Whole Grains in the School Meal Programs Healthy Kids, Healthy Programs Summit Four Points by Sheraton, Norwood, MA May 21, 2015 Presented by: Linda Fischer, M.Ed., RD, LDN

Objectives/Agenda Participants will become familiar with:  Whole Grain-Rich (WGR) criteria  Grain exemption/waiver requirements  How to Calculate Ounce Equivalencies  Creditable versus Non-Creditable Grains Massachusetts Department of Elementary and Secondary Education 2

 Beginning SY , all grains offered must be whole grain-rich in order to credit toward the grains component* * Unless a Whole Grain Rich Product Exemption or Pasta Waiver is requested through the State Agency Massachusetts Department of Elementary and Secondary Education 3 Grains Component (for Lunch and Breakfast)

 An exemption or waiver form must be completed and submitted to the State Agency for approval  Certain criteria must apply to qualify:  Financial hardship  Limited product availability  Unacceptable product quality  Poor student acceptability * Massachusetts Department of Elementary and Secondary Education 4 Requesting an Exemption/Waiver

 Documentation must be provided to substantiate the hardship incurred Acceptable documentation includes:  Menus  Photos  Meal count records  Daily income statements and/or production records for dates of service Massachusetts Department of Elementary and Secondary Education 5 Requesting an Exemption/Waiver

 Whole Grain Rich Product Exemption or Pasta Waiver forms may be found in the Document and Reference Library section of the ESE Security Portal Massachusetts Department of Elementary and Secondary Education 6 Where Can I Get an Exemption/Waiver Form?

1)Foods that contain 100 percent whole grain 2)Foods with a blend of whole-grain meal and/or flour and enriched meal and/or flour of which at least 50 percent is whole grain. Let’s look at the 50 Percent Guideline a bit closer Massachusetts Department of Elementary and Secondary Education 7 What Foods Meet the Whole Grain-Rich Criteria?

The 50 percent guideline for whole grain- rich requires that the grain content of a product contain:  50-percent or more whole grains by weight and  the remaining grain, if any, must be enriched Massachusetts Department of Elementary and Secondary Education 8 The 50 Percent Guideline

For example:  A school has a recipe for homemade dinner rolls containing a total of 6 cups of flour  3 cups of whole wheat flour  3 cups of enriched white flour This would meet the 50 percent whole grain-rich requirement because 50% of the product is made with whole wheat flour and the remaining 50% of the product is made with enriched white flour Massachusetts Department of Elementary and Secondary Education 9 The 50 Percent Guideline

School must evaluate a grain product using the following two-elements set forth in the final rule Element #1:  A serving of the food item must meet portion size requirements for the grains/breads component as defined in Food and Nutrition Service (FNS) guidance.  Exhibit A (grain chart): School Lunch and Breakfast Massachusetts Department of Elementary and Secondary Education 10 Whole Grain-rich Criteria

Element #2: Food must meet at lease one of the following: 1.The whole grains per serving (based on minimum serving sizes specified for grains/breads in FNS guidance) must be  8 grams  This may be determined from information provided on the product packaging, if available or from information provided by the manufacturer (i.e. product formulation statement) Massachusetts Department of Elementary and Secondary Education 11 Whole Grain-rich Criteria

2.The product includes the following FDA- approved whole-grain health claim on the packaging.  “Diets rich in whole grain foods and other plant foods, and low in total fat, saturated fat and cholesterol may reduce the risk of heart disease and certain cancers.” or  “Diets rich in whole grain foods and other plant foods, and low in saturated fat and cholesterol, may help reduce the risk of heart disease.” Massachusetts Department of Elementary and Secondary Education 12 Whole Grain-rich Criteria

Massachusetts Department of Elementary and Secondary Education 13 FDA Approved Whole Grain Health Claim

3.Whole grain is listed first in the product ingredient declaration  Non-mixed dishes (e.g., breads, cereals): Whole grains must be the primary ingredient by weight (a whole grain is the first ingredient listed in the label declaration)  Mixed dishes (e.g., pizza, corn dogs): Whole grains must be the primary grain ingredient by weight (a whole grain is the first grain ingredient listed in the label declaration) Massachusetts Department of Elementary and Secondary Education 14 Whole Grain-rich Criteria

