oversight

The National School Lunch Program

Published by the Government Accountability Office on 1977-09-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                         DCCUMENT RESUME
03965 - rB27940171

The National School Luinch Prograd. B-189930. Sept:cmber 30, 1977.
11 pp. + enclosuire (12 pp.).
Testimony before the Senate Select Committee on Ntrition and
Human Needs; by Dean K. Crowther, Deputy Director, Program
Analysis Div.

Issue Area: Food: Domestic Feeding Programs for School Children
    and the Poor (1710).
Contact: Program Analysis Div.
Budget Function: Health: Preventicn and Control of Health
    Problems (553).
Organizaticn Concerned: Department of Agriculture.
Congressional Relevance: Senate Select Committee on Nutrition
    and Human Needs.
Authority: Transportation Act of 140, as amended (49 U.S.C.
    66). Budget and Accounting Act of] 1921 (31 U.S.c. 49; 31
    U.S.C. 66). 4 C.F.R. 52.3.
         One purpose of the National School Lunch Program (NSLP)
is to safeguard schoolchild health by improving or maintaining
levels of nutrition. A specified food pattern is required for
the Type A Lunch which is expected tc provide cne-third of a
child's daily nutritional needs. The program can help to reduce
problems arising frcĀ¢ malnutriticn, but research is needed to
extend knowledge of effects of nutrition on health. The
Department of Agriculture has not ccmpleted a satisfactory
evaluation of NSLP's impact on schoolchild health. NSLP is an
important part of nourishment for any childrer but, because of
the diversity of nutritional problems, the standard lunch may
not be the best approach. The present Type A pattern for lunches
cannot e relied upcn to provide one-third of a child's
recommended dietary allowance. Less than 60% of cildren
enrolled in SLP schools participate in the prograk, and about
15% of lunches bought are thrown away. The Secretary of
Agriculture should: conduct a study to determine nutritional
standards to safeguard health, prescribe meal requirements in
terms of nutritional standards, and promote nutrition education.
(HTW)
          United States General Accounting Office
                 Washington, D,C. 2Q548


tS

O)                                        FOR RELEASE ON DELIVERY
                                          Expected at 11:00 a.m. B3T
                                          Wda-_ay---e   aembxzxZ o , 1977

                                                 i   SEP 1977


                       Statement of

                     Dean K. Crowther
     Deputy Director of the Program Analysis Division

           of the U.S. General Accounting Office

                        before the
       Select Committee on Nutrition ad Human Needs

                   United States Senate

                           on

            The National School Lunch Program
Mr. Chairman and Members of the Committee:

        We appreciate the opportunity of being here this mc;.ling to discuss

the National School Lunch Program--the largest of several Federally

funded child-feeding programs,

        The National School Lunch Program (NSLP) has two purposes:

        --to safeguard schoolcihild health, by improving and/or maintaining

          levels of nutrition; and

        --to strengthen the agricultural economy, by st..iulating food

          demand.

To these ends, the Secretary of Agriculture requires that program

lunches be designed according to a specified food pattern--called the

Type A Lunch.       The rebulting meal is expected to provide, on the average,

one-third of a child's daily nutritional needs,

        The school lunch program is now available to some 91 percent of

the Nation's schoolchildren, and serves over 4.1 billion lunches a

year.     Nearly 26 million children are fed each day.    About 2 out of
every 5 children receive their meals free or at a price of 20 cents

or less.

        The Federal Government contributed over $1.9 billion in cash

and commodities to support the fiscal year 1976 school lunch program.

Perspective

     Today I would like to concentrate on the nutritional effectiveness

of the school lunch program--its ability --
                                          o safeguard schoolchild health,



                                      -1-
      My statement is based primarily on our recent report, 'The

National School Lunch Program--Is It Working?".   I will also use
information from:

      (L) a study of "Fedezal Human Nutrition Research," that we

            are doing for your Committee; and

      (2) a study of certain nutritional and food quality aspects of

            the school lunch program, that we are doing for Congressman

            Frederick W, Rictmond.
      The purpose of our "school lunch report" was to bring together

the vast amount of research that had been done on topics either directly

or indirectly affecting NSLP--to determine how well the program had

been evaluated.   Naturally, the work involved an extensive search of

both Government and private literature osurces; the appraisal of a

considerable amount of material for technical quality and its relevance

to the current program; and the assistance of persons knowledgeable

in the nutritional sciences.

      To appraise the extenL to which NSLP's effectiveness in safeguarding

schoolchild health had been evaluated, we organized the available infor-

mation to answer three fundamental questions:

      (1)   What is good nutrition and how does it affect health?

      (2) What are the nutrition problems confronting today's school-

            children? and,

      (3) Can, and does, the school lunch program have a beneficial

            impact on schoolchild health?



                                     -2-
Nutrition/Health Relationships

         The National   cademy of Scienes    ~   Recormended Dietart   Allowances
 (RDA)    prescribe,, for various age-sex groups, a daily amotnt of 18

essential nutrients which are expected to satisfy the krown nutritional

needs of practically all healthy persons,            The RDA are widely accepted
as the Nation's starnlards for good nutrition,           They ?rre used by nutri-
tionists, dieticians, consumers, and the school lunzh program, whose

nutritional target is to furnish at least one-third'of the RDA.

