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No 
REPORT OF THE 

COMPTROLLER GENERAL

OF THE UNITED STATES

How Good Are School Lunches?

The Department o Agriculture has specific food requirements for lunches served under

the national school lunch rogram. Through zhese requirements, the Department seeks to

provide students with luncnes that, over time, contain one-third of the recommended daily dietary allowances of specified nutrients.

However, results o laboratory tests sponsored by GAO from C'eveland, Los Angeles. and

New York showed that the Department's goal is not being met. Lunches in these cities were

significantly short in as many as 8 of the 13

nutrients tested.

Separate tests in N,:w York showed that at

least 40 percent of the unches did not meet

the Department's requiremrents as to qcuanti- ties servec'. Department officials acknowl

edged this is nationwide problemn.

Microbiological tests sponsored by GAO showed that the lunches were sdfe to eat but that

local testing varied considerably. Also. a lot of

food was being thrown away because the stu

dents did not like t.

Improved meal standards and better monitor

ing of meal services are needed.

Co.7&22 FEBRUARY 3. 1978
COMPTROLLER GENERAL OF THE UNITED STATES

*AS- W IIftnTO. D C lou

B-178564

The Honorable Frederick W. Richmond

House of Representatives

Dear Mr. Richm.nd:

As you requested we reviewed various nutritional and

food quality and qaualtity aspects of the national school

lunch program. We issued a report to the Secretary of

Agriculture on June 15, 1977, on one aspect of our review.

(See app. II.) Also, we summarized the results of our review in testimony before the Senate Select Committee on

Nutrition and Human Needs on September !0, 1977. (See

app. I.) This report summarizes our findings and contains

recommendations to the Secretary of Agriculture to iprove

the program. Oral comments were obtained rom the Departmert

of Agriculture and are recognized in the report as appropriate.

The National School Lunch Act (42 U.S.C. 1758) rovides

that lunches served by participating schools must meet

standards prescribed by the ecretary of Agriculture. These

standards require that, as a minimum, the lunches contain

specific quantities of various food types. The type of lunch

thus required is commonly called a Type A lunch. The

Secretary's oal in requiring Type A unches, although not

promulgated as a formal reauirement, is to provide students,

over time, one-third of the recommended dietary allowances

published by the National ,:ademy of Sciences.

Independent laboratory tests we sponsored showed that

compliance with Type A requirement- did not insure the

achievement of one-third of the recommended dietary allowances. The tests showed that sample lunches from three

cities--New York, Cleveland, and Los Angeles--were significantly short in as many as 8 of the 13 nutrients tested.

The Department recently proposed changes to the Type A

lunch requirements, but the only relevant change for 10- to

12-year olds is that three additional slices of bread would

be required each week, and alternatives to bread, such as

rice or macaroni, would be ermitted, We do not believe

these changes, if adopted, will overcome the nutritional

shortages we found.
B-178564

We also sponsored tests of the microbiological safety and quality of lunches served in the three cities. Al'nough the tests showed that the lunches were safe to eat, we noted that the testing and standards used by the local authorities varied considerably and that there were no Federal procedures or standards for microbiological testing in the pogram other than for milk. Various experts told us that mane'atory minimum Federal procedures and standards are not warranted because food contamination is not a serious problem. We fied it difgoing 

ficult to argue with this logic; however, if localities are to continue voluntary testing, it might be more effective for them to use consistent procedures and compare the results

against uniform standards.

In another phase of or revi ., we selected a random sample of lunches seived in New Yor.. City during a 6-week test eriod and >ad them ested for compliance with Type A requirements. At least 40 percent did t contain the types or quantities of foods required. In a arch 1977 briefing of Department officials ard again in our June 15, 1977, eport to the Secretary (see app. II), we recommended that the Department determine the extent to which such noncompliaie is a nationwide problem. The Department has acknot,ledged that compliance with Type A requirements is a nationwide problem and plans to make changes in its regulations to deal with this problem. The changes would, among other things, require States to develop standard vendor contracts; require contract specificatioris, including grade, style, weight, and ingredients, of meal conoonents; and require that no Federal payment be made for meals not meeting contract re- quirements. The Department also plans to require States to develop, implement, and monitor plans to insure compliance with Type A requirements under certain conditions. These plans need to be translated into concrete and effective requirements with related oversight procedures to insure compliance. Also, additional measures need to be taken, as recommended below.

Food waste has long been a recognized problem in the school 

earlier lunch program and has been discussed in several reports by our Office. Our recent observations

of meals served in New York City confirm our earlier findings. A number of different factors contribute to food waste--as discussed in chapter 4 of our report to the Congress, The Impact of Fedral Commodity Donations on t:e Scnool Lunch Program' (CED-77-32, Jan. 31, 1977). Although the factors in New York City were in line with those discussed in that report, the most important one seemed to

2
B-178564

be that the studc.ts did not like the food that was served.

The Department is currently studying waste in the school lunch

program ad expects the results to be available in several

months.

RECOMMiENDATIONS TO THE

SECRETARY OF AGRICULTURE

If the goal of providing one-ttird of the recommended

dietary allowances is to be achieved, we recommend that

the Department modify the requirements for school lunches

beyonl the changes recently proposed. Increasing the

quantities of food required may not be a satisfactory sol];-

tion because children frequently do not eat all ot the food

served to them in school lunches now. New approaches may

be needed, and we recommend that consideration be given to

other alternatives as discussed in appendix I. (See p. 10

of this report.)

We also recommend that the Department consider the

possibility and feasibility of publishing uniform procedures nd standards for those localities conducting

microbiological testing in the school lunch pogram. Other

Federal agencies, such as the Food and Drug Aiministration,

would need to be consulted in the development nf such p-ocedures and standards.