Massachusetts Department of Elementary and Secondary Education 15 Whole Grain listed first in Ingredient Declaration

Q. What do we do when the whole grain content comes from multiple ingredients and whole grain is not the first ingredient listed on the label declaration? A. A written product formulation statement must be provided by the company or manufacturer showing the whole grains are the primary ingredient by weight even though a whole grain is not listed as the first ingredient Massachusetts Department of Elementary and Secondary Education 16 Whole Grain from Multiple Ingredients

Massachusetts Department of Elementary and Secondary Education 17 To Evaluate this Product: A product formulation statement is required to determine: 1)How much enriched wheat flour is in this product? 2)How much whole wheat flour is in this product?

Calculating Ounce Equivalencies Massachusetts Department of Elementary and Secondary Education 18

1.Calculating based on total weight of creditable product by using Exhibit A (Grain Chart) for School Lunch and Breakfast 2.Calculating based on grams of creditable grain ingredient by using Product Formulation Statements provided by manufacturers  NOTE: All grains are measured in ounce equivalents and must be rounded down to the nearest quarter ounce Massachusetts Department of Elementary and Secondary Education 19 There are Two Ways to Calculate Oz Equivalencies

1) Calculating Oz Equivalencies Based on Total Weight of Creditable Product  Use Exhibit A (Grain Chart) for School Lunch and Breakfast Massachusetts Department of Elementary and Secondary Education 20

Steps for Calculating Oz Equivalents Step 1:Obtain information from the food label One frosted pop tart = 50 grams (1.76 oz) Step 2: Obtain ounce equivalent information from Exhibit A Group E 1 oz eq = 69 grams or 2.4 oz Step 3: Take the weight of the item and divide by grams or weight in ounces and round down to the nearest quarter ounce 50 grams  69 = 0.72 .50 oz eq 1.76 oz  2.4 oz = 0.73 .50 oz eq 21 1 pop tart toaster pastry (frosted) = 50 grams (1.76 oz)

Massachusetts Department of Elementary and Secondary Education 22

Steps for Calculating Oz Equivalents Step 1: Obtain size/weight information from the food label One bar = ___________________________ Step 2: Obtain ounce equivalent information from Exhibit A – Group _____; 1 oz eq. = _______________________ Step 3: Take the weight of the item and divide by grams or weight in ounces and round down to the nearest quarter ounce 23 1 cereal bar (plain)

Steps for Calculating Oz Equivalents Step 1:Obtain information from the food label One bar = 40 grams (1.42 oz) Step 2: Obtain ounce equivalent information from Exhibit A – Group D 1 oz eq = 55 grams or 2.0 oz Step 3: Take the weight of the item and divide by grams or weight in ounces and round down to the nearest quarter ounce 40 grams  55 = 0.73 .50 oz eq 1.42 oz  2.0 oz = 0.71 .50 oz eq 24 1 cereal bar (plain) = 40 grams (1.42 oz)

Massachusetts Department of Elementary and Secondary Education 25 For Group I items, the volumes or weights listed must be offered to credit as one ounce equivalent This item alone does not meet the minimum one ounce equivalent for Group I

2) Calculating Oz Equivalencies Based on Grams of Creditable Grain Ingredient Massachusetts Department of Elementary and Secondary Education 26

Creditable Grain in Products How do I determine the amount of creditable grain ingredient contained in a product? 1.From information provided on the product packaging, if available. 2.From product formulation statements provided by the manufacturer, if available. Massachusetts Department of Elementary and Secondary Education 27

Creditable Grain in Products  Grain items listed in Groups A-G (of Exhibit A) may be calculated on the basis of 16 grams of creditable grain per serving.  Products can be made with 8 grams of whole-grain and 8 grams of enriched meal and/or enriched flour to be considered WGR.  Products in Group H and I must contain 28 grams of creditable grain per serving or use the weights or volumes listed in Exhibit A. Let’s look at some examples… Massachusetts Department of Elementary and Secondary Education 28

