Let USDA know what makes the School Food Service Market so complicated!

USDA asking for input!


On Dec. 14, 2017 USDA published a notice seeking public input about the the policies governing how USDA "credits" foods toward the school lunch requirements.  These policies may,  or may not be clearly explained in official documents, and complicate the school market for food manufacturers as well as school food service professionals.  .  In the media release, Branden Lipps, a new Trump Administration Official at USDA, expressed an interest in listening to stakeholders to gather ideas to help maximize program operators ability to serve health appealing meals to students. Comments should be submitted online through Feb 12. 

Industry Roundtable has discussed several recommendations over recent years to address crediting complexities:
Eliminate the watermark requirement for CN Labeling

USDA policy requires companies presenting CN labels statements on product information sheets to include a water mark saying the document cannot be used for meal pattern compliance. This creates great confusion as that is precisely what the CN label statement is for. The result has been a persistent requirement for product formulation statements, for CN labeled products, despite USDA instructions to the contrary. To provide equal assurance the product purchased matches the CN statement on the product information sheet, the State Auditor should spot check what is in the freezer and what schools have on their menus.

Reduce Requests for Product formulation Statements

Proactively train state auditors and school foodservices to only request or require product formulation statements for combination products/multi ingredients for which for meal pattern contribution cannot be calculated based on the Food Buying Guide alone. Eliminate the sample product formulation statement for grain items that are calculated based on the bread grain grouping In the Food Buying Guide as this creates an expectation that a Product formulation statement is needed.

Eliminate the Product formulation statement for grains calculated based on bread grain groupings. It is not necessary.

Eliminate the definition and calculation of “uncreditable grains”.

Since “uncreditable grains” are simply not creditable and have since been allowed in exceed the one time limit of 3.99 g. or less per serving, there is no benefit from calculating the precise quantity. Eliminate uncreditable grains calculation form the Product Formulation Statements. Items that are snot defined as creditable, are not creditable, if oat bran is not on the list of Whole or enriched grains, then it is not creditable – but its presence doesn’t need to be specifically identified, calculated or limited.

Update and Revise the Whole Grain Resource Guide

1) The flow chart should be changed to shows CN Labeled as the firs step of identify whole grain rich compliance, not a last step.

2) Correct examples that show product formulation statements (Based on bread /grain groupings) . They can be credited toward the meal pattern based on the Food Buying Guide alone.

3) Define only creditable whole grains and enriched grains that contribute toward the whole grain rich requirements with the understanding that anything that is not defined as creditable, is not creditable, and does not require definition or to be calculated. 

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Phillips Resources provides technical and government relations services to the institutional food service industry selling to the federally funded and regulated school lunch program. Whether your company is large or small, new in the school food service market or experienced, Phillips Resources can help your company maximize the opportunities and minimize the hindrances of this complex market place. More