To achieve compliance with Federal school lunch meal

requirements, we recommend that the epartment

-- develov exolicit instructions on how and wntn

Federal, State, and local monitoring cf this compliance is to be performed (Department officials

said they plan to dvelop such instructions);

--check to see tat the instructions are being

followed anu determine if the Federal recuirements are being met both by vendors anu schools

which prepare their own meals; and

-- stop Federal reimbur.ement in cases where noncompliance with Federai requirements is not

promptly corrected.

In our January 31, 19/7, repor. (CED-77-321, we

recommended that the Department

3
3-178564

--undertake greater promotion of nutrition education as a part of school health programs in an effort to reduce plate waste,

--make greater efforts to encourage State and local 

facilities 

school authorities to improve school lunch and atmosphere, and

--include a nutLient standard as an option to the

with 

Type A lunch pattern to provide menu planners greater flexibility in using Federal commodities.

Some 

All 

initial 

of these measures should help reduce food waste.

as described 

steps have been taken oin these recommendations, below, but implementation has not been completed

--Recent legislation provides for more nutrition education.

--The 

to 

Department has proposed that schools be required involve, students in efforts to enhance the school 

steps 

lunch eating environment and has taken other

facilities.

to encourace Lhe improvement of school lunch

--An alternate nutrient standard has not been proposed but, 

changes 

in conjunction with the Department's proposed

public 

to school lunch requirements, it has requested

plans to 

commtnts 

consider 

on this approach to menu planning. It these comments in determining if such an approach is feasible.

Our most recent review of the school lunch program

'help 

has reinforced 

reduce 

our view that these measures are needed to

be implemented. 

food waste and we again recommend that they

Department 

In addition, we recommend that the

decentralJzed 

encourage local school authorities to use

from various 

menu planning to meet the tastes of children

wide selection 

cultural 

of 

and ethnic backgrounds and ffer a

palatable.

foods that are highly preferred and

4
B-178564

As arranged with your office, we are sending copies of

this report to the Secretary of Agriculture and to various

interested arties. Copies will be furnished to others

upon request.

Sincerely yours,

Comptroller General

of the United States
Contents

PaAPPENDIX

I STATEMENT FOR T RECORD DURING HEARINGS

BEFORE THE SENATE SELECT COMMITTEE ON

NUTRITION AND HUMAN NEEDS CON NUTRITIONAL

AND FOOD QUALITY APECTS 01' THE NATIONAL

SCHOOL LUNCh PROGRAM 6 Nutrition provided by uncnos 7

Microbiological quality and safety of

lunches 10 Meeting Type A l:nch requirements 12

Food waste 14

II REPORT TO THE SECRETARY OF AGCRICULTURE DATED

JUNE 15, 1977 (CED-77-89) ON NEW YORK

CITY'S FAILURE TO FOLLOW FEDERAL REQUIREMENTS

FOR SCHOOL LUNCHES 18 Program administration 19

Testing Inethodology and results 19

Recommmendations 21
APPENDIX I APPENDIX I

WNI'ED STATES CENERAL AOJTI:rG FFI(E EFOR REL.ASF CJ oELIVEY YASHIN(TOJN, D.C. 20548 EXPELTED T 11:00 A.:4. ;

FP.I:Y, SEPTLSG, 30, 1977

STATEIeN' r FOq rHE RECORD rLJRINS qi.{

3EF') E THE

SENATE SELECT CO4MITrEE ON

NUTRIrION AND HUMAI NEEDS 014 NUTRITIONAL AD FOOD QUkLIrY ASPjCTS Of

THE NATIONAL SCH33L LU3C PaOGqA'

MR. CAIRA.r.4 A:ID E!3ERS O THE CMMITTEE:

4E AR HEE TODAY Ar THE EuEsr OF rHE col¶Irr';:E r)

OISCUSS ltE SC:30)L L4Ci PROGRAM--HE LAREST -OF THE SEVEtL

FEDEaALLY FU;iLED CHIL-FECDIA G PROGRAMS. rilE rOO3 ND

NUrRITION EAJICE, OEPART'iENr 3F AGrLCULruRE, AD4rILsrei; T4FF

PKOGRA TiROUid STArE EUCATI3g CENCIeg. OUt JFE'1CE IS ),-

PLETIN A EVIE; OF CERTII NIUTRITIONAL AND FOOD ')ULI'Y

ASPECT3 OF HE PO;GA' PURSUJAJT TO A RE:UEsr Y

COWGRESSMA.4 F'tEOERrCIK . RICHmUoD. GAO'- TTE4EeN TODOAY WILL

W.YAIZE 'OU r'FI.i4 4Gi A3 OUR S'JuGEsrIONo F -I1PT-OVI13 h riE

SCHOOL LUC'-'C PRORA.

THE SH33L LU4C. P.-a. OPEAAreS IN rl E 50 srmTC3, Tq

DISTRAlr 'J COLJ4T, Pro ICO, UAM, THE: VIII4 ISLAOS,

A4ERICAu4 AO1A, 4SO r.i rsr rtir>Yi O T P4CIFIC ILAJCS..

IN FISCAL YEAA 1976, 3Vre. 4.1 3ILLIJ. LUNCHES ERE ERVEU I4

IEARLY 90,000 S:f33L PAXrICIPArI.; T rIHE P,%VY. OUI'j- I{-.

-EAt 40.'l"I (O/Ei3ER) I.i SCqO'JL YA.I 1976-77. A3OU 25.3 'IlLLI.O CHIL.iEN AAf.tE EV'D L'JU4ZrIE3 )ILi. r'l: VALU' OF ,'.3-L

CASH AmIO CO'4mOTIrES P.3IIED3 o3 rPqd CL LUN:H PRORA4 4;;

A3OUT $1.9 3ILLI. I4 FI3_^L YEAl 1976.

