NAMA submitted comments to the United States Department of Agriculture (USDA) on the National School Lunch Program and School Breakfast Program and Nutritional Standards for All Foods Sold in School as required by the Healthy Hunger-Free Kids Act of 2010. Below is a synopsis.
- NAMA’s Commitment to Healthy Choices: NAMA has had a long-standing commitment to providing Americans with nutritional information needed to make an informed decision when purchasing food and beverage from vending machines. Across the country, school and work vending accounts are looking to our industry and Associations to partner with them on health and wellness issues. To address this need, NAMA developed the Balanced For Life® and FitPick® programs to assist in the issue of providing “healthier for you” choices in vending.
- A Voice for our Small Business Members: NAMA understands and appreciates the goals of the USDA’s (The Department's) proposed rules on competitive foods sold in schools. However, NAMA believes that some of these proposed rules do little to help with childhood obesity and may place an undue burden on the vending industry, specifically those operating small businesses. Some small vending operators rely solely on school sales for their income while others rely on it for the majority of their income.
NAMA commends the USDA on inclusion of the Initial Regulatory Flexibility Act (IRFA) analysis. NAMA reminds the USDA that Vending and Food Service Management Companies are included as industry groups that may be more directly affected by the proposed rule than others. NAMA agrees that this rule will have a significant economic impact on a substantial number of small entities and urges USDA to perform a Final Regulatory Flexibility Analysis during the final rulemaking analysis
- School Campus Definition: USDA should clarify the definition of School Campus by amending it to read: “School Campus: all areas of the property under the jurisdiction of the school that are accessible to students during the school day, specifically excluding teacher’s lounges and similar areas restricted to faculty and staff." This would further clarify, in the rules, that these areas are exempt.
- School-Sponsored Fundraisers: The Department’s exemption allowing for school-sponsored fundraisers is supported by NAMA. However, NAMA suggests that allowances be made for distribution of items intended for school sponsored fundraisers during school hours to ensure that items are available to students prior to the time that they depart campus at the end of the school day.
- Specific Comments Regarding Food Requirements: NAMA is supportive of the sale of eligible food without any time and place restrictions. USDA should adopt food requirements that reflect the “vary by grade” level standard that was suggested for beverages. For example, proposed rules for beverages allow different size and caloric content by school grade level. Furthermore, the USDA should implement the NAMA FitPick® program, as it relates to food requirements, at all grade levels. The USDA should revisit and amend the sodium standard set forth in the proposed rule. NAMA contends that the sodium limitation is too restrictive and is not reflective of the 230 milligrams standard set forth in the AHG standards and there should not be any distinction between the competitive food items and those items allowed under the National School Lunch Program (NSLP).
- Specific Comments Regarding Beverage Requirements: NAMA supports the Department’s approach to provide a broader range of lower-calorie beverages to high school students and the availability of caffeinated beverages in high schools. NAMA recommends that USDA modify the proposed beverage standards in order to: maintain consistency with Food and Drug Administration (FDA) regulations); maintain uniformity and consistency within and among the proposed food and beverage standards; and allow the sale of a very limited number of additional beverages in schools.
Consistent with its treatment of food, USDA should permit the sale of all eligible beverages without any time and place restrictions. NAMA respectfully requests that USDA expand the water category for all ages to allow for carbonation and/or the addition of natural flavors (but not sweeteners whether caloric or non-caloric). NAMA also urges the USDA permit the sale of diluted juices (products comprised exclusively of 100 percent juice and water without added sweeteners) for all ages in order to give schools a reduced calorie option to 100 percent juice.