         But, while the job of def.'..ng the requirenments for essential

nutrients--such as protein, calories, iron, an            vitamii C--is an impor-
tant and uncompleted task, the concept of malnutrition now included

food and nutrient excesses as well as deficiencies,             Effective nut.. tion
requires mort than simply consuming a "standard" quantity of nutrients,

         Today it is recognized that nutrition plays a vital role in health

3tatus throughout life.      There is evidence in children, for example,

that

         --anemia affects motivation and the ability to concentrate;

         --severe malnutrition affects intellectual development, ana can

          produce permanent stunting; and

         --obesity may contribute to coronary heart disease in later years.,

We believe that, with existing knowledge, the school lunch program
                                                                   can
mitigate against these problems.      We also believe that there is a clear
need to refine and extend this knowledge through further research:

to (1) define the processes by which dietary constituents lead to
                                                                  the



                                       -3-
onset and development of disease, and (2) evaluate the effects of

dietary modifications proposed as preventive mearures.

     To date, the Department of Agriculture has not completed a

satisfactory evaluation of NSLP's impact on schoolchild health.      A
determination of whether the pogramts influence is beneficial,

neutral, or adverse has not been made.     Our report levied heavy

criticism on the Department for this shortcoming.

     But our criticism of the evaluation effort is one thing; our

opinion of the program's actual performance, and itJ potential to

support schoolchild health, are quite another,     We believe:

     --That the program can, and should, have a beneficial impact

       on schoolchild health;

     -That   it   can be evaluated; and

     -- That, although much remains to be learned about    utrition, we

       have the knowledge, now, to better insure that the program is

       safeguarding health.

The Schoolchild's Nutrition Problem

     The NSLP's impact as a nutrition program depends largely on how

well the program lunch complements the home diet in meeting a child's

total, or 24-hour, nutritional needs.     The lunch itself is a supplement;
its one-third RDA standard, in isolation, is incomplete.

     To gain an insight into the nutritional problems confronting

schoolchildren, and their dietary needs, we compared the findings

of three of the Nation's largest nutritional surveys.     Each survey
 Zound substantial evidence of malnutrition among school-age children.

But,    in nearly all cases, the malnutrition was without visible signs--

 it was detected through the coordinated analysis of dietary intake

da:a,    biochemical specimens, and anthropometric measurements (such

as skin-fold thickness).

        The results of our work indicate that:

        --The NSLP is a very important part of nourishment for many

          child.-en and does, in fact, increase 24-hour nutrient intakes,

        - Tncome-loverty guidelines, as presently used in the free lunch

          program,    re the best known mea;s of selectively targeting NSLP

          to reach' nutritionally-needy children.   A greater number of
          "needy" children exist in the higher-income groups, but the

          "density-of-need" is greatest among children from low-income

          families.

        --On a Nation-wide scale, the major problems appear to be:

          underweight children; overweight children; and children with

          iron deficiency or iron deficiency with anemia,   The mean protein
          intakes of all children appear to be well in excess of RDA

          standards, ranging from 146 percent to 215 percent of the RDA.

        --Characteristics of malnutrition are often unique to specific

         localities and/or population groups.

        Because of the diversity of   utritional problems found among

schoolchildren, we are not sure that the NSLP's requirement for all

children to be served a uniform "standard lunch" is the best choice


                                       -5-
fox a nutritional standard,     We believe that:

     --Presernt meal standards place undue emphasis on high-cost protein.

       The NSLP lunch's protein requirement does not appear to be

       driven b   nutritional needs.       A relaxation of the requirement

       may provide "nutritionally adequate!' meals at lower costs,

     --Reinforcement levels greater than one-third RDA are needed

       for nutrient iron as weli as other vitamins/miLerpls for which

       major deficiencies have been found in some segments of the

       population.

     --Variations of caloric in :akes are needed,       Sizeable numbers

       of both underweight and overweight children participeze in

       the program; a single meal-standard, designed to meet the needs

       of underfed children, increases the risk of obesity in others.

School Lunch Program's Impact on Schoolchild Health

     While it seems obvious that the school lunch program is contributing

to the nutritional health of at least some children, the several studies

undertaken by the Department to substantiate this fact have all been

inconclusive.   Most of    he studies focused on the programrs ability

to impre ,e iron levels.   Not one found any idication to suggest that

participating students faced any better than nonparticipants over a

school year.

     On the other hand, substantial improvements in nutritior.al health have

been demonstrated in studies where the school lunch program was combined

with either a low-lactose supplement or the school breakfast,       The



                                     -6-
problem may be the lunch itself.    Our study found it to be weak i,

iron reinforcement.

      We also found indications that the program culd be contributing

to obesity in some children.    I want to especially point out that the

obesity issue is by no means demonstrated, but it is a potential

hazard faced by the school lunch and, for that matter, any other large-

scale feeding program.

      In a $4 billion program, supported by nearly 2 billion Federal

dollars, we believe that the Congress and the Department of Agriculture

should have better information than has been available on the program

thus far.    To be sure of what the program is doing; to make it more

effective, and to safeguard against the possibility of adverse side-

effects; our formal report recommends that the Department of Agriculture

conduct, with the advice and assistance of the Department of Health,

Education, and Welfare, a formal evaluation of NSLP's impact on school-

child health.

the Type A Lunch

      The heart of the current school lunch program is the Type A meal

pactern.    This pattern-not the nutritional requirement of one-third

RDA--is the requirement set forth for participating schools.   A Type

A lunch consists of one-half pint of fluid milk; two ounces of lean

meat; three-fourths of a cup of two or more vegetables or fruits; and

one slice of bread--with acceptable substitutes permitted for each

component except milk.



                                    -7-
      I am submitting for the record a supplementary statement which

 resents the results of a study GAO undertook at the request of Congress-

man Richmond.   The study included, among other things, findings re-

garding food waste, microbiological safety and quality, and certain

tests of the Type A pattern -- including nutrient content.      I will
hriefl 7 summarize the latter here:
      (1)   A sample of NSLP lunches     rved in New York City was tested
            using weights and measures against portions specified by

            the Type A pattern.   At least 40 percent of the program
            lunches served (between January 10 and February 22, 1977)

            failed to meet the pattern's requirements.     Since our
            review, te USDA has informed us that it has taken initial
            steps to improve its monitoring efforts.     However, much
            more needs to be done to ensure compliance with Federal

            school lunch requirements.

