Dear Secretary Vilsack, please extend Dietary Guidelines public comment past May 16 and open saturated fat limits for course-correction review!

Screen capture from https://www.dietaryguidelines.gov/

‘Preponderance of evidence’ screams for a Dietary Guidelines course-correction to expand flexibility and increase, not reduce, saturated fat limits as well as to examine the nutrient deficiencies of currently approved dietary patterns in all life stages, and to examine the effects of these overly-prescriptive one-size-fits-all patterns on vulnerable populations in government feeding situations such as children obtaining most of their nourishment at school where DGAs rule.

Editorial opinion by Sherry Bunting, Farmshine, May 6, 2022

Recently, USDA and HHS launched the 2025-30 cycle of the Dietary Guidelines for Americans (DGA). Trouble is, the first and undeniably most important part of the process that will shape WHAT can be amended and the research-screening process for doing so are the “scientific questions” to be examined.

A paltry 30-day public comment period about these already-prepared questions was announced April 15 and expires May 16, 2022.

By the time you read this, there will be fewer than 10 days to comment. To read the USDA HHS proposed scientific questions, click here and to submit a comment to the docket, click here

In addition to the links above, comments can be mailed to Janet M. de Jesus, MS, RD, Office of Disease Prevention and Health Promotion (ODPHP) Office of the Assistant
Secretary for Health (OASH), HHS; 1101 Wootton Parkway, Suite 420; Rockville, MD 20852. Be sure to reference HHSOASH-2022-0005-0001 on the submission.

Lack of time to comment on the questions is not the only problem with the 2025-30 DGA launch. The commenting instructions state: “HHS and USDA will consider all public comments posted to Regulations.gov in relation to the specified criteria. Comments will be used to prioritize the scientific questions to be examined.”

These instructions do not leave much opening to amend the already-prepared scientific questions.

I encourage others to join me in requesting an extension of this comment period to 90 days and to open the process into a course-correcting complete re-evaluation of saturated fat limits — to drive home the point that the “preponderance of evidence” screams for higher, more flexible, saturated fat limits (especially for children), to review the science on saturated fat consumption at all life stages on not only cardiovascular health, but also weight management and diabetes, cognitive health, and other areas, including how current saturated fat limits affect under-consumption of essential nutrients, how these limits affect school meal patterns where most children receive most of their nourishment most of the year — considering the 2020-25 DGA Committee admitted the three government sanctioned dietary patterns are deficient in key nutrients of concern for all age groups.

Join me in asking USDA and HHS to educate the public about the true impact of the DGAs on our most vulnerable populations (children and the elderly) and to avoid prescriptive one-size-fits-all dietary patterns.

People don’t seem to pay much attention to the DGA process because there has been no full disclosure of the true impacts of these so-called “guidelines.” People say, oh, they’re “just guidelines.” Maybe that’s true for you and I, but what about the children? What about the elderly? They are under the ruthless thumb of USDA HHS DGA implementation in feeding programs for America’s most vulnerable ages and demographics.

The ink is barely dry on the 2020-25 DGAs, leaving many to believe there is plenty of time to comment on the next round — later — when the process is fully underway. After all, USDA reminds us this is a five-step process, and they are “committed” to providing plenty of opportunities to be heard.

Wrong. This first step is in many ways the most important for public comment because it shapes how the other four steps unfold. It shapes what research will be screened in and out of the process. It shapes what areas of the DGAs can be amended and specific criteria for how they can be amended — no matter how earthshaking a dietary revelation.

This first step also shapes how your future comments will be considered. For example, many comments, even research in the screening process, will be ignored as this 2025-30 DGA cycle unfolds when it is deemed to fall outside of the specific criteria set in the scientific questions of step-one — right now — for this 2025-30 cycle.

USDA and HHS have already formulated the 2025-30 “scientific questions,” leaving most of the failed guidelines ‘base’ pretty much moving forward — as-is.

One area the Departments announced will run parallel is on ‘planetary diets.’

The USDA HHS announcement notes that the 2025-30 DGAs won’t incorporate DIRECTLY any ‘climate-related’ dietary recommendations, stating: “Sustainability and the complex relationship between nutrition and climate change is an important, cross-cutting, high priority topic that also requires specific expertise. HHS and USDA will address this topic separate from the Committee’s process to inform work across the Departments.”

That’s about as clear as mud. In this statement, USDA seems to tie nutrition and climate change together with the term “cross-cutting,” and describes the “relationship” as a “high priority topic,” assuring us that USDA and HHS will handle this separately and then “inform.”

After looking through the scientific questions in the areas of systematic review and dietary patterns, below is my citizen’s comment: 

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Dear Secretary Vilsack:

To use the phrase you used repeatedly in a Congressional hearing about the 2015-20 Dietary Guidelines, the ‘preponderance of evidence’ on saturated fat limits for all ages — and for children and adolescents in particular — should be up for a complete re-evaluation in the 2025-30 DGAs.

Study after study show our government-sanctioned dietary patterns are failing our children who receive most of their nourishment at school under the thumb of USDA-HHS Dietary Guidelines. USDA even threatens to financially penalize any school that dares make nutritious, wholesome, satiating, healthful whole milk available — even for students to buy from a vending machine run by an FFA chapter seeking to raise funds for agriculture programs, simply because the calories and percent of calories from saturated fat in that nutrient-dense superior beverage exceed your arbitrary, unscientific DGA limit.

