After explaining to USDA officials the absurd lengths to which companies are asked to document products contain less than 3.99 grams of "uncreditable grains" including corn starch and oat bran, the Industry Roundtable submitted an alternative means to assure the benefits of whole grain rich requirements are realized in school food service purchasing.
The School Food Industry Roundtable recommends that USDA not define or limit “uncreditable grains”. Some of the items listed as “uncreditable” are considered by many to be worthy sources of fiber such as oat fiber and bran. Others such as corn starch or vegetable “flours” are not normally considered a “grain”. The FDA standards of identity for grains and enriched grains (21 CFR 137) can be referenced to create an objective and practical way to prevent a partial reversal of the gains in promoting whole grain, but allow realistic provisions for common food ingredients and sub ingredients.
A suggested policy was offered:
A serving of whole grain rich product contains 16 grams total grain, of which at least 8 grams are whole grain complimented by up to an equal amount of enriched grain as defined in the 21 CFR Section 137. Product or ingredients for which there is no whole grain version (oat bran, wheat germ, hominy grits, food starches or vegetables flours) and for which there is no standard of identity for an enriched version, may be served as an optional extra food, or as an ingredient of any food, but do not credit towards the whole grain rich meal component. The nutritive content of such products must be included in the nutrition analysis, and a whole grain rich product must be served in compliance with the regulations. Grain ingredients which are minor ingredients of non-grain food items (ie, bread crumbs in meat loaf, or flour used as a thickening agent for a sauce or filling) are not subject to the whole grain rich requirement.