      (2) Of 60 "regulation-size" Type A lunches obtained from New
            York, Cleveland, and Los Angeles, laboratory tests showed

            that, over time, they provided significantly less than one-

            third RDA in 8 of 13 nutrients -- vitamin A, iron, magnesium,

            calories, thiamine, calcium, vitamin B6, and zinc.

Though nutrient deficiencies reported for this sarple of lunches is

somewhat greater than those found in several USDA studies we analyzed

in our July report, all studies agree that the Type A pattern does not,

in general, insure that the Type A lunch will provide one-third of a

schoolchild's RDA.


                                       -8-
         In contrast to a meal designed to ac:ieve a specified nutrient

goal, the Type A pattern restricts the form and      ontent of an NSLP
lunch.    Milk, for example, is mandatory whether or not juice or a

dairy alternate is included; and two or more vegetables or fruits

must be served.

         Many school food   ervice directors believe that the presen: Type

A pttern results in lunche., which are not in keeping with today's eating

habits.     They say the pattern (1) increases meal costs, (2) contributes

to food waste, and (3) discourages paying students from participating

in te      rogram.   Alternatively, an equal number of school food service
directors, and the Department, suvport the "pattern-concept" for its

ability to (1' provide an easy-to-follow standard for local meal planners

that will assure the nutritional integrity of program lunches, and

(2) serve as a tool for teaching childrc:n about food and nutrition.

They indicate that the program's problems with food waste and partizi-

pation can be overcome by increasing the emphasis on nutrition education,

and requiring greater student and parent involvement in menu planning

activities.

         We are convinced that the present Type A pattern,   s currently

structured, cannot be relied upon to provide one-third of a schoolchild's

RDA. And, we have 3erious questions as to whether or not a standard

"one-third RDA" lunch is the best choice for complementing a school-

child's home diet.      For these reasons, our school lunch report recommended

that the Secretary of Agriculture:
         -- Conduct a study, with assistance from HEW,             to deternine Lhe
           nutritional standards that will best safeguard schoolchild

           health.

         Food does little     good unless it     is   eaten.     Less than 60 percent

of the children presertly enrolled in NSLP schools participate in the

program.      Of the lunches bought, 15 percent --             about $290 million of

food in fiscal year 1976 --        is thrown into the garbage pail.           Our
report, and other publications of our Office suggest a number of actions

for improving participation and reducing food waste --                 many of which are
directly dependent upon the attitudes of local administrators.

         We believe that the Secretary of Agriculture should prescribe

NSLP meal requirments in terms of nutritional standards, and meal

patterns conforming to these standards.               Compliance with either would

be deemed to fulfill the Federal requirement.                  In the hands of an inno-

vative meal planner either a pattern or nutritional requirement
                                                                would
be essentially the sme; however, we would encourage flexibility
                                                                to in-
crease program participation -         particularly by those children who are

presently consuming non-nutritious, or "unk,"                  foods off-campus at lunch

time,

         Ultimately, there is     the question of "eto safeguards health when

children grow beyond their school years?".              Studies indicate that nutri-

tion education helps develop proper eating habits and reduces plate

waste.     Yet,   it   receives comparatively low priority with school admin-

istrators responsible for curriculum planning.                 Such courses generally



                                          -10-
consist of identification of the "basic four" food groups, and are

based on the presumption that the typical American diet is ideal.

However, since the "normal" American dietary practices may predispose

a large percentage of our population to premature cardiovascular disease

and possibly to other acute and chronic debilities, it may be desirable

to shift the emphasis on nutrition education from conceiving it as a
passive, abstract discipline to a viable, active part of preventive

health.    We believe nutrition education needs to deal with current

food trends.    It needs to identify food as more than a mere composite
of RDA nutrients.    Improved nutrition    ducation involves disseminating
appropriate knowledge on extenders, saturated fats, fibers, preserva-

tives, and other food constituents present in today's market,

      Our Office has recommended that the Secretary of Agriculture

undertake greater promotion of nutrition education in a number of

repo-ts.   We support the legislation calling for expanded nutrition

education which is presently before a House-Senate Conference Committee.

We also support USDA's proposed NSLP regulation changes encouraging

nutrition education.

      Mr. Chairman, this concludes our prepared statement,     We would
be happy to respond to any questions,




                                    -11-
UNITED STATES GENERAL ACCUNrING OFFICE   FOR RELEASE ON DELIVERY
MWSHINGOON, D.C. 20548                   EXPCXTED AT 11:00 A.M. EDT
                                         '    5   7 -    E--.
                                                          -EDNESDAX-
                                                                   1977
            STATEMENT FOR THE RECORD DURING HEARINGS            3   SEP 1977
                           BEFORE THE
                  SENATE SELECT COMMITTEE ON
                   NUTRITION AND UMAN NEEDS
           ON NUTRITIONAL AND FOOD QUALITY ASPECTS OF
               THE NATIONAL SCHOOL LUNCH PROGRAM

 MR. CHAIRMAN AND MEMBERS OF THE COMMITTEE:

       WE ARE HERE TODAY AT THE REQUEST OF THE COMMITTEE TO

 DISCUSS THE SCHOOL LUNCH PROGRAM--THE LARGEST OF THE SEVERAL

 FEDERALLY FUNDED CHILD-FEEDING PROGRAMS.         THE   FOOD AND

 NUTRITION SERVICE, DEPARTMENT OF AGRICULTURE, ADMINISTERS THE

 PROGRAM THROUGH STATE EDUCATION AGENCIES.         OUR OFFICE IS COM-

 PLETING A REVIEW OF CERTAIN NUTRITIONAL AND FOOD QUALITY

 ASPECTS OF THE PROGRAM PURSUANT TO A REQUEST BY

 CONGRESSMAN FREDERICK W. RICHMOND.       GAO'S STATEMENT TODAY WILL

 SUMMARIZE OUR FINDINGS AND OUR SUGGESTIONS FOR IMPROVING THE

 SCHOOL LUNCH PROGRAM.

