Comments on USDA Proposed Standards for Snack Foods and Beverages Sold in Schools

The Kids' Safe and Healthful Food Project (KSHF) is excited that more than 200,000 people all over the country submitted comments to the U.S. Department of Agriculture (USDA) encouraging strong nutrition requirements for all foods sold in schools, including snacks and beverages. Following is a summary of those KSHF submitted to USDA on the proposed rule.

For the first time in more than 30 years, USDA is updating nutrition standards for snack foods and beverages sold in schools. This proposed rule complements USDA's standards for school meals, which took effect this school year.

Childhood obesity rates have more than tripled in the past three decades. Despite recent improvements to nutrition standards for school meals, the snack foods and beverages available to students are still largely less-healthy items like sugary drinks, salty snacks, and candy. It is time that ALL foods sold and served in schools are healthy for kids. This is a common-sense approach that strengthens the investment parents and taxpayers have made in our children and our schools.

Parents Want National Snack Standards

A 2012 poll found that 80 percent of parents support setting national standards for snack and a la carte foods and beverages. They are concerned about children's health and want to make sure we are setting kids up for success.

These proposed guidelines have the potential to make a major difference. They would ensure that when kids make choices about snacks and drinks, the options they choose from are healthy ones – whether sold as a la carte items in the cafeteria, in vending machines, or in school stores. These items are a big part of what our young people eat — roughly 40 percent of students buy a snack at school every day.

Even if students eat a healthy lunch, research shows they often still consume excess calories from a la carte items the cafeteria might serve, such as french fries or ice cream. Sometimes kids skip a healthy meal entirely in favor of less-healthy snacks.

Strengthening the Smart School Snack Proposal

We commend USDA for proposing strong standards that will promote students' consumption of healthy foods, such as fruits, vegetables, whole grains, and non-fat and low-fat dairy products, as well as limit calories, fat, sugar, and sodium in snack foods and beverages. These standards support what parents want and they support the recently updated standards for school meals.

There are certain areas of the rule that we recommend USDA consider strengthening, such as:

• We urge USDA to ensure that all foods meet these standards, including items sold a la carte in the cafeteria, regardless of whether or not they're sold in a regular school meal. Exceptions would create a loophole that will result in increased access to and consumption of less-healthy foods by students.
• Similar to reimbursable meals, we advise USDA to implement calorie limits for snack foods and beverages that are tiered based on grade level. Calorie needs change as children grow. While 200 calories may be a reasonable limit for secondary school snacks, 200 calories is a significant portion of daily calorie needs for an elementary student.
  We propose:

• 100 calories in elementary schools (grades K-5)
• 140 calories in middle schools (grades 6-8)
• 180 calories in high schools (grades 9-12)

Food companies are already making snacks that would fit these standards.

We agree with the rationale to offer some flexibility in beverage choices in high schools, but are concerned that sugary drinks are far less healthy than other options. To ensure the healthiest options are available, we recommend setting a limit for calories per container that is as low as possible.

Areas of Support

• We agree that the rule should apply to all foods and beverages sold throughout the school day (until at least 30 minutes after school ends) and across the entire school campus. The same rules should apply inside and outside of the cafeteria throughout the day.
• Foods sold in schools should meet strong standards for calories, fats, sugars, and salt, as well as provide students a positive nutritional benefit. This can be done by serving fruits, vegetables, whole grains, or foods that naturally contain meaningful amounts of a nutrient of public health concern (i.e., calcium, potassium, vitamin D, or dietary fiber).
• We support allowing no more than 35 percent of foods' calories to come from total sugars, as recommended by the Institute of Medicine.
• The standards should be applied to foods and beverages as they are packaged and sold to children (i.e., one bag of chips should count as one serving).
• Schools should make potable water readily accessible to children at no charge during the school lunch and breakfast meal service.
  For more information, see our detailed comments to USDA on the proposed Smart Snacks in Schools rule.