But that’s okay, say the HHS USDA DGA, just have a Mountain Dew Kickstart or a sugar-free Gatorade Zero. PepsiCo thanks you, dear USDA, for caring about the profitability of the Smart Snacks empire they and others have built on your say-so, while children become fatter, sicker and sadder and under-consume key nutrients for health and brain power.

Meanwhile, farmers wonder what on earth they can do to get the nutritious, natural, beautiful, local whole milk product they produce to the children in need of nourishment at school, while doctors bemoan under-consumption of nutrients of concern like calcium, vitamin D and potassium (abundant in milk, better absorbed with the fat).

Even the 2020-25 DGA Committee admitted that all three dietary patterns leave all age groups deficient in key nutrients. That’s okay, just get in line for our vitamin pills, right?

It’s even more concerning to see the diets in reality are even worse than they are on paper, if that’s possible, as students pass-over the obligatory skimmed milk in favor of big-brand junk drinks devoid of nutrition, or they take the skimmed milk and toss it into the trash.

USDA’s own study in 2013 showed that in the first year after the Smart Snacks regulations tied competing beverages to the DGAs — outright prohibiting whole milk and 2% milk from schools — student selection of milk fell 24%, and the amount of milk discarded by students increased by 22%. Other studies since 2012 show milk is among the most frequently discarded items at schools. World Wildlife Fund issued a report saying one way to reduce this waste is to educate schools on the fact that they are not forced to serve milk, they can offer it and educate students not to take the milk if they aren’t going to drink it.

What does that solve? It still leaves children and youth without the nourishment USDA touts in the school lunch program on paper even as the school meal situation has become an increasingly restrictive maze of fat limits and thresholds that schools give up managing it and leave it to the ‘Big Daddy’ institutional foodservice corporations with their pre-packaged, highly-processed deals that come with ‘USDA compliance guarantees.’

Why is the Biden Administration fast-tracking this agenda? There are four bipartisan bills before Congress dealing with school milk and others dealing with childhood nutrition. There are bills about allowing whole milk in schools at the state level in Pennsylvania and New York, with lawmakers in at least two other states watching closely to perhaps do the same.

The Whole Milk for Healthy Kids Act to repeal your whole milk prohibition has 93 cosponsors in 32 states. City schools, rural schools, town mayors, boards, teachers, parents, coaches, dieticians, doctors, nurses, farmers — people from all walks of life — and, yes, food and nutrition scientists are increasingly appalled at the school milk and school lunch issues — all under the thumb of the DGAs.

The DGAs are designed in a way that each 5-year cycle builds on the one before it — since 1990! The scientific questions are formulated to keep moving that way instead of looking back and re-evaluating or re-examining nutritional aspects USDA considers ‘settled science.’

In reality, however, there is nothing settled about the DGA ‘science’ on saturated fat. This build-upon process is flawed.

In fact the ‘preponderance of evidence’ would tell us the process should be opened up for a more thorough and reflective review, toward more flexible saturated fat limits — especially to expand overly-restrictive saturated fat limits that are creating concerns for children and youth and, in effect, keep nutrient-dense whole milk and 2% milk, as well as full-fat dairy products out of schools. By these standards, the DGAs actually embrace artificially-created highly processed beverages and foods — even Impossible Burger over Real Beef.

The preponderance of evidence is undeniable. The DGA saturated fat limits are a straight-jacket for schools, imprisoning children into poor nutritional health outcomes that can stay with them the rest of their lives and may affect their abilities to learn. Our future as a nation, the health of our children, the economic standing of our food producers, our nation’s food security, our national security itself are all rooted in these DGAs that are still centered on false narratives about saturated fat that the preponderance of evidence has disproven.

Please extend this comment period to 90 days and expand the input considerations and the process, especially as relates to saturated fat limits for all life stages and evaluate the current patterns for under-consumption of nutrients of concern for all life stages. Simply amending a failed base product is unproductive at best and creates more negative health consequences at worst. We need a DGA course correction, a re-do, rigorous scientific debate, acknowledgment that the science is not settled against fat with the preponderance of evidence moving toward the healthfulness of dietary fat.

Finally, we need a Dietary Guidelines product that serves more broadly as just that — guidelines — not a prescriptive one-size-fits-all straight-jacket that obviously is failing the majority of Americans.

Public discussion about the process is needed in a more open, thoughtful, comprehensive manner before the 2025-30 DGAs get underway.

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Comments due March 24: Ask USDA to end its prohibition of whole milk in schools, give students milkfat choice

Photo credit (Top) USDA FNS website screen capture from https://www.fns.usda.gov/building-back-better-school-meals and (bottom) fat-free flavored milk and fat-free yogurt on a local school lunch tray.
Screen capture and lunch tray photo S.Bunting

By Sherry Bunting, published Farmshine, Feb. 18, 2022

WASHINGTON — As reported in the Feb. 11 Farmshine, USDA announced a ‘transitional standards’ rule on Feb. 4 for milk, whole grains, and sodium for school years 2022-2023 and 2023-2024. 

The transitional standards are only in place while USDA works with stakeholders on long-term meal standards through a new rulemaking. 

The proposed rule for the longer-term is expected to come from USDA in fall 2022 and will become effective in school year 2024-25. It will be based on the Dietary Guidelines for Americans 2020-2025, but USDA says it is conducting a public comment and review process related to the standards and to the “gradual implementation” plan it will develop based in part on stakeholder input. 

In the official transitional standards rule, USDA notes that full implementation of its 2012 meal pattern requirements for milk, grains and sodium have been delayed at intervals due to legislative and administrative actions. “Through multiple annual appropriations bills, Congress directed USDA to provide flexibility for these specific requirements.” 