       THE SCHOOL LUNCH PROGRAM OPERATES IN THE 50 STATES,            HE

 DISTRICT OF COLUMBIA, PUERTO RICO, GUAM, THE VIRGIN ISLANDS,

 AMERICAN SAMOA, AND THE TRUST TERRITORY OF THE PACIFIC ISLANDS.

 IN FISCAL YEAR 1976,     OVER 4.1 BILLION LUNCHES WERE SERVED IN

 NEARLY 90,000 SCiOOLS PARTICIPATING IN THE PROGRAM. DURING THE

 PEAK MONTH (NOVEMBER) IN SCHOOL YEAR 1976-77, ABOUT 25.8 MIL-

 LION CHILDREN WERE SERVED LUNCHE3 DAILY.         THE VALUE OF FEDERAL

 CASH AND COMMODITIES PROVIDED TO THE SCHOOL LUNCH PROGRAM WAS

 ABOUT $1.9 BILLION IN FISCAL YEAR 1576.
NUTRITION PROVIDED BY LUNCHES

        THE NATIONAL SCHOOL LUNCH ACT (42 U.S.C. 1758) REQUIRES

THAT LUNCHES SERVED BY PARTICIPATING SCHOOLS MEET NUTRITIONAL

STANDARDS PRESCRIBED BY THE SECRETARY OF AGRICULTURE.       THE
SECRETARY HAS DETERMINED THAT, AS A GOAL, SCHOOL LUNCHES

SHOULD, OVER TIME, PROVIDE ONE-THIRD OF THE NUTRITION CALLED

FOR BY THE RECOMMENDED DIETARY ALLOWANCES     (RDA) DEVELOPED BY
THE NATIONAL ACADEMY OF SCIENCES.     TO ACHIEVE THIS GOAL, THE
SECRETARY REQUIRES THAT SCHOOL LUNCHES CONTAIN PRESCRIBED

QUANTITIES OF VARIOUS TYPES OF FOODS.     THE REQUIRED MEAL PAT-
TERN IS BASED ON     HE NUTRITIONAL NEEDS OF 10-TO-12 YEAR OLD

CHILDREN AND IS COMMONLY CALLED THE TYPE A LUNCH.

        TYPE A LUNCHES ARE REQUIRED TO CONTAIN TWO OUNCES OF MEAT

OR OTHER HIGH PROTEIN FOOD, THREE-QUARTERS CUP OF TWO OR MORE

FRUITS AND/OR VEGETABLES, ONE SLICE OF ENRICHED BREAD, AND ONE

HALF PINT OF FLUID MILK.     ADJUSTMENTS IN THE QUANTITIES RE-

QUIRED BY THE TYPE A PATTERN ARE PERMITTED FOR YOUNGER AND

OLDER CHILDREN.

        ALTHOUGH SCHOOL LUNCHES ARE NOT SPECIFICALLY REQUIRED TO

PROVIDE ONE-THIRD RDA, THE TYPE A PATTERN WAS DESIGNED TO

ACHIEVE     HE GOAL OF ONE-THIRD RDA OVER TIME,   EXCEPT FOR CALO-
RIES.     HOWEVER, INDEPENDENT LABORATORY TESTS WE SPONSORED

SHOWED THAT ADHERING TO THE TYPE A PATTERN DOES NOT ENSURE

THAT THIS GOAL WILL BE ACHIEVED.

        WE CONTRACTED WITH THE WARF INSTITUTE IN MADISON,

WISCONSIN--NATIONALLY RECOGNIZED EXPERTS IN NUTRITIONAL

                                 2
TESTING--TO TEST 60 SCHOOL LUNCHES WE OBTAINED FROM 12 ELEMEN-

TARY SCHOOLS IN THREE CITIES--NEW YORK, CLEVELAND, AND

LOS ANGELES.    ALTHOUGH IT WAS NOT FEASIBLE FOR US TO SELECT A

SCIENTIFIC RANDOM SAMPLE OF LUNCHES FOR THIS PHASE OF OUR WORK,

WE SELECTED SCHOOLS SERVING TYPES OF MEALS COMMONLY SERVED TO

10-TO-12 YEAR OLD CHILDREN IN THE RESPECTIVE CITIES.

     FOR FIVE CONSECUTIVE DAYS IN EACH OF THE 12 SCHOOLS, WE

PURCHASED SCHOOL LUNCHES JUST LIKE THE ONES BEING SERVED TO

THE CHILDREN.   WE MEASURED THE LUNCIES AND SUPPLEMENTED THEM

IF NECESSARY TO MAKE SURE THEY MET THE REQUIREMENTS OF THE

TYPE A LUNCH PATTERN.     IN ACCORDANCE WITH DETAILED INSTRUCTIONS

PROVIDED BY WARF, WE PACKED AND FROZE THE LUNCHES AND SHIPPED

THEM TO WARF IN DRY ICE; THEY ARRIVED AT WARF STILL FROZEN AND

IN EXCELLENT CONDITION.    WARF RAN TESTS TO DETERMINE THE

QUANTITIES OF 13 DIFFERENT NUTRIENTS CONTAINED IN THE LUNCHES.

