Sandra Ford 2013-04-03 14:43:06
Participate in the Process Have you reviewed and provided feedback on USDA’s proposed rule for competitive foods? Most of you should be well aware by now that in early February, the U.S. Department of Agriculture (USDA) released a proposed rule applying specific nutrition standards and other requirements to foods and beverages sold in competition with National School Lunch and School Breakfast Program meals. These standards would affect all foods and beverages sold during the school day in vending machines, school stores and concession stands—as well as a la carte items sold in the cafeteria. As directed by the Healthy, Hunger-Free Kids Act of 2010, these are science-based nutrition standards consistent with the Dietary Guidelines for Americans. Generally, they stipulate that snack food items be lower in fat, sugar and sodium and provide more of the nutrients that kids need. This is a proposed rule. USDA has invited comments from all interested stakeholders, and any new regulation would not go into effect until a full school year has elapsed after the final rule is published. Visit www. schoolnutrition.org and look for the “Comment on Competitive Foods” link in the Highlights section to find the full text of the proposed rule, as well as related resources available exclusively for SNA members. Although the comment deadline, April 9, 2013, is rapidly approaching as this issue of School Nutrition goes to press, I want to share with you the details of SNA’s process and approach to responding to this proposed regulation. I also strongly encourage you to take these last few days and personally take advantage of USDA’s invitation to comment (see the box on page 86). Guiding Principles SNA’s Competitive Foods Task Force (for the complete list of members, see the box on page 86) met in late February to discuss the proposed rule. The group established guiding principles to help ensure that the Association’s final submitted comments take into account the varied needs and views of our diverse membership. An excerpted version of these principles follows. • The Task Force will engage in a transparent and open process focused on collecting views and information from SNA’s membership, providing ample opportunities and outlets for feedback. SNA members also will be encouraged to provide comments on their own. • The Association recognizes the need for a level playing field between school food authorities (SFAs) and other food sellers operating on school property during school hours. • We strongly believe that any requirements for competitive foods must be consistent with the current, updated meal pattern requirements for school meals and that they take into account such nutrition criteria as those for the HealthierUS School Challenge, current government dietary guidelines and existing state competitive foods laws, as well as others. • We recognize the need for the final rule to be flexible, simple and easy to implement. We also agree with USDA’s stipulation that allows state and local authorities to apply more stringent standards as desired. • SNA will recommend that USDA minimize the additional responsibility of any increased and undue burden that is a consequence of the monitoring of competitive foods compliance by SFAs. School nutrition program directors should not be responsible for any penalties that are accrued for decisions made beyond their control. • SNA’s official comments will take into consideration the diversity of school programs, including size and geography. The Association also champions the wisdom and benefits of maintaining participation in the federal child nutrition programs. We understand that increasing the burden on SFAs while also possibly impacting revenue could lead certain schools to consider withdrawal from program participation. • The Task Force will be held to SNA’s mission to provide nutritious meals and nutrition education for children. School nutrition directors are best-equipped to make school-based nutrition decisions for students. Collecting Feedback The Association has worked to provide its members with a variety of resources to help them understand the implications of this complex proposed regulation. Among these was a Webinar Wednesday presentation featuring several USDA representatives. The presentation (archived online at SchoolNutrition.org; click on “Careers & Education” and follow the links) provided background, definitions, a summary of the proposed rule, exemptions, recordkeeping, agency monitoring and instructions for commenting. In addition, SNA scheduled dedicated “listening session” opportunities at last month’s Legislative Action Conference in Washington, D.C. Plus, the Association created an online tool for members to provide specific feedback on various provisions in the regulation. For example, members are invited to explain their positions on the effect of water availability during lunch or afterschool snack service, recordkeeping, fundraiser restrictions, nutrition standards, side dishes sold a la carte, beverages, administrative reviews, definitions of recognized during the program. Plus, reserved tables will be made available to you and other members of your home state who attend LAC. Complete details about how to comment and ensure that your comment is submitted both to USDA and to be eligible for SNA’s drawing will be available at www. schoolnutrition.org. competitive foods, school campus, school day and combination foods and more. Timeline On February 27, on behalf of the SNA Board of Directors, I sent a letter to Agriculture Secretary Tom Vilsack respectfully requesting that USDA grant a 60-day extension of the comment period. Given the complexity of the proposed regulation and the ongoing implementation of the new meal patterns, SNA’s leadership believes that its Association members need more time to review, analyze and provide comprehensive comments on the proposed regulation. At press time, USDA had not acceded to this request, and the Association was moving forward with plans to submit its comments and share these with the SNA membership. I cannot urge you in strong enough terms to take some time to draft your own feedback on this issue and provide it to USDA before the expiration of the comment period. SNA is committed to identifying recommendations that best reflect the needs of our membership, but given our diversity, it is impossible to identify a one-size-fits-all solution that will be right for every school, district and community, as well as for all our vendor partners and allies. Only you can articulate how this proposed regulation likely will impact your program and business. USDA is committed to reviewing all of the comments that it receives on this issue. Make sure your voice is heard. Raise YOUR Voice Although SNA has completed the process of collecting feedback from members to draft its official comments to the proposed regulation on competitive foods, every Association member and School Nutrition reader is encouraged to submit your own comments directly to USDA. Only you know how this rule will affect your school or business. As an incentive, SNA will randomly select two winners from individually submitted comments from SNA members to each earn a trip for two to LAC 2014! The winners and their companions will enjoy free registration, hotel stay and travel, as well as being recognized during the program. Plus, reserved tables will be made available to you and other members of your home state who attend LAC. Complete details about how to comment and ensure that your comment is submitted both to USDA and to be eligible for SNA’s drawing will be available at www.schoolnutrition.org. Competitive Foods Task Force Chair • Sandra Ford, SNS, SNA President Members (Operators) • Paul Becker, O’Fallon, Mo. • Marilyn Briggs, PhD, SNS, Davis, Calif. • Cynthia Brooks, Seymour, Conn. • Becky Domokos-Bays, PhD, SNS, Alexandria, Va. • Sara Gasiorowski, SNS, Indianapolis, Ind. • Chris Kamradt, Houston, Texas • Jean Ronnei, SNS, St. Paul, Minn. • Megan Schaper, SNS, State College, Pa. • Wendy Weyer, SNS, Seattle, Wash. Members (Industry) • Ami Childers, PepsiCo Foodservice • Pat McCoy, SNS, Schwan’s Food Service, Inc. • Gary Vonck, KeyImpact Sales & Systems Member (State Agency) • Lynn Harvey, North Carolina Board Liaison • Leah Schmidt, SNS, Kansas City, Mo. Staff Liaisons • Cathy Schuchart, SNS, SNA • Roger Szemraj, Olsson, Frank, Weeda, Terman, Matz, PC Sandra Ford is SNA president and chair of SNA’s Competitive Foods Task Force.
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