Read the transitional standards rule here at https://www.regulations.gov/document/FNS-2020-0038-2936 where a comment button can be clicked to provide a public comment to USDA by March 24, 2022.

Now is the time to comment before March 24, 2022 and to call for an end to the prohibition of whole milk in schools. Request that USDA restore the choice of whole milk in schools by commenting at the online rulemaking portal https://www.regulations.gov/commenton/FNS-2020-0038-2936

Comments and questions can also be sent to: Tina Namian, Chief, School Programs Branch, Policy and Program Development Division—4th Floor, Food and Nutrition Service, 1320 Braddock Place, Alexandria, VA 22314; telephone: 703-305-2590. 
Include FNS-2020-0038-2936 in your correspondence. 

In a rare move Feb. 7, the American Association of School Superintendents (AASA) made a public media statement on the transitional standards — pointing out their concern that the long-term standards will be ‘more stringent’ due to the restrictive Dietary Guidelines that were approved by USDA and HHS in 2020. 

The Association of School Superintendents stated: “It is important to acknowledge that healthy meals are only healthy if students eat them.” 

Agreed! This applies to the milk also. Students miss out on 21 minerals, 13 vitamins, complete high quality protein, a healthy matrix of fat and several nutrients of concern when they don’t actually consume the milk offered or served at school. Those nutrients ‘on paper’ are then not realized. Many key nutrients of concern are also fat-soluble. A study at St. Michael’s Children Hospital, Toronto, showed children consuming whole milk had 2.5 to 3x the Vit. D absorption compared with those consuming low-fat milk, and they were at 40% less risk of becoming overweight! Details were presented in a June 2021 hearing in the Pennsylvania Senate, listen here

Milk consumption plummeted and waste skyrocketed since USDA’s 2012 fat-free/low-fat milk rules were set for both ‘served’ milk and competing a la carte offerings. Studies by USDA and others show milk is now one of the most discarded items at school. In fact, USDA did a plate waste study comparing 2011 to 2013 (pre-/ and post-change) They focused on fruits and vegetables, but saw milk decrease significantly, waiving it off as though it were due to an “unrelated policy change.” Technically, it was the smart snacks rules for beverages and it WAS related to the 2012 standards as both were implemented together.

See the losses in Tables 2 through 4 below in ‘selection’ and ‘consumption’ of milk from the USDA study reflecting a 24% reduction in student selection of milk (offer vs. serve) after the 2012 fat-free/low-fat implementation and 10 to 12% reduction in consumption among those students being ‘served’ or selecting the restricted fat-free/low-fat white milk option or fat-free flavored milk option. That’s a double whammy for childhood nutrition and for dairy farm viability. Since 2012, at least one generation of future milk drinkers has been lost.

Charts above are from a USDA study published in 2015 to assess school meal selection, consumption, and waste before and after implementation of the new school meal standards in 2012. Those standards impacted a la carte offerings as well as beverages, not just served meals. The method for the USDA study was: Plate waste data were collected in four schools in an urban, low-income school district. Logistic regression and mixed-model ANOVA were used to estimate the differences in selection and consumption of school meals before (fall 2011) and after implementation (fall 2012) of the new standards among 1030 elementary and middle school children. Analyses were conducted in 2013. The authors note that prior to the full implementation of new nutrition standards in 2012, a variety of fat levels of milk were offered to students and no restriction upon flavored milks. See the report here —– Additionally, a PA school trial offering all fat percentages, including whole milk, revealed a 52% increase in selection of milk and 95% reduction in discarded milk, netting a 65% increase in consumption of milk in 2019.

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What does USDA’s ‘transitional’ standard on school milk REALLY mean?

USDA announced a ‘transitional standards’ rule on Feb. 4 for milk, whole grains, and sodium for school years 2022-2023 and 2023-2024. In short, the transitional standards are only in place while USDA works with stakeholders to strengthen meal standards through a new rulemaking for the longer term. The proposed rule for the longer-term is expected in fall 2022 and will be based on the Dietary Guidelines for Americans 2020-2025 — effective school year 2024-2025. A “gradual implementation” plan for the long-term standards will be developed by USDA based on ‘stakeholder input.’ Read the transitional standards rule and comment here. Stay tuned for proposed long-term standards rule and comment period this fall. Even the American Association of School Superintendents (AASA) made a statement this week, believing the long-term standards will be ‘more stringent’ due to the Dietary Guidelines, and that “it is important to acknowledge that healthy meals are only healthy if students eat them.” That goes for the milk also. Milk consumption plummeted and waste skyrocketed since USDA’s 2012 fat-free/low-fat milk rules were set for both ‘served’ milk and competing a la carte offerings.

By Sherry Bunting, Updated (above) since published in Farmshine, Feb. 11, 2022

WASHINGTON — USDA announced ‘transitional’ nutrition standards on Friday, Feb. 4 that put low-fat 1% flavored milk back on the menu next school year, without the cumbersome waiver process. The announcement also delays the planned sodium reductions, helping the cheese side of school lunches. 

National Milk Producers Federation (NMPF) and International Dairy Foods Association (IDFA) came out with hearty applause for the news, thanking Congressmen G.T. Thompson (R-Pa.), author of the Whole Milk for Healthy Kids Act, and Joe Courtney (D-Conn.), author of the School Milk Nutrition Act, for their leadership on this issue through the years, using words that treat this USDA announcement as though it’s a done-deal, and all is good to go. 