THE RESULTS WERE ANALYZED TO SEE WHETHER EACH SCHOOL'S LUNCHES

PROVIDED ONE-THIRD OF THE RDA FOR 10-TO-12 YEAR OLD CHILDREN

OVER THE 5 DAY PERIOD.

     THE CURRENT TYPE A PATTERN IS BASED ON THE 1968 VERSION

OF RDA WHICH INCLUDED 17 NUTRIENTS.    WE TESTED FOR 12 OF THESE

NUTRIENTS PLUS ZINC, WHICH WAS ADDED TO THE RDA IN 1974.     ON
THE RECOMMENDATIONS OF PROFESSIONAL NUTRITIONISTS, WE DID NOT

RUN TESTS ON THE OTHER FIVE NUTRIENTS IN    HE RDA BECAUSE RE-

LIABLE TESTING TECHNIQUES WERE NOT AVAILABLE OR BECAUSE IT WAS

VERY UNLIKELY THAT THERE WOULD BE SHORTAGES.



                                3
      THE TESTS SHOWED THAT, OVER THE 5 DAYS,      THE LUNCHES FROM
EACH SCHOOL PROVIDED THE RECOMMENDED AMOUNTS OF 5 OF THE 13

NUTRIENTS--PROTEIN, PHOSPHORUS, NIACIN, IODINE, AND VITAMIN C.

HOWEVER, THERE WERE SIGNIFICANT SHORTAGES       (MORE THAN   5 PERCENT
OF RDA) AT EACH OF THE 12 SCHOOLS IN ONE OR MORE OF THE OTHER

8 NUTRIENTS.      FOR EXAMPLE, LUNCHES FROM 7 OF THE 12 SCHOOLS

HAD DEFICIENCIES OF 19 TO 50 PERCENT IN VITAMIN A; 9 SCHOOLS

HAD DEFICIENCIES OF 13 TO 42 PERCENT IN IRON; AND ALL 12

SCHOOLS HAD DEFICIENCIES OF 5 TO 35 PERCENT IN MAGNESIUM.

LUNCHES     FROM ALL 12 SCHOOLS   ALSO HAD DEFICIENCIES OF 7 TO 42

PERCENT IN ZINC.      THERE ALSO WERE LESSER DEFICIENCIES IN CALO-

RIES, THIAMINE, CALCIUM,     AND VITAMIN 36.

     WE 3ELIEVE THESE TESTS       INDICATE THAT THE TYPE A PATTERN

IS NOT ADEQUATE TO ENSURE ACHIEVEMENT OF THE PROGRAM'S NUTRI-

TIONAL GOAL.     THE DEPARTMENT RECENTLY PROPOSED A NEW LUNCH

PATTERN GIVING SCHOOLS MORE FLEXIBILITY IN ACHIEVING ONE-THIRD

RDA FOR DIFFERENT AGE      ROUPS, BUT THE ONLY RELEVANT CHANGE FOR

10-TO 12-YEAR OLDS IS THAT EIGHT SLICES OF BREAD WILL BE RE-

QUIRED EACH WEEK INSTEAD OF FIVE.       ALSO, ALTERNATIVES TO 3READ,
SUCH AS RICE OR MACARONI, WOULD BE PERMITTED.       EXCEPT FOR CAL-
ORIES, THESE CHANGES DO NOT APPEAR SUFFICIENT TO OVERCOME THE

NUTRITIONAL SHORTAGES     INDICATED BY OUR CONTRACTOR'S TESTS.

     THE DEPARTMENT NEEDS TO FURTHER MODIFY THE SCHOOL LUNCH

REQUIREMENTS    IF THE GOAL OF PROVIDING ONE-THIRD RDA IS     TO BE
ACHIEVED.     INCREASING THE QUANTIrIES OF FOOD REQUIRED BY THE

TYPE A PATTERN MAY NOT BE A SATISFACTORY SOLUTION BECAUSE SOME

                                   4
FOODS MIGHT BE INCREASED TO EXCESSIVE QUANTITIES AND BECAUSE,

AS DISCUSSED LATER IN THIS STATEMENT, CHILDREN FREQUENTLY DO

NCOT EAT ALL OF THE FOOD SERVED TO THEM IN SCHOOL LUNCHES.          NEW

APPROACHES MAY BE NEEDED; CONSIDERATION SHOULD BE GIVEN TO OP-

TIONAL USE OF A STANDARD REQUIRING SPECIFIC NUTRIENT CONTENT

(AS DISCUSSED LATER IN THIS STATEMENT), CAREFUL EXPANSION OF

THE USE OF ENRICHED FOODS,    MORE DECENTRALIZED AND MORE FLEX-

IBLE MENU PLANNING, OR OTHER INNOVATIVE TECHNIQUES.

MICROBIOLOGICAL QUALITY AND SAFETY OF LUNCHES

     TO OBTAIN AN INDICATION OF WHETHER SCHOOL LUNCHES ARE OF

GOOD QUALITY AND SAFE TO EAT ACCORDING TO     ICROBIOLOGICAL

TESTS, WE CONTRACTED WITH PRIVATE LABORATORIES IN THE THREE

CITIES TO OBTAIN SAMPLE LUNCHES AND CONDUCT BACTERIA TESTS.

THE LABORATORIES   PICKED UP 60 ADDITIONAL LUNCHES FROM THE

SCHiOOLS AND TESTEO THEM FOR RECOGNIZED INDICATORS OF QUALITY

AND SAFETY--TOTAL BACTERIA PLATE COUNT, FECAL COLIFORM,

E.COLI, STAPHYLOCOCCUS,   SALMONELLA, SHIGELLA, AND CLOSTRIDIUM

PERFINGENS.

