The National School Lunch Program (NSLP) has provided meals to students since 1946, and currently serves over 30 million children. It is overseen by the United States Department of Agriculture (USDA). If you thought the recent news about possibly tainted beef in school cafeterias indicated some problems with the NSLP and its overseer, the USDA, you’d be right. Failure to guarantee the safety of food served to schoolchildren is merely the latest problem to surface. Here are some others:
10. Requiring each child to hold their own lunch card results in spread of germs.
This NSLP regulation drives teachers of younger kids crazy. It says that each student must hold their own lunch card, which bears a code specifying the student’s eligibility for lunch – free, reduced, or paid. Each child’s eligibility must be recorded by a cafeteria worker in order to collect government reimbursement, but why must each child physically hold the card in their hand?
Some teachers feel that students handling the cards, which are then bundled together at the end of the line, spreads germs from all the cards to the students, increasing pupil absenteeism due to illness. Is there a compelling reason why the teacher could not hand the cards to the caf worker as students pass through the line, and then retrieve them, so that the children wouldn’t have to touch them at all?
9. Offer vs. serve means adults cannot hand students fruit, milk, bread, or any other meal component.
In order for a school lunch to qualify for government reimbursement, the cafeteria “offers” 5 meal components (protein, grain, fruit, vegetable, and milk) and the student must choose at least 3 of the 5; however, the operant word is “choose.” The student must reach out and select the items he wishes to eat himself – an adult may not give him milk, or an apple, or anything else (that would be “serving” rather than “offering.”) Some teachers, aware that their students will not get much dinner, try to get them to fill up at lunch. But if they hand the food to the students, or even put a plate of bread to share on a table where students are eating, it violates USDA policy.
8. The list of “foods of minimal nutritional value”, which are disallowed in school cafeterias, is a very short list.
It is comprised only of soda, water ices, chewing gum, sugar coated popcorn, and a few specific types of candies made almost entirely of sugar or other sweetener, such as hard candy or licorice. Flaming Hot Cheetos (or other snacks of the chips variety), Kit Kat bars (or any other popular candy bars), Capri Sun (or other mostly water/sweetener) “juice” drinks, fried pork rinds, Slim Jims (not to be confused with real beef jerky), chocolate covered double stuffed Oreo cookies (as well as any other type of cookie) – none of these are considered to be “foods of minimal nutritional” value, and all are permitted for sale in the cafeteria under current USDA regulations. A food need only contain 5% of the recommended daily allowance of one nutrient to avoid the FMNV list, yet surely no one believes that fried pork rinds contribute to proper nutrition for children.
7. Overt identification – now you see it, now you don’t.
The USDA is all over the place on this one. Technically, “overt identification” is anything that makes it clear to an onlooker that a student is receiving a meal. Any system which involves the use of cash by students paying for their cafeteria meals is “overt identification” because it makes clear that those not paying cash are getting free meals. The use of colored tickets, or any other system which has one group of students handing over, in exchange for the meal, something different than another group of students, is overt identification.
But the USDA has no problem with schools operating a la carte food sales; such sales do not have to be of complete meals, like the free lunch, but can instead be just snacks like Gatorade and potato chips. These a la carte items are sold separately and are not available as part of the free lunch, Clearly students purchasing them are paying customers, while those choosing the school lunch are likely to be getting free meals, yet cafeterias selling a la carte is not considered “overt identification.”
In fact, it was the USDA which, in the 1980s, began encouraging schools to sell these very popular and profitable snacks, as a way of generating more money to support the free lunch program. Concurrently, the federal government eliminated the funds previously available for schools to replace aging or broken cafeteria equipment (no such fund has existed now for over 20 years.) The USDA did specify that foods of minimal nutritional value (see #8) could not be sold in the cafeteria or anywhere that NSLP meals were served or eaten, which led some schools to open separate a la carte facilities, so that they could sell soda and still comply with USDA regulations. This apparently is not a violation of “overt identification” – indeed, how could it be, when the USDA both encouraged the sale of soda and also prohibited it from being sold in the caf – but surely an impartial observer would conclude that the students lining up to buy the USDA-approved a la carte snacks were not free lunch students.
6. USDA meal regulations limiting sugar and fat apply to weekly averages, not individual components.
This means that high-fat fried chicken nuggets (over 60% of calories come from fat in some nuggets) can be averaged with green beans, fruit, bread, and low fat milk, to produce a meal which has less than 30% calories from fat, as the USDA requires. However, as students can take as few as 3 of the 5 meal components, there is no way to prevent the child from leaving the fruit and the vegetable, taking only the nuggets, bread, and milk, and consuming only the nuggets and milk, thereby ingesting far more than 30% calories from fat.