But let’s hold our horses and examine the USDA announcement — described clearly as “transitional” based on schools “needing more time to adjust” post-pandemic. 

USDA stated that future nutrition standards will be proposed in the fall of 2022 as part of the administration’s “Build Back Better with School Meals, input will be gathered, and those will be the standards that go into place beginning with the 2024-25 school year. 

USDA also made it clear that these future long-term standards “will line up with the Dietary Guidelines” and input from schools and industry will be sought in “how to gradually implement them.”

In 2010, the Healthy Hunger Free Kids Act of Congress tied government food and nutrition programs, like school lunch, to the Dietary Guidelines. By 2012, under President Obama’s USDA — with Tom Vilsack at the helm then as now — had banned whole milk as an a la carte offering in the ‘Smart Snacks’ rules. At the same time, the Department required flavored milk to only be offered if it was fat-free and required unflavored milk to be either fat-free or low-fat 1%.

Milk sales plummeted and waste increased.

Then, the Trump-USDA in 2018, under Ag Secretary Sonny Perdue, “rolled back” some of the 2012 USDA standards, delaying the sodium rules and allowing low-fat 1% flavored milk to be offered through a waiver system at the state level. Some states, like Pennsylvania, made blanket waivers available, and many schools began offering low-fat 1% flavored milk over the next few years.

Then, a lawsuit took the Trump-era USDA to court for the rollbacks. The court ruled that the Trump-USDA did not use a proper public comment process before doing the rollbacks. So, beginning with the 2021-22 school year, the low-fat 1% flavored milk was again bumped out of school menus — except where waivers were sometimes granted for pandemic-related supply disruptions as justification for serving a higher fat milk.

Over the past year, USDA Food Nutrition Services has received comments about how to gradually implement nutrition standards to line up with the Dietary Guidelines on sodium, whole grains, and milkfat. Friday’s announcement on ‘transitional standards’ was accompanied by a detailed and lengthy rule that will be implemented July 1, 2022.

“USDA is giving schools time to transition from current, pandemic operations, toward more nutritious meals. In 2022, USDA will continue to prioritize supporting schools as they navigate the challenges of the pandemic and related operational issues,” the announcement said, adding that USDA “is also planning for the future by engaging with school meal stakeholders to establish long-term nutrition standards beginning in school year 2024-2025 that will be achievable.”

Ag Secretary Tom Vilsack was quoted in the announcement blaming the pandemic disruptions of the past two years for making schools “unprepared to fully meet those standards at this time” for milk, whole grains and sodium.

“These transitional standards are step one of a longer-term strategy to lean into the school meal programs as a crucial part of improving child health,” said Vilsack.

“Over the coming months and years, USDA will work closely with its school meal partners to develop the next iteration of nutrition requirements. We’ve got to find the right balance between standards that give our kids the best chance at a healthy future based on the latest nutrition science, and ensuring those standards are practical, built to last, and work for everyone,” Vilsack added.

The purpose of the “transitional” standards, according to the USDA announcement, is to “give schools clarity for the coming school years, allowing them to gradually transition from the extraordinary circumstances caused by the pandemic to normal program operations and meal standards that are consistent with the latest nutrition science, as required by law.”

Specifically, the transitional standards beginning with the 2022-23 school year are as follows:

1) Milk: Schools and childcare providers serving participants ages six and older may offer flavored low-fat (1%) milk in addition to nonfat flavored milk and nonfat or low-fat unflavored milk;

2) Whole Grains: At least 80% of the grains served in school lunch and breakfast each week must be whole grain-rich; and

3) Sodium: The weekly sodium limit for school lunch and breakfast will remain at the current level in SY 2022-2023. For school lunch only, there will be a 10% decrease in the limit in SY 2023-2024. (This affects school cheese).

The expressed linkage of long-term USDA nutrition standards to the anti-fat 2020-25 Dietary Guidelines was mentioned throughout the USDA announcement, giving an indication of where the school milk standards are headed, long-term.

That is, unless Congress acts to remove all doubt and make fuller fat milk — whole milk — a legal option for schools in the future.

For a true solution for the long-term, Congressional leadership is needed on the school milk issue.

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FOOD FIGHT: USDA, Scholastic join billionaire-invested brand-marketing of ‘fakes’ in school meals, curriculum

The cover story of a recent Junior Scholastic Weekly Reader — the social studies magazine for elementary school students — was dated for school distribution May 11, 2021, the same week USDA approved a Child Nutrition Label for Impossible Burger and released its Impossible Kids Rule report. This label approval now allows the fake burger to be served in place of ground beef in school meals and be eligible for taxpayer-funded reimbursement. Meanwhile, Scholastic Weekly Reader and other school ‘curricula’ pave the marketing runway with stories incorrectly deeming cows as water-pigs, land-hogs, and huge greenhouse gas emitters, without giving the context of true environmental science.

Is USDA complicit? Or ring-leader? One Senator objects

By Sherry Bunting

WASHINGTON – It’s appalling. Bad enough that the brand of fake meat that has set a goal to end animal agriculture has been approved for school menus, fake facts (brand marketing) about cows and climate are making their way to school curriculum as well. The new climate-brand edu-marketing, and USDA has joined the show.

“Schools not only play a role in shaping children’s dietary patterns, they play an important role in providing early education about climate change and its root causes,” said Impossible Foods CEO Pat Brown in a May 11 statement after Impossible Meats received the coveted USDA Child Nutrition Label. “We are thrilled to be partnering with K-12 school districts across the country to lower barriers to access our plant-based meat for this change-making generation.”

