Revising School Lunch Program Patterns

CFA commends the efforts of the Food and Nutrition Service of the U.S. Department of Agriculture to address the need for better nutrition for our nation's school children. We support your efforts in applying the best science to government policies related to food and nutrition delivery.

Meeting the ambitious and laudable goals of the proposed rule will not come without added costs, however. As the proposed rule notes, increasing the availability of fruits, vegetables and whole-grain foods, with an emphasis on whole foods, will result in increased food costs. There is also added labor cost associated with training food-service staff to prepare whole foods as the reliance on prepared foods is decreased. In addition, there may be costs associated with new equipment acquisition that would be necessary to accommodate new on-site preparation methods and food storage.

Canned products are uniquely positioned to successfully address many of these challenges. Canned products provide consistent quality and year-round availability, delivering a safe product that requires less kitchen labor and equipment. Canned foods can have a lower unit cost and a lower environmental impact compared to other forms, as well.

Key supporting points and data about canned fruits, vegetables and beans:

  • Canned fruits and vegetables deliver key nutrients: A University of California-Davis study published in the Journal of the Science of Food and Agriculture 1 concluded that exclusively recommending one form of fruit or vegetable (canned, fresh, frozen or dried) over another ignores the benefits that each form provides. A study from the University of Illinois found that canned foods are comparable to cooked, fresh and frozen varieties in their nutrient contribution to the American diet.2

  • Canned beans and legumes do not require extensive preparation time or additional staff training on preparation techniques: Adding beans, legumes and lentils to the diet can help close the fiber gap, a goal emphasized in the 2010 Dietary Guidelines for Americans. As canned beans and legumes are already prepared, only heating is required to serve, making them a convenient and cost-effective food to help meet fiber nutrient needs. They are also a good/excellent source of plant-based protein.

  • Canned corn, peas and lima beans and other starchy vegetables are palatable to kids and help provide good/excellent sources of four nutrients of concern: The CFA supports the consumption of a variety of vegetables. However, CFA does not support prescribing specific selections and does not support the proposed limits on starchy vegetables. School food authorities should be encouraged to vary vegetable selections for healthier school meals, as is currently done in the HealthierUS School Challenge. We believe schools should have the flexibility to determine how to integrate a variety of vegetables, including corn, peas, and lima beans, in their menus to maximize actual consumption (as opposed to serving vegetables that end up left on food trays or dumped in the trash) and manage costs.

  • Canned soups offer a child-friendly method of increasing the amount of vegetables and grains consumed by school children: The proposed rule discusses "combination foods," but does not specifically mention prepared soup. Canned soup offers an excellent vehicle for delivering vegetables and whole grains in a "child approved" form.

  • Canned tomato paste should continue to be credited based on its calculated whole tomato equivalent: CFA recommends continuing current tomato paste crediting as outlined in the Food Buying Guide for Child Nutrition Programs at pages 2-3. "Vegetable and fruit concentrates are allowed to be credited on an 'as if single-strength reconstituted basis' rather than on the actual volume as served." Using a volume-served basis for crediting tomato paste and tomato puree does not consider the important nutritional contributions of tomatoes and their concentrates to the diets of children. Eliminating the vegetable credit from tomato paste-based products discourages the use of tomatoes as an economically viable source of vegetables in school meals. The potential effect is to decrease consumption of a popular vegetable that contains vitamins A and C, potassium (a nutrient of concern under the 2010 DGA) and lycopene.

Key supporting points and response on sodium in canned foods:

The food industry continues to make inroads regarding the reduction of sodium levels. In order to meet the needs for food acceptability, modifications must be made carefully. While the IOM's goal of sodium reductions over a ten-year period allowed for phase-ins, it is an ambitious goal that should be coupled with practical experience.

CFA also believes that allowances should be made for naturally occurring sodium, including revising sodium targets to compensate for naturally occurring sodium. Unless allowances for naturally occurring sodium are made, the proposed rule may have the unintended consequence of requiring even more stringent reductions in the sodium levels of processed foods which may not be obtainable without degrading the acceptability of the final product.


  • Canned foods maximize cash-value benefit: Canned foods are often less expensive than their fresh counterparts. Therefore, canned fruits, vegetables, meat, seafood and beans may offer a lower per unit cost alternative for budget-conscious governments and school districts as they strive to meet the nutrient criteria outlined in the proposed rule.

  • Canned foods have a long shelf-life, reducing waste from spoilage and eliminating the need for additional refrigerated storage: The canning process locks in nutrients at their peak of freshness and, due to the lack of oxygen during storage periods, canned foods' nutrient levels remain relatively stable up until the time they are consumed.1 Canned foods can be stored at room temperature, negating the need for school districts to purchase additional cold storage to meet increased fruit and vegetable requirements.

  • Canned meats, seafood and beans offer convenient and affordable sources of protein to meet nutrient requirements: Canned meats, seafood and beans require minimal preparation, offering a quick, easy-to-prepare source of protein. Canned protein does not require extensive on-site preparation. Low-sodium versions of these products are increasingly available, and many canned meats and seafood are low in fat and cholesterol.

  • Canned foods reduce food safety concerns: Steel cans provide protection from outside contaminants, such as oxygen, water and light, helping to keep nutrients in and impurities out.

1 Rickman, J., Barrett, D. and Bruhn, C. "Nutritional comparison of fresh, frozen and canned fruits and vegetables." Journal of the Science of Food and Agriculture, Vol. 87. Issues 6 and 7. April and May 2007.
2 Klein, B. and Kaltez, R. Nutrient conservation in canned, frozen, and fresh foods. University of Illinois. 1997.