     THERE ARE NO NATIONAL STANDAhDS FOR BACTERIAL CONTENT IN

SCHOOL LUNCHES OR FOR TESTING PRACTICES OTHER THAN FOR MILK.

ACC.)RDINGLY, THE LABORATORIES TESTED LUNCHES IN ALL THREE

CITIES AGAINST THE NEW YORK CITY HEALTH CODE STANDARD FOR

BACTERIAL CONTENT SO THAr ALL OF OUR TEST RESULTS WOULD        E

BASED ON THE SAME STANDARD.

     A FOOD AND DRUG ADMINISTRATION    (FDA) OFFICIAL AND AN       IN-

DEPENDENT MICROBIOLOGIST EXPLAINED THAT Tli    NEW YORK CITY

                                5
STANDARDS CONTAIN SAFETY MARGINS.      THEY REVIIWED THE RESULTS

OF THE TESTS     E HAD CONDUCTED AND, ALTHOUGH 20 OF IHE 240 SAC-

TERIAL READINGS EXCEEDED NEW YORK CITY STANDARDS BY SMALL

AMOUNTS, THEY CONCLUDED THAT ALL THE LUNCHES WERE SAFE TO EAT

BECAUSE EACH O     THE READINGS EXCEEDING THE STANDARDS WAS WITH-

IN THE SAFETY MARGINS.

     STATE AND LOCAL STANDARDS FOR BACTERIA IN SCHOOL LUNCH.S

VARY CONSIDERABLY.     IN 1975, FDA ESTIMATED THAT ONLY HALF OF

THE STATES    HAD OR WERE IN THE PROCESS OF ESTABLISHING BACTERI-

AL STANDARDS OR GUIDELINES FOR FOODS.       ACCORDING TO AN FDA
ANALYSIS,    STATE STANDARDS AND GUIDELINES VARY 3Y FOODS COVERED,

TYPES OF BACTERIA, AND PERMISSIBLE LEVELS OF THE BACTERIA.

SOIE STATES APPLY STANDARDS FOR BACTERIAL LEVELS EQUALLY ro

ALL FOODS.     OTHER STATES HAVE LEVELS FOR ONLY ONE OR TWO SPE-

CIFIC FOOD ITEMS.

     ALTHOUGH SOME LOCAL BACTERIAL TESTING WAS BEING PERFORMED

IN EACH OF THE THREE CITIES WE VISITED, THE TESTING PRACTICES

VARIED GREATLY.     FOR INSTANCE, ONE CITY REGULARLY TESTED FRO-

ZEN ITEMS FOR EACH OF THE BACTERIA FOR WHICH WE HAD TESTS CON-

DUCTED.     GENERALLY, ITEMS PURCHASED EITHER FRESH OR CANNED WERE

TESTED FOR BACTERIA ONLY WHEN SOMETHING APPEARED WRONG WITH

THEM OR     HEN SOMEONE COMPLAINED ABOUT THEM.

     IN ANOTHER CITY TWO BACTERIAL READINGS WERE TAKEN DURING

THE INITIAL COOKING OF RAW FOODS--TOTAL BACTERIA PLATE COUNT

AND COLIFORM.     IF EITHER COUNT WAS EXCESSIVE, THE LABORATORY

CONDUCTED OTHER TESTS AS NEEDED.     THIS   PROCEDURE WAS ALSO

                                 6
APPLIED TO FROZEN FOODS AND CANNED GOODS IF SOMETHING SEEMED

WRONG WITH THEM.

       IN THE THIRD CITY FROZEN FOODS WERE TESTED FOR YEAST,

MOLD, COLIFORM, AND TOTAL PLATE COUNT.          ALL FOODS WERE TESTED

BY KITCHEN STAFFS FOR FRESHNESS, TEMPERATURE, AND TASTE, AND

THE EQUIPMENT USED IN PREPARING THE FOOD WAS TESTED FOR BAC-

TERIA.

       DESPITE TE INCONSISTENCIES       IN LOCAL TESTING PRACTICES

AND STANDARDS,    VARIOUS    EXPERTS IN BACTERIA TESTING TOLD US

THAT MINIMUM NATIONAL STANDARDS FOR SCHOOL LUNCHES, ALTHOUGH

THEORETICALLY DESIRABLE, ARE NOT PRACTICAL OR ARE NOT JUSTI-

FIED     Y THE SMALL NUMBER OF CASES OF ILLNESS CAUSED BY CON-

TAMINATED FOODS.       WE FIND IT DIFFICULT TO ARGUE WITH THIS LOG-

IC.    IF LOCALITIES ARE GOING TO CONTINUE CONDUCTING 3ACTERIAL

TESTS, HOWEVER, IT MIGHT BE WORTHWHILE FOR THE DEPARTMENT OF

AGRICULTURE TO GIVE THE IDEA OF        UNIFORM TESTING PRACTICES AND

STANDARDS SOME FURTHER THOUGHT.

MEETING TYPE A LUNCH REQUIREMENTS

       IN A SEPARATE SERIES OF TESTS,      WE USED STATISTICAL SAM-

PLING TECHNIQUES      TO ESTIMATE THE NUMBER OF SCHOOL LUNCHES

SERVED IN NEW YORK CITY SCHOOLS THAT FAILED ro MEET TYPE A RE-

QUIREMENTS    FOR QUANTITY   AND TYPE n:   FOOD SERVED DURING A 6-WEEX

PERIOD IN JANUARY AND FEBRUARY 1977.

       WE HAD TESTS     ADE OF EACH TYPE OF LUNCH SERVICE      IN

NEW YORK CITY SCHOOLS--CAFETERIA       STYLE,   MEAL PACK,   BASIC       (SOUP

AND SANDWICH),    AND 3ULK   (PREPARED-FROZEN COMPONENTS).          WE

                                   7
PICKED UP THE LUNCHES     ND DELIVERED THEM TO DIETITIANS AT A

VETERANS ADMINISTRATION HOSPITAL IN NEW YORK CITY WHO TESTED

THE LUNCHES FOR COMPLIANCE WITH TYPE A REQUIREMENTS.

        FROM OUR SAMPLE WE ESTIMATE, WITH 90 PERCENT CERTAINTY,

THAT AT LEAST 40 PERCENT OF THE SCHOOL        UNCHES SERVED    IN
NEW YORK CITY DURING OUR TEST PERIOD DID NOT MEET TYPE A RE-

QUIREMENTS; FEDERAL REIMBURSEMENT FOR THESE NONCOMPLYING

LUNCHES WOULD BE AT LEAST $3.7 MILLION.        FACTORS CONTRIBUTING

TO THIS SITUATION WERE THAT ABOUT 20 PERCENT OF NEW YORK CITY

SCHOOLS DID NOT HAVE SCALES TO WEIGH MEAL COMPONENTS AND 16

PERCENT DID NOT HAVE PRE-PORTIONED SERVING UTENSILS TO ENSURE

THAT QUANTITIES REQUIRED BY THE TYPE A PATTERN WERE           EING
SERVED.     THE RESULTS OF THESE TESTS ARE DESCRIBED    IN MORE DE-
TAIL IN OUR JUNE 15, 1977,    REPORT   TO THE SECRETARY OF AGRICUL-

TUR     (CED-77-89), A COPY OF WHICH IS    ATTACHED TO THIS    TATE-
MENT.

        THE DEPARTMENT OF AGRICULTURE HAS DELEGATED RESPONSI-

BILITY FOR MONITORING THE SCHOOL LUNCH PROGRAM TO THE NEW YORK

STATE DEPARTMENT OF EDUCATION.       ALTHOUGH AGRICULTURE REQUIRES

COMPLIANCE WITH THE TYPE A PATTERN, IT DOES NOT SPECIFY HOW

COMPLIANCE IS TO 3E TESTED.    THE STATE'S REVIEWS HAVE 3EEN

CONCERNED PRIMARILY WITH CHILDREN'S       ELIGIBILITY TO RECEIVE

FREE OR REDUCED PRICE LUNCHES    ND WITH PROGRAM ACCOUNTABILITY,

AND ONLY LIMITED ATTENTION HAS BEEN GIVEN TO COMPLIANCE WITH

TYPE A REQUIREMENTS. THE STATE HAD NEVER WITHHELD PROGRAM

FUNDS FROM NEW YORK CITY' BECAUSE OF TYPE A NONCOMPLIANCE.

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        IN MARCH 1977, WE BRIEFED THE DEPARTMENT, THE STATE, CITY

SCHOOL OFFICIALS,    AND CONGRESSMAN RICHMOND ON THE RESULTS OF

OUR TESTS.     Ai' THE CONGRESSMAN'S REQUEST, A JOINT FEDERAL,

STATE, AND CITY TASK FORCE EVALUATED NEW YORK CITY'S SCHOOL

LUNCH PROGRAM AND MADE RECOMMENDATIONS TO CORRECT IDENTIFIED

PROBLEMS.     TESTING AND MONITORING OF TYPE A LUNCH REQUIREMENTS

IS TO BE EXPANDED AND EMPHASIZED BY THE DEPARTMENT AND THE

STATE IN THE 1.977-78 SCHOOL YEAR.

        FAILURE TO MEET THE TYPE A REQUIREMENTS RESULTS IN SCHOOL

CHILDREN BEING FURTHER SHORT-CHANGED IN RECEIVING THE NUTRI-

ENTS WHICH THE FEDERALLY SUBSIDIZED LUNCH IS DESIGNED TO PRO-

VIDE.     WE FIRST RECOMMENDED BACK   N MARCH THAT THE DEPARTMENT

DETERMINE THE EXTENT TO WHICH THE PROBLEM OF NONCOMPLIANCE

WITH THE TYPE A LUNCH REQUIREMENTS FOUND IN NEW YORK CITY IS A

NATIONWIDE PROBLEM.     THE DEPARTMENT HAS ACKNOWLEDGLD THIS TO
BE A NATION4IDE PROBLEM AND HAS TAKEN INITIAL STEPS TOWARD RE-

QUIRING BETTER MONITORING OF COMPLIANCE WITH THE TYPE A RE-

QUIREMENTS.     HOWEVER, MUCH MORE NEEDS TO BE   ONE;   THE DEPART-

MENT SHOULD DEVELOP SPECIFIC INSTRUCTIONS ON HO4 FEDERAL,

STATE, AND LOCAL MONITORING IS TO BE PERFORMED.         DEPARTMENT

OFFICIALS TOLD US THEY PLAN TO DEVELOP SUCH INSTRUCTIONS.

FOOD WASTE

        FOOD WASTE HAS LONG BEEN A RECOGNIZED PROBLEM IN THE

SCHOOL LUNCH PROGRAM AND HAS BEEN DISCUSSED IN SEVERAL EARLIER

REPORTS BY OUR OFFICE.     OUR RECENT OBSERVATIONS OF MEALS

SERVED IN NEW YORK CITY SCHOOLS CONFIRMED OUR EARLIER FINDINGS.

                                 9
WE FOUND THAT CHILDREN CONSISTENTLY REJECTED VEGETABLE ITEMS

AS WELL AS FRUITS AND MILK.

     SCHOOL LUNCH PROGRAM PERSONNEL MENTIONED THE FOLLOWING

FACTORS AS CONTRIBUTING TO PLATE WASTE:

     -- LACK OF NUTRITION EDUCATION AMONG THE CHILDREN AT HOME

       AND UNFAMILIARITY WITH MANY VEGETABLE ITEMS DUE TO CUL-

       TURAL AND ETHNIC DIFFERENCES IN NEW YORK CITY.

     -- POOR LUNCHROOM ATMOSPHERE A ' CONDITIONS,           SUCH AS SHORT

       AND HURRIED LUNCH PERIODS AND LACK OF ADEQUATE SUPER-

       VISION OF STUDENTS.

     -- PEER GROUP PRESSURES NOT TO EAT CERTAIN FOODS.

     --THE CHILDREN TIRE OF EATING THE SAME FOOD ITEMS OVER

       AND OVER AGAIN.

THESE ARE IN LINE WITH THE REASONS CITED IN OUR JANUARY 31,

1977, REPORT ENTITLED "THE IMPACT OF FEDERAL COMMODITY DO-

NATIONS ON THE SCHOOL LUNCH PROGRAM"         (CED-77-32).

     ALTHOUGH THESE FACTORS MAY IMPACT ON FOOD CONSUMPTION,

IT APPEARED TO US THAT FOOD WASTE WAS MOST OFTEN CAUSED BY

STUDENTS SIMPL     NOT LIKING THE      ITEMS BEING SERVED.    IN ONE

SCHOOL, FOR EXAMPLE, SEVERAL CHILDREN SPECIFICALLY REQUESTED

THAT GREEN BEANS NOT BE ADDED TO THEIR LUNCHES.          WHEN THEIR

REQUESTS WERE    DENIED THEY THREW THE ITEM AWAY UNTOUCHED.            WE

ALSO FOUND THAT THE SAME    ITEMS WERE NOT CONSISTENTLY ACCEPTED

OR REJECTED.     FOR EXAMPLE,   TUNA FISH WAS WELL RECEIVED IN ONE

SCHOOL, BUT 30 PERCENT OF IT WAS WASTED IN ANOTHER SCHOOL.



                                  10
     ALTHOUGH COMPREHENSIVE STUDIES ARE NOT AVAILABLE ON THE

EFFECTIVENESS OF NUTRITION EDUCATION IN IMPROVING CHILDREN'S

DIETS, THERE ARE SOME INDICATIONS THAT WELL-DESIGNED AND IM-

PLEMENTED NUTRITION EDUCATION PROGRAMS HAVE A FAVORABLE IMPACT,

INCLUDING SIGNIFICANT REDUCTIONS IN PLATE WASTE.       HOWEVER,

NUTRITION EDUCATION HAS A LOTA PRIORITY WITH SCHOOL ADMINISTRA-

TORS RESPONSIBLE FOR CURRICULUM PLANNING.

     THE DEPARTMENT IS CURRENTLY STUDYING PLATE WASTE IN THE

SCHOOL LUNCH PROGRAM ON A NATIONAL SCALE AND EXPECTS THE

RESULTS TO BE AVAILABLE IN LATE 1977.

     WE BELIEVE THAT TO REDUCE FOOD WASTE T        DEPARTMENT

SHOULD:

     -- ENCOURAGE MORE NUTRITION EDUCATION IN SCHOOL [{EALTH PRO-

      GRAMS TO DEVELOP PROPER EATING HABITS AT AN EARLY AGE.

      WE NOTE THAT THE DEPARTMENT'S PROPOSED CHANGES TO THE

      SCHOOL LUNCH REGULATIONS ENCOURAGE NUTRITION EDUCATION

      AND THAT LEGISLATION PRESENTLY BEFORE A HOUSE-SENATE

      CONFERENCE COMMITTEE CALLS FOR EXPANDED NUTRITION ED-

      UCATION.     WE SUPPORT THESE CHANGES.

     --ENCOURAGE LOCAL SCHOOL AUTHORITIES TO USE DECENTRALIZED

      MENU PLANNING TO MEET THE TASTES OF CHILDREN FROM VARI-

      OUS CULTURAL AND ETHNIC       BACKGROUNDS AND OFFER A WIDE

      SELECTION OF FOODS THAT ARE HIGHLY PREFERRED AND PALA-

      TABLE.     THE DEPARTMENT'S PROPOSED REGULATIONS WOULD

      REQUIRE STUDENT INVOLVEMENT IN MENU PLANNING AND EN-

      COURAGE PARENT    INVOLVEMENT IN SCHOOL LUNCH ACTIVITIES.

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  WE SUPPORT THIS PROPOSAL, BUT     E BELIEVE PARENT IN-

  VOLVEMENT IN MENU PLANNING COULD HAVE SUBSTANTIAL PO-

  TENTIAL FOR REDUCING PLATE WASTE AND SHOULD BE SPECIF-

  ICALLY REQUIRED.

-- ENCOURAGE LOCAL SCHOOL AUTHORITIES TO IMPROVE LUNCHROOM

 ATMOSPHERE AND CONDITIONS.

-- CONSIDER THE USE OF A NUTRIENT STANDARD    S AN OPTION TO

  THE TYPE A PATTERN TO PROVIDE GREATER FLEXIBILITY IN

  MENU PLANNING.     THE PROPOSED REGULATIONS STATE THAT THE

  DEPARTMENT IS CONTINUING TO EXPLORE ALTERNATIVES TO THE

 TRADITIONAL   ENU PLANNING APPROACH AND REQUESTS PU3LIC

 COMMENT ON THE    USE OF A NUTRIENT STANDARD.




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