U.S. Senator Joni Ernst (R-Iowa), who was born and raised on a rural Iowa family farm, has called on U.S. Agriculture Secretary Tom Vilsack to ensure students will continue to have access to healthy meat options at schools. The Senator’s letter to the Secretary asked that USDA keep political statements disincentivizing meat consumption out of our taxpayer-funded school nutrition programs.

Food transformation efforts are ramping up. These are political statements where cows and climate are concerned, not backed by science, but rather marketing campaigns to sell billionaire-invested fake foods designed to replace animals. (World Wildlife Fund, the dairy and beef checkoff sustainability partner, figures into this quite prominently.)

As previously reported in FarmshineImpossible Foods announced on May 11 that it had secured the coveted Child Nutrition Label (CN Label) from the USDA. The food crediting statements provide federal meal guidance to schools across the country. The CN label also makes this imitation meat eligible for national school lunch funding.

“This represents a milestone for entering the K-12 market,” the CEO Brown stated, adding that the use of their fake-burger in schools could translate to “huge environmental savings.” (actually, it’s more accurate to say it will translate to huge cash in billionaire investor pockets.)

Concerned about ‘political statements’ made by USDA and others surrounding the CN label approval — along with past USDA activity on ‘Meatless Mondays’ initiated by Vilsack’s USDA during the Obama-Biden administration —  Sen. Ernst wrote in her letter to now-again current Sec. Vilsack: “School nutrition programs should be exempt from political statements dictating students’ dietary options. Programs like ‘Meatless Monday’ and other efforts to undermine meat as a healthy, safe and environmentally responsible choice hurt our agriculture industry and impact the families, farmers, and ranchers of rural states that feed our nation.”

No public information has been found on how Impossible Foods may or may not have altered its fake-burger for school use. My request for a copy of the Child Nutrition Label from USDA AMS Food Nutrition Services, which granted the label, were met with resistance.

Here is the response to my request from USDA AMS FNS: “This office is responsible for the approval of the CN logo on product packaging. In general, the CN labeling office does not provide copies of product labels. This office usually suggests you contact the manufacturer directly for more information.”

I reached out to Impossible for a copy of the nutrition details for the school product. No response.

It’s obvious the commercial label for Impossible is light years away from meeting three big ‘nutrition’ items regulated by USDA AMS FNS. They are: Saturated Fat, Sodium, and Calories.

As it stands now, the nutrition label at Impossible Foods’ website shows that a 4-oz Impossible Burger contains 8 grams of saturated fat. That’s 3 more grams than an 8-oz cup of Whole Milk, which is forbidden in schools because of its saturated fat content. The Impossible Burger also has more saturated fat than an 85/15 lean/fat 4-oz All Beef Burger (7g).

Sodium of Impossible Burger’s 4-oz patty is 370mg! This compares to an All Beef at 75g and a McDonald’s Quarter-pounder (with condiments) at 210 mg. Whole Milk has 120 mg sodium and is banned from schools.

The Impossible Burger 4-oz. patty also has more calories than an All Beef patty and more calories than an 8 ounce cup of Whole Milk. But there’s the ticket. USDA is hung up on percent of calories from fat. If the meal is predominantly Impossible Burger, then the saturated fat (more grams) become a smaller percent of total calories when the fake burger has way more calories! Clever.

In her letter to Vilsack, Sen. Ernst observes that, “Animal proteins ensure students have a healthy diet that allows them to develop and perform their best in school. Real meat, eggs, and dairy are the best natural sources of high quality, complete protein according to Dr. Ruth MacDonald, chair of the Department of Food Science & Human Nutrition at Iowa State University. Meat, eggs, and dairy provide essential amino acids that are simply not present in plants. They are also natural sources of Vitamin B12, which promotes brain development in children, and zinc, which helps the immune system function properly.”

She’s right. A recent Duke University study goes behind the curtain to show the real nutritional comparisons, the fake stuff is not at all nutritionally equivalent. But USDA will allow our kids to continue to be guinea pigs.

In May, Ernst introduced legislation — called the TASTEE Act — that would prohibit federal agencies from establishing policies that ban serving meat. She’s looking ahead. Sen. Ernst is unfortunately the only sponsor for this under-reported legislation to-date.

Meanwhile, within days of the Impossible CN approval from USDA, school foodservice directors reported being bombarded with messaging from the school nutrition organizations and foodservice companies, especially the big one — Sodexo — urging methods and recipes to reduce their meal-serving carbon footprint by using less beef for environmental reasons, and to begin incorporating the approved Impossible.

The Junior Scholastic Weekly Reader for public school students across the nation — dated May 11, the same day as the USDA CN Label approval for ‘Impossible Burger’ — ran a cover story headlined “This burger could help the planet” followed by these words in smaller type: “Producing beef takes a serious toll on the environment. Could growing meat in a lab be part of the solution?”

The story inside the May 11 scholastic magazine began with the title: “This meat could save the planet” and was illustrated with what looked like a package of ground beef, emblazoned with the words: “Fake Meat.”

Impossible Foods is blunt. They say they are targeting children with school-system science and social studies (marketing disguised as curriculum) — calling the climate knowledge of kids “the missing piece.”

In the company’s “Impossible Kids Rule” report, they identify kids as the target consumer for their products, and how to get them to give up real meat and dairy.