6
APPENDIX I APP.NDIX I

NUTRITION PROVIDED BY LUNCHES

THEi NATIONAL SCHOOL LUNCH ACT (42 U.S.C. 1758) REOUIRES

THAT LUNCHES SERVED av PARrICIPATING SHOOLS EET !'"JTRITIONrAL

SrANDARrS PRESCRIBED BY HE ECRETARY OF ACRICULTUkE. ThE

SECRETARY HAS DETERMINEO THAT, AS A GOAL, SCHOOL LUNCHES

SHOULD, OVER rImE, PROVIDE ONE-THIRD OF THE NUTRirION CALLED

FOR dY HE ECODMENDED DIETARY A.L -4cr- (DA) DEVELOPCD 9Y

THE NATIONAL ACADEM'i Of SCIENCES. TO CHIEVE T1H13 GOAL, THE

SECRETARY REQUIRES THAt SCHOOL LUNCHES CONTAIN 24CSCI3E

OUANTlIrES OF VARIOUS rYPES OF "00DS. TH-" EQUIirC EAL PArTERt I ASED ON THE NUTRITIONAL NEEJS OF 10-'rC-12 YA OLD

C:ILuSN A:D IS COl.O'-JLf CALLED THE TYPE A LUNCH.

rYPE A LUNCHES ARE REOUIED ro CO4 T.AI TWO OUNCES OF .MEAT

o or-i Hs PrgI FOOD, rH;E£-Q.UARrr..; CUP OF T*O OR ORE

FPRIr A/OR vEGFrAlLES, OE SLICE OF ENRICHED 3READ, AD ONE

HALF PI.Ar OF FLUID MILK. 4DJUST.sErs IN THE UAN.TirIeS RQUIRED Y TE tfPE A tTTERv4 ARE PERMITTED FO YOUNGER A0

OLOER HILDREN.

ALr.IOJU;i SCHOOL LU{C!'3 ARE NOr PECIFICALLY REQUIRED TO

PROVIDE ONE-THIROD DA, f1it TYPE A PA'rTER'J AS DS;IGJED TO

ACHIEVE THE GOAL Of O,{E-rHI4t) RDA OVE rl.I4E, EXCEPr r'OR CALORIES. HOIEVER, INDEPENDE-r LA3ORA'OtY rr.sir; E SP)nOoE.

SHOWED rHAr ADdERIiG TO rtE YP' A P4rrE.J D)t:g Nr -:Nsu-t

THA T S GOAL WdILL E AC-IEED'.

WE CON'RACTED 41rH TE W.tRP INSIrUrF r 4I)-,

iISCOaS-IN--NArIOiALLf RECOGNIZED XPER3Z' 1. NUI'R.iri')4AL

7
APPENDIX I APPENDIX 

TEsrIN;--TO EST 60 SCHOOL LUNCHES WE CTAIED FO0l 12 LFMEVrARY SCHOOLS iN TREE CIES--NE4 YORK, CLEVELAV, AND

LOS ANGELES. ALTdOUIIG IT WAS NOT FASIlbL. FOR US TO SELECr A

SCIENTIFIC ANDCM SAMPLE OF LUNCHES FOR HIS PHASE OF OLR AOR",

dE SELECTED SCdHOLS S;ESVIq rPES OF EALS COV4M.)LY iFVED ro

10-rO-12 YEA2 OLD CHILDRE I THE RESPECrIVE CITIES.

FOR FPI E CONSECUTIVE DAYS IN EACH OF r4HE 12 SC$'3L) , vE:

PURCHASED SCOOL LUNCHES J3sr LKE THe OES EIIG SmeVeD r

dHE CHILDREN. viE EASURED THE LUNC'IEi ANO SUPPLE4EANTEO THEM

IF NECESSARY ro AKE SUaE THEY 4r r:E EQUIE.;mqs OF rHE

TYPE A LUNCH PArrE.. IN ACORDANCE ITH DETALEZ ;SS-rRUCIrl3NS

PROVIDED 3Y WARF, E PACKED AND FROZE 'rTE LUNCHE3 A.A SIPPED

THE, TO WARF IN Y CE; THEY ARRtIVD T 4JARF SILL FROZEN A.ND

'N EXCELLE CO;DITIOON. WARF RAN TESTS 0 DTE'4I;,N HE

QUANTITIES 13 DIFPERET NUTRIENTS CONTAINED I THE LUNCHES.

THE RESULrS dERE ANALYZED TO SEE HETHE4 EACH SCHOOL'S LUNCHES

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

OVER THE 5 DAY PERIOD.

TH2 CURRENT TYPE A PATTERN IS BASED ON HE 196d VER3ION

OF DA d.IC4 INCLUDED 17 NUTRIENTS. v:. "ESTED FOR 12 Of THESE

NUTSIENrS PLUS ZINC, WHICH AS ADDED TO THE DA IN 1974. ON

THE RECOME.ODATION O PROFESSIONAL NUTRITIONISTS, WJE DIU NOT

RUOU TEST3 ON THE OTrCR FIVE NUTRIENTS I THE RDA ECJAU3E SLIA3LE TESTING TECHNIQUIES JERE Nor VAILABLE O 3ECAUg6 ir A,

VERY ULIKELY THAT THERE OULJO E 53ORTAGES.

8
APPENDIX I APPENDIX I

THE TESTS SHOWED THAr, OVER THE 5 DAYS, T'E LUNCHES PROM

EA ' SCHOCL PROVIDED THE RECOMMENO.D AMOUNrs OF 5 OF THE 13

NUTRRIEcrS--PROT EI, P!HOSPHORUS, NIACIN, ICDINE, AND VITAMIN C.

HOdEVER, THERE ERE SIGNIFICANT SHORTAGES (MORt THAN 5 PERCENT

OF RDA) AT EACH OF THE 12 SCHOOLS IN ONE OR 1MO! OF HE OrHER

d NUTRIENTS. FOR EXAMPLE, LUNCHES FROM 7 OF THE 12 CTHOOLS

HAD DEFICIENCIES OF 19 TO 50 PERCENT IN VITAM:q A; 9 SCHOOLS

HAD DEFICIECIES OF 13 TO 42 PERCENT IN IRON: AND ALL 12

CHOOL dAiC EFICIENCIES OF 5 93 35 PERCENT ;4 '.?':;iU'4.

LUNCHES .'aO ALL 12 SCHOOLS ALSO HAD DEFiCIeNCIES OF 7 T 42

PERCENr ;e ZINC. THERE ALSO ERE ES3ER DEFICIENCIE3 1~ CALORIES, rHIA-4:NE, CALCIUM, AND ITAMIN 36.

' E ELI':vz THESE TESTS INDICArE THAT THE YPE A PArTErN

IS NCT ADEQUArE ro ENSURE ACHIEVEMENT Or' THE PROGA'S sNUrRITIONAL OAL. THE OEPARrMENT CENrFL PROPOSED A EW LUNCH

PArTERN GIVING SCHOOLS MORE PLEXI3L!.IrY IJ AC4SIEgING INE-TIRO

RDA FOR DIF'ERENT AGE GROUPS, 3UT THE ONLY ELEVANT CHANG7e FOR

10-r3 12-YEAR OLO I THAT EIG r SLICES OF SREAD ILL E REQUIAED EACH WEEK IISlEAD OF '"lVE. ALiO, ALPER!NAIVES 8REAO,

SUCH AS aICE OR ACARONI, 4OUL3 3E PER4ilrTED. EXCEPT FOR CALORIES, THESE CHANGES D NOr PPEAR SUFFICIENT TO OERCO.ME TH$E

NUTRITIONAL SHORTAGES INDICATED Y OUR CONTRACTOR'S TrS.

THE DEPARTMENr EEOS TO FURT,{E.A MODIFY rHE CHOOL LUNCH

REQUIREYEVTT3 IF THE GL OF PROVI1 DING ONE-'HIRI RD.A I ro E

ACHISVEO. INCREASING THE J.ATxrIE3 OF FOOD EUIARLE 3Y THE

TYPE A PATTERN AY NOT 8E A SATISFACTORY SOLUPIaN 3ECAUSE SC&.

9
APPENDIX I APPENT! I

FOODS IGHT C ICREAiED 'O EXCESSIVE QUATI'IES AND 3ECAUSE,

AS DISCUSSED LATER I THIS STATE'rENT, CHILDREN FREQEN,Y DO

NOT AT ALL OF THE FOOO SE:VED TO THEM IN SCHOOL LUNCHES. NEW

APPROACHES MAY 8d NEEDED; CONSIDERATION SHOULD aE IJEN TO OPTIONAL USE OF A STANDARD REQUIRI.G SPECIFIC NUTRIENT CONTE4T

(AS DISCUSSED LATER IN THIS STA'TEMENT), CAREFUL EXPANSION OF

THE USE OF ENRICHED FOODS, MO4RE DECENTRALIZED AND ,4ORE FLEXISLE ENU PLANNING, OR OTHER INOVArIVE ECH;4IQUES.

IICROSIOLOGICAL QUALITY AND SAFErY OF LUNC:HES

*rO 33TAIN A INDICATION OF HETHER SCHOOL LUNCHES ARE OF

GOOD QALITY .%ND SfE TO EAT ACCORDING TO IRJ3IOLOSI-CL

TErSt, .E CONTRACTED 1TH PRIVA7E LA30RATORIE I TE THREE

CITIES TO OTAIN SAMPLE LUNCHES AND CONDUCT iACTERIA TST'ri.

'HE LA3RA'..R)P.CS PICKED UP 60 ADDITIONAL LUNCHES FRO4 THE

SCHdOOLS ANo rESTEl THEM FOR RECOGNIZED INDICATO OF tQUALITY

AND AFErY--'CTAL ACTERIA PLATE COUNT, FECAL COLIFORY,

E.COLI, STAPHYLOCOCCUS, SALMONSLLA, SHIGELLA, AD CLOSrRIDIUM4

PERFINGESIS.

rP;~E ARE NO NArT:)NAL sr.NnARDS FOR 3ACTERIAL CONTENT IN

SCHOOL LUNCHES O FOR TESTING PRACTICES OTHER THAN FOR, 4ILK.

ACCORDINGLY, THE LA30RArOmIrES TESTED LUNCHES IN ALL THREE

CITIES AGAINST TE NEA YORK CITY HEALTH CODE STANDkD FOR

BACTERIAL CONTENT SO rr ALL OF OUR rEST ESUL'r3 WULO E

SASED ON E SAME STANDARD.

A FOOD AND ORUG ADm.INI.iTrArION FDA) OFFICIAL AND AN IDEPENDENr ICRO4IOLOGISi EXPLAINtFD TAr THE NEW YORK CITY

10
APPENDIX I APPENDIX I

STANDARDS CONTAII SAFErY MARGINS. THEY REVIEWED HE ESULrS

OF THE TESTS WE HAD CONDUCTED ANO, ALThOUGH 20 OF THE 420 ACrERIAL EADINGS EXCEEDED NEA YORK CItY STANDARDS Y SMALL

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

BECAUSE EACH OF THE READINGS EXCEEDI.4- THE STrANDARDS WAS I'HIN HE SAFETY ARG!NS.

STATE AND LOCAL .SrANDARDS FOR '~ACTERIA IN SCHOOL LUNCHES

VARY CONSIDERABLY. IN 975, FDA ETI:ATED THAT ONLY HALF OF

THE STATES HAD OR ERE I rdi PROCESS OF ESTABLISHING ACTERIAL STA4DAaS 3R GUIDELINES FOR 1FOODS. ACCORDING TO AN FOA

ANALYSIS, STATE STANDARDS AND GUIDELINES VARY 3Y FOODS COVERED,

TYPES OF 3ACTERIA. AND PERMISI3LE LEVELS OF rHE ACTEIA.

SOME SA'rES P?LY STANDARDS FOR ACTERIAL LEVELS EUrJALLY O

ALL FOOOS. OTHEA STATES HAVE LEVELS FOR ONLY ONE O T SPECIFIC FOOD IrEMS.

kLrHOUGH SOME LOCAL 3ACrPIIAL rESTI'-, WJAS EI4G PERFORMED

IN EACH OF TdE THREE CrrIES 4E VISITE., T TESTING ACrrccs

VARIED LREArLY. FOR INSrANCE, ONE. CIPY EGULARLY rESTED FROZEN ITEAS FOR EACH OF THE 3ACTERIA FOR adIICi :JE AD rEsrs CONOJCTED. GCENEtALLY, IrTiS PURCHASED EIrHEl FRESH r CANNEO ERZ

TESTED FOA. ACTEqIA ONLf WHNEt SOMETHING APPEARED .RON~ ITH

rHEI OR 4HEN SOMEONE COPLAI1ED 30OUT THE4.

IN AOTYER CITrY rwo ACTERrAL REAlINGS wEA . rAxEN OURI.IG

THE I[:IrIAL COOKIG; OF A4 FOODS--TOTAL 9ACrERIA PLAr CO'JNT

AND COLIFrOR4. IF r:TH_.A COUNT A EXCESSIVE, TE LA3ORATORY

ConD(ucrEO TE 'rE;r; AS E,3 D). r'HI3 PROCEDURE AS ALSO

11
APPENDIX I APPENDIX I

APPLIED ro FROZEN FOODS AND CANEO GOODS IF SOMETHISG SEEtED

WRONG ITH THEM.

Iq rHTE THIRD CITY FROZEN FOODS 'E1E TEST'ED FOR YEASr,

MOLD, COLIFORM, .ANO TOTAL PLATE COUNT. ALL FOODS ERE rE3TED

BY KITCHEN STAFFS FOR FRESHNESS, EMPEATURE, AND rATE, AND

THE EQUIPMENT USED IN PREPARING THE FOOD WAS rE3rE F 3ACTERIA. -

DESPITE TE INCONSISrENCIES IN LOCAL ESTI AG P-ACrIC's.

ANO STANDARDS, VARIOUS EXPERTS I 3ACTERIA TE-3['IL, TOLO U';

THAt .INipIUM ArIONAL STANDARDS FOR SCHOOL LUNCYFE, ALr:0'{JGH

THEORETICALLY OESIRABLE, AE NOT PRACTICAL OR AE NOT JUSTIFIED Y tHE 3MALL NUSERI OF CASES OF ILLNtES CAUSED 3Y CO4-

rAMINArED FOODS. WE FIND IT DIFFICULT TO ARGUE WITH TIS LOGIC. IF LOCALITIES ARE GOING TO CONrTINUE CONDUCTI.G 3ATER.1AL

TESrS, HOWEVER, IT IGHTr E 4ORT/HILE FOR rHE DEPARTYENT OF

AGRICULT;JRE TO GIVE £-I IDEA OF UIFOR4 TESTING PRAACrlES AND

STANDARD:0 SO30E FUA'TOE A THOUGHr.

erEETING TYPE A LUNCH REQUIREMENTS

IN A SEPARATE SERIES OF TESTS, iWE USED s'rATIS:CAL SAmPLInG TECdNIJ-JE T ESrIATE TZ NUM3ER OF SCHOOL LUNCHiES

SERVED IN NEW YRK CITY SCHOOLS THAT FAILED ro EET TYPE A EQUIREMENTS FOR QUANTITY NO TYPE OF FOOD SERVE) OURING A 6-WEEK

PERIOD IA. JANUARY AND FE3aUARY 1977.

WE HAD ESTS 4ADE OF EACH YPE OF LUS4CH SERVIC'_- I

NEW YORK CITY SCHOOLS--CAFETERIA SrYLE, MEAL PAC(, BASIC (SO3UP

AND SANOsICt), ANO ULK (PREPARED-FROZEN CO'PONENTS). WE

12
APPENDIX I APPENDIX I

PICKED UP THE LUNCHES ANO DELIVERED THEM TO DIETITIANS Ar A

VETERANS ADMINISTRATION HOSPITAL IN NEW YORK CTY WHO TESTED

THF LUNCHES FOR COMPLIANCE WITH TYPE A REQUIREMENTS.

FROM OUR SAMPLE WE ESTIMATE, WITH 90 PERCENT CERTAINTY,

THAT AT LEAST 40 PERCENT OF THE SCHOOL LUNCHES SERVED 1

NEd YORK CITY DURING OUR TEST PERIOD DID NOT MEEr TYPE A REQUIAEMENT$; FEDERAL REIM3URSEMENT FOR THESE NONCOMPLYING

LUNCHES WOULD aE AT LEAST $3.7 MILLION. FACTORS CONTRISUTING

TO rHiS STTUATION WERE THATr ABOUT 20 PERCENT OF NEW YORK CITY

SCdOOLS DID NOT HAVE SCALES TO WEIGH MEAL COMPONENTS AND 16

PERCENT DID Nor HAVE PRE-PORTIONED SERVING UTENSIL3 TO ENSURE

THAI QUANTITIES REQUIRED BY THE TYPE A PATTERN WERE BEING

SEAVED. THE RESULTS OF THESE TESTS ARE ESCRI&ED IN YORE ETAIL IN OUR JUNE 1, 1977, REPORT ro THE SEChSTA.Y OF AGRICUJLTURE (CED-77-89), A COPY OF WHICH IS ATTACHED TO HIS STATrEMEN r.

THE DEPARTMENT OF GRICULTURE HAS DELEGATCr) RESPONSISILIrY FOR MONITORING THE SCHOOL LUNCH PROGRAM T TE NEW YORK

STrE DEPARTMENr OF EDUCArION. ALTHOUGd AGRICULrURE REQUIRES

CO'4PLIANCE WITH THE TYPE A PATTERN, IT DOES NOT SPECIFY OW

COMPLIANCE IS TO E rESTED. THE STArE' REVIEWS HAVE 3EN

CONCERNED PRIMARI!LY WITH .q4LOREi' ELIGIBILITY ro RECEIVE

FREE OR EDUCED PRICE LUNCdE3 A.L qIrH PROGRAM AcOuJ'rA3ILITY,

AND ONLY LI,1ITED ATTENTr13N HA3 EEN GIVEN rO CO[PLIA.CE WITH

TYPE A REQUIREEMENTr. HE STArt A) 'A EVIa. ItidELD PROG;RAM

FUNDS FROM NEW YORK CITY ECAUSE OF YPE A NONCZ)'PLA'CE.

13
APPENDIX I APPENDIX I

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

SCHOOL OFFICIALS, AND CONGRESSMAN RICHMOND ON THE RESULTS OF

OUR TESTS. AT THE CONGRESSMAN'S SEQUEST, A JOINT FEDERAL,

STATE, AND CITY TASK FORCE EVALUATED NiEW YORK CTY'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 Y THE DEPARTMENT AND TE

STATE IN THE 1977-78 SCHOOL YEAR.

FAILURE TO MEET THE TYPE A REQUIREMENTS RESULTS I SCHOOL

CHILDREN BEING FURTHER SHORT-CHANGED IN RECEIVING THE NUTRIENTS WHICI HE FEDERALLY SUBSIDIZED LUNCH IS DESIGNED TO POVIDE. WE FIRST RECOMMENDED BACK IN MARCH THAT THE DEPARTmENT

DETERMINE THE EXTENT TO WHICH THE PRCSLEM OF NONCOMPLIANCE

WIT!; THE TYPE A LUNCH REQUIREMENT'rS FOUND IN NEW YORK CITY IS A

NATIONWIDE PROBLEM. THE DEPARTMENT HAS ACKNOWLEDGED THIS TO

BE A NATIONaIDE PROBLEM AND HAS TAKE INITIAL STEPS TOWARD REQUTRING BETTER MONITORIN3 OF COMPLIANCE WITH TE TYPE A REQUIREMENTS. HOWEVER, MUCH MORE NEEDS TO BE DONE; THE DEPkRTMENT SHOULD DEVELOP SPECIFIC INSTRUCTIONS ON HOW FEDERAL,

STATE, .iND LOCAL MONITORING IS TO BE PERFORMED. DEPARTMENT

OFFICIALS TOLD US TdEY PLAN TO DEVELOP SUCH INSTRUCTIONS.

FOOD WASTE

FOOD iSATE HAS LONG BEEN A RECOGNIZED PROSLEM IN THE

SCHOOL LUNCH POGRA.S AD HlAS BEEN DISCUSSED IN SEVERAL EARLIER

REPORTS Y OUR OFFICE. OUR RECENT OBSERVATIONS OF t4EALS

SERVED IN NEW YORK CITY CH.OLS CONFIRMED Oa EARLIER FINDINGS.

14
APPENDIX APPENDIX I

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 :]UTRIrloA EDUCATION AONG THE CHiLDREN AT HOME

AND UNFAMILIARITY WITH MANY VEGETABLE ITEMS DUE TO CULTURAL AND ETHNIC DIFFERENCES IN NEW YORK CITY.

--POOR LUNCHROOM ATMOSPHERE AND CONDITIONS, SUCH AS SHORT

AND HURRIED LUNCH PERIODS AND LACK 'F ADEQUATE SUPERVISION OF STUDENTS.

--PEER GROUP PRESSURES NOT TO EAT CERTAIN FOODS.

--THE CHILDREN TIi. OF EATING THE SAME FOOD ITEMS OVER

AND OVER AGAIN.

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

1977, REPORr ENTITLED "THE IMPACT F EDERAL COMMODITY DONATIONS ON TE SCHCOL LUNCH PROGRAM' (CED-77-32).

ALTHOUGH THESE FACTORS MAY I.MPACT UN FOOD CONSUMPTION,

IT APPEARED TO US THAT FOOD WASTE wAG MOST OFTEN CAUSED 

STUDENTS SIMPLY NOT LIKING THE ITEMS EING SERVED. IN ONE

SCHOOL, FOR EXANM-LE, SEVERAL CHILDREN SPECIFICALLY REQUESTED

THAT GREEN e.EANS NOT BE ADDED TO THEIR LUNCHES. WHEN THEIR

REQUESTS WERE ENIED THEY THREW THE ITEM AWAY UNTOUCHED. WE

I.LSO FOUND THAr THE SAME ITEMS WERE NOT CONSISTENTLY ACCEPTED

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

SCHOOL, 3UT 30 PERCENT WF IT WAS WASTED IN ANOTHER SCHOOL.

15
APPENDIX I APPENDIX I

ALTHOUGH COMPRF.HENIVE STUDIES ARE NOT AVAILABLE ON THE

EFFECTIVENESS OF NUTRITION EDUCATION IN IMPROVING CHILDREN'S

DIETS, THERE ARE SOME INDICATIONS THAT WELL-DESIGNED AND IMPLEMENTED NUTRITION EDUCATION PROGRAMS HAVE A FAVORABLE IMPACT,

INCLUDING SGNIFICANT REDUCTIONS IN PLATE WASTE. HOWEVER,

NUTRITION EDUCATION HAS A LW PRIORITY WITH SCHOOL ADMINISTRATORS RESPONSILE FOR CURRICULUM PLANNING.

THE DEPART4ENT IS CURRENTLY STUDYING PLATE WASTE IN THE

SCHOOL LUNCH i.OGRAM ON A NATIONAL SCALE AND EXPECTS TE

RESULTS TO BE AVAILABLE IN LATE 1977.

WE BELIEVE THAT TO REDUCE FOOD WASTE THE OEPARTMENT

SHOULD:

--ENCOURAGE 4ORE NUTRITION EDUCATION IN SCHOOL HEALTH PROGRAMS TO DEVELOP PROPER EATING HABITS AT AN EARLY AGE.