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Q. Can schools use the Whole Grain Stamp (from the Whole Grain Council) to determine if a food product meets the WGR criterion? A. The Whole Grain Stamp provides useful information to suggest the product contains the proper amount of whole grains, but the content of the whole grain must still be matched against the serving size requirements in the school meal patterns. Massachusetts Department of Elementary and Secondary Education 31 Grains Component (for Lunch and Breakfast)

Q. Are schools allowed to use statements from products/packaging or company factsheets to determine meal pattern equivalents? 32 Grains Component (for Lunch and Breakfast)

A. Product labels and company factsheets are a good way for food manufacturers to communicate with school program operators about how their products may contribute to the meal pattern requirements, however, unless the product contains a CN label, the product must still be evaluated as a WGR product and matched against the serving size requirements in the school meal patterns. Massachusetts Department of Elementary and Secondary Education 33 Grains Component (for Lunch and Breakfast)

Child Nutrition (CN) Labels  What are Child Nutrition Labels? Allows manufacturers to state the contribution on their labels. The program provides a warranty against audit claims for purchasers of CN labeled products  How does the Program work? Requires an evaluation of a product's formulation by FNS to determine its contribution toward meal pattern requirements Massachusetts Department of Elementary and Secondary Education 34

Child Nutrition (CN) Labels Are CN Labels Required? No!  Manufacturers are NOT required to obtain CN labels for their products  Schools are NOT required to purchase products with a CN label Massachusetts Department of Elementary and Secondary Education 35

How do I identify a CN label? In addition to required labeling features, a CN label will always contain the following:  The CN logo (which is a distinct border) The meal pattern contribution statement  A 6-digit product identification number  USDA/FNS authorization statement  The month and year of approval Massachusetts Department of Elementary and Secondary Education 36

37 SAMPLE (CN) Label

Product Formulation Statements (PFS)  Demonstrates how a processed product contributes to meal pattern requirements.  Would request when purchasing a processed product without a CN Label.  Program operators may request a signed Product Formulation Statement on manufacturers’ letterhead that must be maintained on file along with nutrient information. If there is no Nutrition Facts panel on the processed product, nutrient information must be obtained from the manufacturer. Massachusetts Department of Elementary and Secondary Education 38

Product Formulation Statements (PFS)  Program operators are ultimately responsible if a menu does not fulfill meal pattern requirements; therefore they must keep records of supporting documentation.  It is the program operator’s responsibility to request and verify that the supporting documentation is accurate. Massachusetts Department of Elementary and Secondary Education 39

 USDA Policy Memo (TA (v.3), November 26, 2014  Tip Sheet for Accepting Processed Product Documentation  Child Nutrition (CN) Labeled Products  Product Formulation Statements (PFS)/Other Documentation Massachusetts Department of Elementary and Secondary Education 40 Guidance for Accepting Processed Product Documentation for Meal Pattern Requirements

Creditable Versus Non-Creditable Grains Massachusetts Department of Elementary and Secondary Education 41

Creditable Grains in school meal programs are:  whole meal, whole four, enriched meal, and enriched flour. Non-Creditable Grains are those that are not whole or enriched. These include:  oat fiber, corn fiber, wheat starch, corn starch, bran, germ, and modified food starch (including potato, legume and other vegetable flours). Massachusetts Department of Elementary and Secondary Education 42 Creditable Versus Non-Creditable Grains

 If purchased grain products include non- creditable ingredients, they must be present at a level of less than 2% of the product formula (or less than 0.25 oz eq.) for the grain product to be creditable at lunch or breakfast. 43 Creditable Versus Non-Creditable Grains

44 For Additional Information on Grains …

Resources USDA – Child Nutrition (CN) Labeling Program USDA – Food Fact Sheets: USDA – New Meal Pattern in Schools: U.S. Department of Agriculture Food and Nutrition Service, July USDA – Nutrition Standards for School Meals: