Comments to FNS re: Fresh Fruit and Vegetable Pilot Program for Canned, Frozen and Dried Produce

September 8, 2014
Desk Officer for Agriculture
Office of Information and Regulatory Affairs
Office of Management and Budget
Departmental Clearing Office, USDA, OCIO
Mail Stop 7602
Washington, DC 20250-7602

RE: Evaluation of the Pilot Project for Canned, Frozen, or Dried Fruits and Vegetables in the Fresh Fruit and Vegetable Program (OMB Control Number 0584-NEW)

Dear Sir or Madam,

The Academy of Nutrition and Dietetics (the “Academy”) appreciates the opportunity to submit comments to the United States Department of Agriculture’s (USDA’s) August 8, 2014 comment request regarding the proposed “Pilot Project for Canned, Frozen, or Dried Fruits and Vegetables in the Fresh Fruit and Vegetable Program.” Representing over 90,000 registered dietitian nutritionists (RDNs),1 dietetic technicians, registered (DTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States committed to improving the nation’s health through food and nutrition across the lifecycle. The Academy’s members demonstrate this commitment in part by working to implement the FFVP in school districts and conduct research to enhance its effectiveness.

The FFVP, first implemented in 2006-2007, is an innovative nutrition program that enhances nutrition integrity by increasing fruit and vegetable availability to schools. The United States Farm Bill, Food, Conservation, and Energy Act of 2008 (Pub L No. 110-234, §19) expanded the FFVP to 4,600 schools in all 50 states, as well as the District of Columbia, Guam, Puerto Rico, and the Virgin Islands, and the program has successfully introduced students to a variety of nutrient-dense, fresh produce that they may not otherwise experience. The Academy strongly supports the FFVP and the funding and nutrition education elements that help the program meet goals of increasing consumption of healthy fresh fruits and vegetables by elementary school-aged children and helping them develop lifelong healthy behaviors.

FFVP Is Successful
America’s children and adolescents consume inadequate amounts of nutrient-rich foods such as fruits and vegetables. A study based on 1999-2000 data found only 0.7% of boys aged 14 to 18 years met USDA fruit and vegetable recommendations. Moreover, half of all children aged 2 through 18 years consumed less than a serving of fruit per day, with french fries accounting for about half of the vegetables. Children from socioeconomically disadvantaged families—the same children reached by the National School Lunch Program and the FFVP—are shown to consume the lowest number of servings of fruits and vegetables per day, thereby increasing their risk for diet related chronic disease.

The FFVP is a success story; it transforms the eating habits of elementary school students and their families. The results of an independent evaluation demonstrate FFVP effectiveness; children who participate in the FFVP increase their fruit and vegetable consumption by 15%, on average, on days the FFVP is provided. Significantly, the FFVP increases children’s fruit and vegetable consumption without increasing their total caloric intake, thus suggesting that the fresh fruit or vegetable snack is replacing other foods in the diet, rather than adding excess calories.

School nutrition professionals, including many registered dietitian nutritionists, struggle with a “trilemma” of problems: meeting the nutritional requirements of the student; minimizing program costs (including maintaining outdated facilities); and maximizing student acceptability and participation.

Evaluation of the Pilot Project
The Academy believes that rigorous evaluation of the Fresh Fruit and Vegetable Program (FFVP), completed in March of 2013, should serve as a benchmark for the proposed Canned, Frozen, or Dried (CFD) Fruits and Vegetables pilot project in the FFVP. The 2013 evaluation of the program noted that both primary objectives, such as consumption behavior inside and outside of the classroom, in addition to secondary objectives, such as improved nutrition knowledge, improved attitudes towards fruits and vegetables, interactions with the new school meals standards, and impacts on the overall school nutrition environment are equally important when assessing the CFD pilot program.2

The successes documented in the 2013 FFVP evaluation show marked improvement on consumption behavior of fruits and vegetables inside and outside the classroom as well as students’ attitudes towards fruits and vegetables. Specifically, students participating in FFVP were more likely to agree that they “like most fruits” and that they “like to try new fruits and new vegetables.”3 The evaluation showed that, on average, FFVP schools offered three times the amount of nutrition education per week as compared to schools not participating in the program.4 Additionally, consistent with the primary objectives of FFVP, nutrition education and promotion messages about fruits and vegetables and encouraging students to try new kinds of foods were conveyed more frequently in FFVP schools.5 These changes in consumption behavior, improved attitudes towards fruits and vegetables, and increased nutrition knowledge have significant benefits, notably because these low-income children have the lowest fruit and vegetable intake and are at the highest risk of poor health outcomes.

The Academy respectfully suggests that the CFD pilot evaluation should ensure the preservation of these important public health gains and provide insights as to the best avenue to reach the goal of the FFVP, which is to introduce children to a wide variety of fresh fruits and vegetables.6 As a result, the Academy has confidence the program will continue to provide nutrition education and introduce healthful products that will help students develop lifetime eating habits that improve health and reduce obesity and overweight.

The Academy appreciates the opportunity to comment on this important initiative and hopes to discuss these recommendations in greater detail in the near future. Please contact either Jeanne Blankenship at 202-775-8277 ext. 6004 or by email at jblankenship@eatright.org or Pepin Tuma at 202-775-8277 ext. 6001 or by email at ptuma@eatright.org with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS RDN
Vice President, Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Director, Regulatory Affairs
Academy of Nutrition and Dietetics


1 The Academy recently approved the optional use of the credential “registered dietitian nutritionist (RDN)” by “registered dietitians (RDs)” to more accurately convey who they are and what they do as the nation’s food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.

2 Bartlett, S., Olsho, L., Klerman, J., et al. (2013). Evaluation of the Fresh Fruit and Vegetable Program (FFVP): Final Evaluation Report. Prepared by Abt Associates under Contract No. AG-3198-D-09-0053. Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service. Project Officers: Karen Castellanos-Brown and Allison Magness.

3 Ibid.

4 Ibid.

5 Ibid.

6 U.S. Department of Agriculture Food and Nutrition Service. Fresh Fruit and Vegetable Program Fact Sheet. Accessed September 3, 2014. Available at www.fns.usda.gov/sites/default/files/FFVPFactSheet.pdf.