Likewise, the USDA allows the totals to be averaged out over the whole week’s worth of meals, so that a higher fat entree like chicken nuggets can be offset by a lower fat meal served later in the week. But there is no way to guarantee that students who ate the nuggets meal also compensated later in the week by eating the lower fat meal. So even offering school meals which meet all USDA regulations for fat and sugar content still doesn’t necessarily result in students who are well nourished.
This is why the SFUSD has stricter standards, designed to ensure that each entrée alone (not averaged with all meal components, and over the course of a week) meets the USDA limit for fat; snacks and side dishes must meet USDA limits for fat and sugar, and also are required to contain at least 5% of 8 essential nutrients.
5. Tofu is not allowed as the required protein component of a meal, limiting vegetarian options and making a variety of vegan reimbursable meals almost impossible to provide.
Both peanuts and peanut butter are allowed; I guess the USDA is unaware that some children have such severe peanut allergies that if the cafeteria were to serve peanut butter sandwiches for lunch, they wouldn’t be able to come to school at all that day (SFUSD does not serve peanuts or peanut butter in school meals.) Beans are allowed, but most students don’t want to eat beans for lunch, not even in combination with hot dogs, so that leaves cheese as the most common vegetarian option. Students who don’t or can’t eat cheese, either because of lactose intolerance or vegan preference, are simply out of luck.
4. Commodities on which districts must depend are often of low quality or high in fat.
The commodity program doesn’t really exist to help support better nutrition for children, but rather to provide price supports for agriculture. After all, that’s what the A in USDA stands for (and there is nothing in that name that refers to kids.) Want to make sure the price of milk stays high? Just buy up the excess milk (in years when there is an excess) and turn it into the famous “government cheese,” which can then be distributed as a commodity to schools. Not enough milk one year? Well, then there may not be any commodity cheese the next year.
Same thing with beef, poultry, pork, and a slew of other commodities. They are dumped into the lunch program in bountiful years, and disappear when supplies get scarce. A lunch program designed with the kids’ nutrition in mind would provide a wider selection of reduced fat cheeses, and higher quality meat, as well as fresh locally grown produce, instead of canned fruits and vegetables. It would protect against the use (even by mistake) of tainted beef in school lunches.
3. Food not sold or served by the end of the meal period must, in most cases, be thrown away.
It cannot be given away to children who are still hungry at the end of the day (and who might welcome a heartier snack at their after school daycare program), nor taken home to feed their hungry families.
2. The government reimbursement for free and reduced price meals is woefully inadequate in high cost-of-living areas.
The federal reimbursement for a meal served to a student qualified for free lunch in the 48 contiguous states is $2.49 (Alaska and Hawaii get more), which, along with about 22 cents more coming from the state, must pay for every single cost of running the SFUSD school meals program, not just the food. Maybe that's enough in a lower cost of living state like Kentucky, but here in San Francisco, after labor, garbage collection, pest control, utilities, supplies like tin foil and paper towels, and the costs of running the Student Nutrition Services office are all figured in, only about $1 is left for food. Try serving any kind of complete meal for $1, let alone a nutritious tasty one made from the fresh, locally grown food students and parents prefer. School districts located in higher cost of living areas should get high reimbursement, just as Alaska and Hawaii do.
1. The cutoff for eligibility for reimbursable meals is unrealistically low for high cost-of-living areas.
Imagine a family of 4 in San Francisco - two children, and two parents each working 40 hours per week at minimum wage jobs. Believe it or not, these parents will exceed the amount of income they can earn and still qualify for reimbursable meals for their children! The cutoff for eligibility for this hypothetical family is $38,203, but their 40 hour work weeks at SF’s minimum wage of $9.36 an hour would earn them $38,937. Impossible to imagine parents raising two kids in SF on under $39,000 a year, but the federal government thinks that if a 4 person family earns that much, the kids clearly don’t need a free breakfast or lunch.
The USDA devotes an enormous amount of effort to trying to make sure that families don’t “cheat” – as if anyone could get rich scamming free school meals for their kids! Meal applications must be filled out each year; districts are required to randomly pull 3% of all applications and verify that the information provided is accurate. Every day, cafeteria workers must check the eligibility of every student receiving a meal, to make sure that the government is only billed for those qualified.
Inspectors visit every NSLP school district every four years to monitor compliance with USDA policies, and the quality and safety of the food is not their only concern; they are looking for violations of all of the regulations cited here, and particularly they are looking to see if accurate “counting and claiming” is going on – in other words, they are looking for the “cheaters” who might be scamming a free lunch. Wouldn’t it make more sense to forget the meal applications, forget verifying the accuracy of the income information on them, forget the lunch cards, and the counting and claiming, and the search for “cheaters”, and just feed the kids?
Dana Woldow has worked on school food issues in San Francisco since 2002. She is the parent of one current SFUSD student and two SFUSD graduates. Although she serves as co-chair of the SFUSD’s Student Nutrition and Physical Activity Committee, the views expressed here are her own and do not necessarily reflect those of the Committee or of the SFUSD.