Sugar Milk, and Other Foods Named by a Standard of Identity and Nutrient Content Claim, Should Qualify for the Child Nutrition Programs Standards of identity are commonly used as requirements for products to be included in the Child Nutrition Programs. Standards of identity are particularly useful for dairy products, since there are so many standards for dairy foods. In many cases, if a nutrient is altered in order to meet the claims such as low fat or reduced sugar, the product will no longer meet the standard of identity. However, nutrient content claims can be used in conjunction with the standards of identity to name the product, such as low fat milk or reduced sugar chocolate milk. One example of products commonly in use in the Child Nutrition Programs that are named through the use of a standard name and a nutrient content claim is low-fat and fat free milk. In fact, for the majority of children in CACFP and all children in the school meals programs, low-fat or fat free milk is required, while standardized milk (whole milk) is reserved only for 1 year old children in CACFP. However, another type of milk that makes a nutrient content claim, reduced sugar milk, is not provided for in the child nutrition programs. This claim is important because it provides a way for flavored milk to reduce sugar or calories through the use of non-nutritive sweeteners. Reduced sugar milk and other milks that use a nutrient content claim in their name should be allowed in child nutrition programs, as long as they meet the required fat levels. While schools would not be required to offer reduced sugar milk, it would provide additional flexibility for meeting the nutrition requirements of the child nutrition programs while also meeting the flavor preferences of the students that participate. Crediting of Foods with No Standard of Identity Products that do not have a federally defined standard of identity should still be allowed in the Child Nutrition Programs. A food or beverage should be judged on the nutritional value it provides, rather than whether it aligns with a standard of identity. While many dairy foods do have defined standards, there are some that do not. In order for these products to be included 5
in child nutrition programs, a USDA Commercial Item Description (CID) could be a useful basis for identifying the product and ensuring that schools receive a consistent product. For certain products that may have varying content that could affect the crediting, such as commercially prepared smoothies, the Child Nutrition Labeling program may be useful. When these products are destined for schools, they could request a Child Nutrition Label that verifies the amount of protein, milk, fruit or vegetables present. This would allow a school food service operation to properly credit the smoothie. Conclusion We appreciate the opportunity to provide comments regarding the Child Nutrition Programs crediting process. IDFA member companies are proud of the nutritious dairy products that are included in the Child Nutrition Programs and the important role that dairy plays in the diets of children. Please contact us if you have questions or would like additional information. Sincerely, Cary Frye Senior Vice President, Regulatory Affairs Michelle Matto, MPH, RDN Consultant to the International Dairy Foods Association AM Food & Nutrition 6