This Is a Really BIG Deal, People: More on the New School Food Regulations

Yesterday I hastily posted about the USDA’s proposed new regulations for school food, but because I was burdened with a lengthy To-Do list and a doctor’s appointment that ran late, I don’t think I did this topic justice.  So let me lay it out in terms that will get your attention:

The new school food regulations – however they look in their final form — are a big deal.  They will dictate the food that does (and doesn’t) appear on millions of kids’ lunch trays for the foreseeable future.

Important, right?

The new rules run to 78 pages of tiny type, and  I’m only just starting to read them.  But here are two big changes that you should know about now:

Moving From Nutrient-Based to Food-Based Meal Planning

As outlined in my Schoool Lunch FAQs, school districts currently may use one of two methods to ensure their compliance with the program’s nutritional requirements.

The older method is called “Food-Based Menu Planning”, in which a school must offer five foods in every school lunch: a meat/meat alternative, grains/breads, two servings of fruits and vegetables and a milk.   This is the way the average person thinks about planning a meal in their own home: some foods from this group, some from that.

The second method, called “Nutrient Standard Menu Planning” allows a school district pay less attention to the foods served, so long as the requisite number of nutrients are offered over the course of an entire week.  According to Janet Poppendieck, about 30% of school districts (including Houston ISD) use the Nutrient Standard.   One consequence of using the Nutrient Standard method is the increased reliance by school districts on manufactured products and meals. Manufacturers can fortify and tweak their products so that they are compliant with the nutrient standard and can also offer what’s called a “CN Label” that indemnifies the school district should it later be found noncompliant with federal nutrition regulations.   The Nutrient Standard can also lead to some bizarre results:  my own school district served graham crackers — essentially cookies — to kids at breakfast because they contain iron (due to fortification) and that helped the district meet the nutrient standard for iron.  Crazy.

The good news (in my opinion) is that the new rules move us back to a primarily Food-Based standard.   The proposed meal pattern for breakfast would offer fruits, grains, meats/meat alternatives and milk, while lunch would include fruits, vegetables, grains, meats/meat alternatives, and milk.   (A nutrient standard does comes into play with respect to limits on things like sodium, saturated fats and trans fats.)

Calorie Maximums

Back in the 1940’s, when malnutrition was of greater concern than it is today, calorie minimums (but not maximums) were set for school meals.  These same minimums have been carried over to the present day, despite the fact that children now eat far more food outside of scheduled meal times than in the past.  Schools faced the difficult problem of meeting the calorie minimums without tipping over the limits on fat.  The result: lower fat but high sugar foods, like cookies and cakes, appearing regularly on lunch trays.

The new school food regulations would set both minimum and maximum calorie levels, which is welcome news to those concerned about both childhood obesity and childhood hunger.

* * *

I’ll continue to delve into the regulations (embarrassingly, this is enjoyable bedtime reading for the kid-and-food blogger!) and will share thoughts and insights with you in the coming weeks.  In the meantime, you may also want to check out Marion Nestle’s take on the regulations here.


  1. says

    Sadly it looks like more rearranging of deck chairs on the Titanic.
    Without food based education integrated into curriculum, and school gardens to help kids to fall in love with vegetables, our kids are sunk!

    Low fat mayo and chocolate skim milk. Hip hip hooray, USDA. The food industry continues to be able to laugh all the way to the bank.

  2. says

    I agree with Dr. Rubin. While I am all for progress I have yet to hear HOW this improvement are going to be supported.

    I believe it is next to impossible to cut food manufacturers out of the school food business. Particularly at this point when the NSLP is still so meagerly funded. Therefore, I would like to see VERY specific regulations and requirements be placed on the foods sold to schools. This would inspire manufacturers to be more creative and “clean” with the foods they market to schools in order to maintain the large amount of revenue those sales generate.

    Dr. Rubin is also right on re: nutrition ed. Without academic support changes will have much less of a chance of being effectual. Thus, leaving a lot of room for criticism and backlash.

  3. Maggie says

    I’m sad to say that I agree as well. The first thought I had about the dark green veggies requirement was that someone is going to come up with a dark-green vegetable based snack chip that will fulfill the requirement.

    Education would be good. So would a general atmosphere of support & respect for the meal programs as an important part of the day, as much as any other class or lesson. Is there a lack of respect because the programs are “bad”, or are the programs “bad” because there is little respect?

  4. Dana Woldow says

    Another angle little discussed thus far is the timeline for these changes. Here’s what the new proposed rule states
    “This proposed rule seeks to update the school meals for school-aged
    children to align them with the 2005 Dietary Guidelines and make them
    consistent with the DRIs (Dietary Reference Intake), as described in the IOM (Institute of Medicine) final report “School Meals: Building Blocks for Healthy Children,” which was published October 20, 2009 (see the report at As recommended
    by IOM, this proposed rule focuses on revising the meal requirements
    for the NSLP (National School Lunch Program) and SBP (School Breakfast Program). The new meal requirements seek to ensure that the meals planned by school foodservice providers and selected by students reflect the food groups emphasized by the 2005 Dietary Guidelines and
    meet the nutrient targets identified by IOM.”

    So, the new rule is based on aligning school meals with the 2005 Dietary Guidelines, which were actually developed during 2004. I have been told that the timeline for the new rule is likely to have it “finalized” some time in 2012. Final Rule will probably give the state agencies 1-2 more years to train school districts, and school districts 1-2 years to fully implement changes, with
    minimum standards for all school districts fully implemented by either September 2014 or 2015, just in time for the new Dietary Guideline for Americans to be released in December 2015.

    In other words, the “new” rule is based on what was believed to be sound nutritional practice in 2004, and may not show up completely in school cafeterias until 2014 or even 2015. It seems like, nutritionally speaking, we are still trying to play catch up.

  5. Joyce Slaton says

    Ms. Siegel, I sent you a message asking you to talk to me on this very topic for, we’ve been following the school lunch issue for some time now, not the least because several of us in the editorial office have kids at school. I assume that message went awry. Can you email me back and we could carve out a time to talk? Thank you so much.

  6. Gary Miles says

    I am a manufacturer of sustainable school lunch trays. At Trellis Earth, we make our trays out of plant starch and rice hulls. Our mission, is to offer a cost-effective alternative to current conventional plastics in food service items.
    Could someone advise me on where I could find the latest federal requirements regarding portions and possibly even tray dimensions etc.?
    Thank you so much.


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