Toward the end of the report is this excerpt:“THE MISSING PIECE: While most kids are aware of climate change, care about the issues, and feel empowered to do something about it, many aren’t fully aware of the key factors contributing to it. In one study, 84% of the surveyed young people agreed they needed more information to prevent climate change. Of the 1,200 kids we surveyed, most are used to eating meat every week—99% of kids eat animal meat at least once a month, and 97% eat meat at least once a week. Without understanding the connection between animal agriculture and climate change, it’s easy to see why there has been so little action historically on their parts. Kids are unlikely to identify animal agriculture as a key climate threat because they often don’t know that it is. Similar to adults, when we asked kids what factors they thought contributed to climate change, raising animals for meat and dairy was at the bottom by nearly 30 points.

After showing the impressionable children Impossible marketing, they saw a big change in those “awareness” percentages and noted that teachers and schools would be the largest influencers to bring “planet and plate” together in the minds of children, concluding the report with these words:

When kids are educated on the connection between plate and planet
and presented with a delicious solution, they’re ready to make a change. And adults might just follow their lead,” the Impossible Kids Rule report said.

USDA is right with them, piloting Impossible Burger at five large schools using the Impossible brand name to replace ground beef with fake meat in spaghetti sauce, tacos and other highlighted meals. This allows brand marketing associated with the name — free advertising to the next generation disguised as “climate friendly” options with marketing messages cleverly disguised as “education.”

In the New York City school system, one of the pilot schools for Impossible, new guidelines are currently being developed to climate-document foods and beverages served in the schools.

Impossible doesn’t have a dairy product yet, but the company says it is working on them.

Impossible’s competitor Beyond Meat is also working on plant-based protein beverages with PepsiCo in the PLANeT Partnership the two companies forged in January 2021. PepsiCo is the largest consumer packaged goods company globally and has its own K-12 Foodservice company distributing “USDA-compliant” beverages, meals and snacks for schools.

How can this brand-marketing in school meals be legal? Dairy farmers pay millions to be in the schools with programs like FUTP60 and are not allowed to “market”. In fact, dairy checkoff leaders recently admitted they have a 12-year “commitment” to USDA to “advance” the low-fat / fat-free Dietary Guidelines in schools, top to bottom, not just the dairy portion.

Pepsico has a long history of meal and beverage brand-linking in schools. Working with Beyond, they will assuredly be next on the Child Nutrition alternative protein label to hit our kids’ USDA-controlled meals.

Like many things that have been evolving incrementally — now kicking into warp speed ahead of the September 2021 United Nations Food System Transformation Summit — the taxpayer-funded school lunch program administrated by USDA is a huge gateway for these companies. Ultimately, will parents and children know what is being consumed or offered? Who will choose? Who will balance the ‘edu-marketing’? Will school boards and foodservice directors eventually even have a choice as huge global companies mix and match proteins and market meal kits that are guaranteed to be USDA-compliant… for climate?

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Dietary Guidelines Committee must be stopped, its flawed upcoming report excludes rigorous fat studies

ThenAndNow_DGAs_web

Drawings by Heidi Krieg Styer as published on Farmshine cover, June 12, 2020 edition

By Sherry Bunting, Farmshine, June 12, 2020

WASHINGTON, D.C. — As we have reported for several years now, there is this thing called the Dietary Guidelines for Americans that most people think is simply government guidance of how Americans should eat to be healthy, and that we can take – or leave – that advice based on our own choices and understanding of the science.

Wrong!

The Dietary Guidelines for Americans increasingly control our choices in ways subtle and obvious, especially where our children are concerned and especially where the poorest among us are concerned.

They began in the 1980s and are updated every five years by a Dietary Guidelines Advisory Committee. Since 2000, these Guidelines have become more restrictive, and in 2010 — under the Obama administration with Ag Secretary Tom Vilsack implementing measures to ban whole milk in schools and then lobbying for the bill, Congress took the step that linked the guidelines more closely than ever to our schoolchildren through the Healthy Hunger-Free Kids Act. The bill is anything but what its name implies.

At the same time, Americans have continued to grow fatter, sicker and sadder as the limits on saturated fat have grown stricter and the federal control more pervasive.

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Most of the ‘experts’ on the DGA Committee are free to choose their own meal pattern. Our schoolchildren, our poor, our chronically ill, our elderly, our military, our economically and nutritionally at-risk persons — their dietary choices are controlled by the DGA. According to the CDC, these are the demographic populations dealing with the most pervasive rise in obesity, diabetes and other chronic illnesses many scientists believe are rooted in the DGAs.

For 40 years, the advice coming from the Dietary Guidelines Advisory Committee every five years, and then virtually rubber-stamped by the Secretaries of Agriculture and Health and Human Services, has led Americans down an unhealthy road. The Committee pushes vegetarian eating patterns, high carb / low fat dogma, and increasingly strict saturated fat restrictions despite sound science to the contrary.

The process needs reform, according to the Academies of Sciences.

The 2020-25 Dietary Guidelines draft will be released next Wednesday, June 17 by the current Dietary Guidelines Advisory Committee (DGAC), and as the Nutrition Coalition and others have been warning, this draft is bad for Americans, bad for our children, and bad for our dairy and livestock producers.

What’s more, this draft is based on the deliberations of a committee that excluded rigorous studies showing the saturated fat in milk and dairy products is actually GOOD for us, especially for our children, and that it has little if any negative effect on cardiovascular health and all-cause mortality, with positive effect on Type II diabetes, obesity, cognition, brain function and mood.

Quite literally, the DGAC, Secretaries of Ag and HHS (even Congress and past and present administrations) — in their infinite wisdom and refusal to turn this Titanic away from the iceberg – are happy to watch American health sink, and the survival of our farmers and ranchers to sink right along with it.