WE OTE THAT THE DEPARTMENT'S PROPOSED CHANGES TO THE

SCHOOL LUNCH REGULATIONS ENCOURAGE NUTRITION EDJCATION

AND THAT LEGISIATION PRESENTLY BEFORE A HOUSE-SENATE

CO£NFERENCE COMMITTEE CALLS F EXPANDED NUTRITION EDUCATIO. WE SUPPORT THESE CHA IGES.

--ENCOURAGE LOCAL SCHOOL AUTHORITIES O USE DECENTRALIZED

MENU PLANINNG TO MEET THE TASTES OF CHILDREN FROM VARIOUS CULTURAL AND ETH:IIC BACKGROUNDS AND OFFER A WIDE

SELECTION OF FOODS THAT ARE HIGHLY PREFERRED &ND PALATASLE. THE DEPARTMENT'S PROPOSED REGULATIONS WOULD

REQUIRE STUDENT INVOLVEMENT IN NENU PLANNING AND ENCOLRAGE PARENT INVOLVEMENT IN SCHOOL LUNCH ACTI'ITIES.

16
APPENDIX I APPENDIX

WE SUPPORT THIS PROPOSAL, BUT WE BELIEVE PARENT INVOLVEMENT IN MENU PLANNING COULD HAVE SUBSrANTIAL POTENTIAL FOR REDUCING PLATE WASTE AND SHOULD E SPECifICALLY REQUIRED.

-- ENCOURAGE LOCAL SCHOOL AUTHORITIES TO IMPROVE LUrJCHROO31

ATMOSPHERE AND COIODITIONS.

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

THE TYPE A PATTERN TO PROVIDE GREATER LEXIBILITY IN

MENU PLANNING. THE PROPOSED REGULATIONS STATE THAT THE

DEPARTMENT IS CONTINUING TO EXPLORE A'LTERNATIVES TO TE

TRADITIONAL MENU PLANNING APPROACH ANI) REQUESTS PUBLIC

COMMENT ON THE USE O A NUTRIENT STANDARD.

17
APPENDIX II APPEND:X II

X ~UNITED .~. STATES GENERAL ACCOLNTING OFFICE

WASHINGTON. D.C. 4

a"stu"mrI &do boric

B-178564

June 15, 1977

The Honorable

The Secretary of Agriculture

Dear Mr. Secretary:

At the request of Congressman Frederick W. Richmond,

we are reviewing various food aspects of the school lunch

program in New York City. Although our work is not com- plete, we note one aspect of the program requiring iwaeliate attenticn and action by the Department of

Agriculture. We will include additional information on the reillts of our review in a subsequent report.

The Department's minium Type A lunch requirements provide the framework for nutritionally adequate school lunches and consist of specified amounts of protein-rich

foods, vegetables and fruits. bread, and milk. (See enc.

I.; We estimate, with 90-patcent certainty, that during

our test period at least 40 percent of the lunches served

to children in New York City schools did not meet these nutritional requirements. Department nd New York State

school lunch officials need to take immediate steps to

assure that lunches served in New York City, and elsewhere, meet minimum Type A requirements.

In March 1977 we briefed Department, State, and

City school lunch officials and Congressman Richmond's office on the results of this aspect of our review in

New York City. City officials were given access to the details supporting our findings. Details on our tests

and the results follow.

CED-77-89

I6
APPENDIX I APPENDrX II

3-178564

PROGRAM AMINISTRATION

Unoer the school lunch program, Federal subsidies are provided hrough thu State to school districts on the oasic of the numoer of Type A unches reported as served to

children n participating schools. In New York City about

96 million school lunches were served during the 1975-76 school year at a total cost of over $79.4 million. Federal

reimbursements were $62 million (78 percent), State

reimbursements ere $2.8 million (4 percent), and the City provided the balance of $14.6 million (15 percent).

The school lunch program is administered by the

Department's Food and Nutrition Service at the Federal

level, the New York State Education Department's ureau

of School Food Management at the State level, and the

ew York City Board of Edlcation's Bureau of chool Lunches

at the City schools. any of tne lunch components-- especially for meal pack style lunches--are purcnased from

vendors and assembled into complete lunches by local school

employees. In such cases, it ma, be possible for the

City to obtain refunds from vendors that supplied meal

components not meeting Type A requirementr.

TESTING ETHODOLOGY AD RESULTS

We used statistical sampling techniques to estimate

the number of school lunches 'served in New York City schools that met or failed to meet Type A requirements during our test periods. We tested each of the four types of lunches served--cafeteria style, meal pack, basic

(primarily soup and sandwiches), and bulk (prepared foods

frozen i: bulk). The first two types were tested between

January 10 and February 9, 1977; the oth,: two, between

February 10 and 22, 1977. Of the lunches served, about 57 percent were cafeteria sty'e, 30 percent were meal

pack, 7 percent were bulk, and 6 percent were basic.

Each type of lunch was tested as a separate sampling universe which enabled us to project the results to all

lunches of that type served during the respective test

periods.

We scientifically selected and sampled 40 cafeteria

style, 40 meal pack, 16 bulk, and 16 basic lunches.

Respective school lunch managers told us that each sample lunch we obtained was a Type A lursch.

19
APPENDIX II APPENDIX I

3- 78564

Di.t.tians at a Veterans Administration Hospital

laboratory in Nw ork City tested the lunches for compliance with Type A requirements basically using a weight

and measures test. The results are shown in the following

table.