If ever there was a time for action (and believe me, this chorus I’ve sung quite a few times since the year 2000), it is now!

Contact your Senators and Representatives in Washington and ask them to urge Secretaries Perdue and Azar to delay this DGAC report until all of the science is considered.

It is unconscionable that USDA – through its strange screening process that includes “conformance to current federal policy” implemented by department interns – was the first layer prohibiting rigorous science from the DGAC work over the past year.

It is even more deleterious that the DGAC further refined the science included in the saturated fat questions to illogical parameters that no other DGAC subcommittee used for its screening process.

Americans are smart. They are choosing whole milk and full-fat dairy products because they are learning about the science that was buried and suppressed over the past 40 years as well as the new studies surfacing.

But that’s only good for the wealthy adults among us. Children are ruled by DGAC decisions, thanks to Congress. Those suffering poor health are ruled by DGAC decisions because medical professionals tend to regurgitate them.

Families in need are perhaps MOST controlled by DGAC decisions because they rely on government feeding programs that must meet these fat-restricting Dietary Guidelines, but are issued SNAP cards that allow them to buy soda and cheap snacks full of carbohydrates that do nothing nutritionally for them.

Amid the COVID-19 crisis, how many times have we heard that the obesity and diabetes in our population, especially the poor, increases how harmful this virus is to certain populations, demographically? With these guidelines governing USDA feeding programs, it’s no wonder.

Shameful!

Not to mention, a year ago, military generals crafted a letter to Congress over their concerns about recruits being too obese or unhealthy to serve. Yes, the military is another sector of government-feeding that is tied to the flawed Dietary Guidelines for Americans.

So, big deal, my family can still choose. Right? For many families, those choices are made for them when dining out as restaurants increasingly document calories, saturated fat and other information on menus. This is required by the federal government for chain restaurants of a certain size. More of these restaurants admit to using “stealth health” to make adjustments to meals to show that they are meeting – you guessed it – the Dietary Guidelines.

In fact, the Food and Drug Administration (FDA) began its multi-year Nutrition Innovation Strategy, whereby it is seeking to “modernize” standards of identity to “achieve nutritional goals.” FDA also is designing a “good for you” symbol that foods will only get if they meet the criteria being developed. The agency in its meetings over the past year, cited reduced consumption of fat and salt as primary nutritional goals, and have made statements such as “American consume too much protein.” The FDA’s “modernization” of food labeling and standards of identity will certainly move forward under the good ‘ole Dietary Guidelines.

Meanwhile, when it comes to the simple “choice” of whole milk or even 2% in schools and daycares for children over two years of age, these wholesome products are outright banned because of the Dietary Guidelines. In fact, not only does the government require non-fat and 1% milk to be served, cheese and yogurt are also limited to low- and non-fat.

When fat is removed from the diet, carbs and sugars replace it, and foods are not consumed that bring tons of nutrients and vitamins to the table.

Here we are at a crossroads in our nation’s health. Obesity and diabetes are reaching epidemic proportions in our children. Iron, iodine, calcium, and certain vitamins, especially fat-soluble vitamins found in whole fat dairy and meats are nutrients of concern. Doctors are finding Americans, especially children and teens, are deficient in these nutrients when low-fat Dietary Guidelines rule the plate.

The only thing that can possibly turn the Titanic as it is already crashing on the iceberg is a groundswell of letters, phone calls, emails and faxes to members of Congress, Secretary of Agriculture Sonny Perdue, Secretary of Health and Human Services Alex Azar, even the President of the United States.

Sheer numbers are needed. To-date, medical and health professionals, scientists, teachers, parents, citizens have commented on the DGAC docket. Many have written letters and opinions, forwarded research that has been excluded, pointed out the flaws in research that was included.

Now Congress needs to hear from their constituents. There’s a war to win for our health and our farmers.

Concerned citizens have met with members of Congress over the past year on issues such as whole milk in schools, and yet the Whole Milk for Healthy Kids Act, House bill 832, and Milk in Lunches for Kids Act, Senate Bill 1810, have stalled at 41 and 3 cosponsors, respectively, which is where they were in October when I went to Washington with the first 10,000 of the 30,000 names on the Whole Milk Choice in Schools petition.

There are heavy hitters on the other side of this fat discussion. Never mind the animal and climate activists with their facts all jumbled up, there are huge investments in the future of food by powerful people who want to see the Dietary Guidelines continue the current path.

Processed With Darkroom

Part of the screening process used by USDA for science that will be included or excluded from Dietary Guidelines Advisory Committee consideration is this curious item shown above: “Framed around relevancy to U.S. Federal  Policy”. Committee members in October asked for more information on this research screening criteria. USDA explained it to them and those watching that this refers to including only the research that “aligns with current federal policy.”

While I was in Washington in October, my eyes were opened. I sat in on the DGAC meeting and wrote about it in Farmshine. There, I learned that one of the screening criteria by USDA for determining what science was “in” or “out” of the DGAC process is this strange point: “relevancy to U.S. federal policy.” When a question was asked by a member of the committee about that point, it was explained as “research inclusion that conforms or aligns with current federal policy”.

That, my friends, is the unelected bureaucracy feeding itself and pretending to have the scientific basis to use diet to achieve other goals.

I visited Senator Bob Casey (D-Pa.) that day and asked his staffer why Sen. Casey would not support Senator Pat Toomey’s (R-Pa.) Milk in Lunches for Schools bill.

The response? “We (Congress) are not a scientific body. We have a process for that, the Dietary Guidelines.”

Yep. There it is again.

When pressed further, asking how citizens – constituents — can redress their concerns with ELECTED officials if that committee stands in the way, I was surprised to hear the staffer note that National Milk Producers Federation (NMPF) did not support Sen. Toomey’s bill. I had identified myself as a member of the Grassroots PA Dairy Advisory Committee but also as a mother, grandmother and former school board director, but the answer I was given honed-in on my “dairy” reference.

I was told by the Casey staffer that NMPF did not support Toomey’s Senate bill on whole milk because it included language that would not just allow the choice of whole milk, but would also exempt school milk choices from the “10% calories from saturated fat limit.”

Later, I contacted NMPF and spoke with one of their lobbyists who confirmed that NMPF did not support the Toomey bill language. They did not want that exemption for milk because they said they believed “we can win the fat argument.”

dga1Meanwhile, on the day of my trip to Washington in October, as I posted a photo on facebook of USDA Food and Nutrition Services undersecretary Brandon Lipps in front of the Dietary Guidelines sign at the DGAC meeting in the USDA building, I recalled his words to me, that the department loves milk, but that the “science” needs to come together, and that the industry needs to be on the same page. (I had just handed him his copy of the first 10,000 signatures on the whole milk in schools petition)

Mr. Undersecretary, how can “the science” come together when your USDA interns and DGAC members left a lot of the good science on the cutting room floor and effectively screened it out of the “coming together” process these 5-year DGAC cycles are intended to address?

As I walked out of the USDA building to meet with legislators on that day in October 2019, I noticed a post on my facebook newsfeed from Hoard’s Dairyman quoting DMI CEO Tom Gallagher as follows:  “Now, we’re not sure if it will be in this go-around with the Dietary Guidelines for Americans . . . but I believe by the next Dietary Guidelines we will get the fat story reversed,” said Gallagher. “That opens up the door to whole milk products and other dairy products in schools, which would be a big plus.”

Already in October, when the DGAC process was near its beginning, the top national dairy checkoff leader was publicly admitting defeat. Or, was he actually telegraphing the wishes of DMI “partners” to USDA, another partner, that they’d prefer to keep stalling it.

In this quote, Gallagher makes it look like DMI supports whole milk in schools, while at the same time stalling a change in policy and conceding to a defeat in 2020 before the game got off the ground — while diverting everyone’s attention to 2025.

Back in 2014-15, I was involved in that DGAC cycle, writing several columns for a metropolitan newspaper. Same story, different year. You’ll find lots of background here.

At the time, I asked checkoff leaders at a dairy meeting why they weren’t involved in turning this around on saturated fat and why were they not more vocal in the guidelines process. I was told in 2015, that they were working on it for 2020.

Stall, delay, stall.

Our kids and our farmers don’t have 5 more years to get 40 years of wrong and 10 years of really-really-wrong, right.

This week, I was pleased to see Bob Gray who has represented the Northeast Council of Dairy Cooperatives sent out a memo to industry colleagues citing what Nina Teicholz and the Nutrition Coalition have been sounding the alarm about. He urged people to contact members of Congress and ask them to get a delay in the release of the DGAC 2020-25 report, to keep it from being released next Wednesday, and to keep it off the table until the science that was excluded is considered.

Unfortunately, at other levels of industry involvement, the response is a shrug.

For example, two weeks ago, I heard from a dairy farmer who contacted her regional dairy checkoff organization and asked for help distributing whole milk gallons to families in need at her local school during lunch pickup.

“You can’t do that,” she was told. “It’s not allowed.”

Unfazed, she contacted the school and the processor anyway, on her own, and both were enthusiastic about making her idea happen. She and her husband purchased the whole milk with their own money – 200 gallons of it – and they stood beside the school foodservice folks and gave it to families driving through picking up school lunches.

Additionally, ADA Northeast is a regional checkoff organization that has indicated to dairy farmers that their taste tests in cities show children don’t really notice the difference between whole milk and 1% low-fat milk, and that consumption of milk did not increase when whole milk was offered, but that consumption did increase when 1% chocolate milk was offered instead of just non-fat chocolate milk.

For the industry – it’s all about the 1% milk in schools. In fact, if the DGAC report is released next Wednesday and gets on its way to USDA / HHS approval, 1% milk will be kissed goodbye in schools as well because the DGAC is doubling-down on saturated fat levels, not loosening them.

Meanwhile, a high school / middle school trial in western Pennsylvania would put these checkoff findings to shame. Teenagers given the choice of whole milk this school year favored whole milk three to one over 1% low-fat milk. The milk choices were put in front of them with no information, and within a short time, they figured it out on their own. Within five months of students having this choice of whole milk, teenagers were consuming 65% more milk and the amount of milk being discarded fell by 95%.

On every level – nutrition, satiety, sustainability, environment – you name it, that’s a win. A win that schools and children will not get to realize if the DGAC issues its 2020-25 report doubling-down on saturated fat.

This Dietary Guidelines scandal has many players and parties involved – and it’s obvious by now this has nothing whatsoever to do with “the science.”

Contact your Senators and Representatives as soon as possible before Wed., June 17 and ask them to urge Sec. Perdue and Sec. Azar to delay the DGAC report and to send the committee back to the drawing board to include the science they left out.

If you don’t know who represents you in Washington, use this link to plug in your home address at this link to find out: 

Also, register your comment with Secretaries Perdue and Azar here

Let’s get this Titanic turned around. We don’t have 5 more years to waste. Who’s with me?

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