Results o Tests for Tvoe A 'h Comaliance

in New orK Ctv .i_ g '

Area faLLing short of reuirements

Lunch Total heat ano

style sampled Passed Failed eat Vegetable vegetable Bread ilk

Cafeteria

style 40 20 20 6 9 4 0 1

Heal pack 40 18 22 7 8 7 0 0

Bulk 16 6 10 6 1 0 0

Basic 16 9 7 1 4 2 0 0

As noted above, some of the meals had two components failing

to meet minimum requirements. The amounts by which the-lunches

failed varied from a small part of one minimum component

(vegetable), to almost two-thirds of another (meat), and to

all of a third (milk).

The sample results, when projected to all lunches served

during the test periods, show that:

--At least 40 percent of all cfeteria style lunches

and 45 percent of all meal pack lunches served in

New York City schools during tile period January 10

through February 9 did not meet Type A requirements.l/

-At least 45 percent of all bulk lunches and 27

percent of all basic lunches served in New York

City schools during the period February 10

through 22 did not meet the Type A requirements.l/

IT/here is Q-percent certainty that a test of every lunch

served would show a failure rate at least as much as our

sample results.

20
APPENDIX II 

APPENDIX II

a-178564

--Federal reimbursement 

Type A requirements for lunches not meeting the during the test periods could be at least $3,718,000. (See encs. It and Ill.)

The Service has delegated responsibility of school lunch program monitoring to Neu, York State. The setate mak administrative reviews of program operations school districts are to see whether complying with program regulations. These 

lunch participant 

reviews have 

eligibility 

been Primarily concerned with school and program accountability. On occasion, the reviews have uncovered some noncompliances with the Type A lunch requirements due to ne or more missing lunch components. In such cases, Servicp regulations require that State agencies assure corrective action. According to a

New York State school lunch official, the Stat. assured that corrective action was taken through followu reviews. The came State official said that program funds have never been withheld from New York City because of noncomplianc. with Type A lunch requirements.

Richmond 

During 

on New 

a March 28, 1977, meeting held by Congressmad York City's school lunch program, the Congressman suggested that a joint Department/State task force be formed to correct program Problems.

RECOMENDATIONS

number 

Because 

of school 

our project ons showed that a significant lunches served in New Yo.k City fell short of eeting the Department's Type A requirements, we recommend that yc, direct the Administrator, Service, i:. Food and Nutrition

-Determine 

noncompliance 

the 

with 

extent to which the problem of

found in New 

the Type A lunch requirements

requiring broad, 

Yort City is a national problem major corrective measures.

--See 

action 

that 

to 

State 

establish 

or City officials take appropriate

vendors furnishing and collect claims against meal components contract specifications. not meeting

-Take appropriate action concerning ment for Federal reimburse- lunches served in New York City and else- where that failed to meet Type A lunch requirements.

21
APPENDIX II APPENDIX II

9-178564

AS you know, section 236 of the Legislative Reorganization Act of 1970 requires the head of a Federal agency to submit a written statement on actions taken on our recommendations to the House Committee on Gocernment Operaticn3 and tile Senate Committee on Governmental Affairs not later than 60 davs after the date of the report and to the House ad Ser.t¢ Committees

on Appropriations with the agency's first request for appropriations made more than 60 days after te dte of the report.

We are sending copies of his report to the above Committees' the House Committee orn Education and Labor and the Senate Committee on Agriculture, Nutrition, and Forestry; other interested Committees and embers of Congress, including Congressman Richnond; the Director, Office of Mana.gement and Budget; the Administrator, Fod and Nutrition Service; and the Director, Office of Audit.

Sincerely yours,

Henry Lschweae

Director

Enclosures - 3

22
APPENDLX II APPENDIX II

(ENCLOSURE I)

The Tlpe A Lunch Pattern...

The 

Rncoulended 

nauiocal Pl for chaol luaches n to t b ua lanst oe-third of ts Daily Dieur AUiowances of the Natmecl Rnes u Caacil for childr 

fraoare 

ol ,sano a ep pup. The Te A luncb quuewae pwie tbr k for utntoali cequ cho lunches. The kinds ad amunts of foods lted in the Tpe A lunch patern ae baed on te 196S RcnmuGded DanIy DwCuy Allowances far 10- to 2 -)ew old ar girls.

As puihfd in the Natioa Shod Lnc Rlul isa Tr, m A Is b shall sWn as a · M nimum Lch of the llownM food compaismI a the mmoum.

MrAT AD rN ' ALTERNATf

d trn at (ads f .ee u aal of ci oa poty or h or Iwo oos

sOm 

d; 

1 paim 

or oa _ res or .at vp f dy b.an, r i pe; or for l;bie- b~dtww1 a a oeqlI of ly CQMa- af a/ & -'f d l o41a. Tb 

t b 

a aJme a tan rwluiarm tmd foe as be q4W a & Ama dL um dab da om er m. emma 

,OEGTABNLES A)D FRLT'

A rume 

Th-fosrt scu-p c omal of two or mowe ,el s or rtis a tI-'. t. cp or mos) ot Nreoagb eiptaab or bw aw may be u o Ga as c* dm i VpmmaL

READ

Oat dc of Wfioi.grA , ncboe bfead or a· wrag of obn bmd an scoeMe m t" l ula. G rO -e m-t t a maelf orl tr.

FLLD LM

CaMLrll psat o bti~ -i at bmuas.

Add Oer Foods ot pan of the lunch rqumnmeua 1 ad to complte luo h. to help aepabiry ad t Oimprow prov ide daal food enr and ather utruans.

To help auu that all Type A lunchs meet the nomtionl goal. it i rom- madol4 that lunes itnaude: . . · VITAM1N A etable o frui at leat rwic a eek. . a VITAMN C vetUble or ruit e.l uLaMe a w L · · · r foods for IRON each day.

It also reommcwded tha: . Fat in the T)p A luac be kpt at modert 1.d. · .. lodid Salt be usd prqenng luna.

SUi yonr childr a ut lay able to eat the am st speim in the Type A lunch. the regulajoos prtalt wrinil thet childre laesr amou of smened food than ae specced abom. See GAO naote bov7.

To met the autruoal ne of trgen. the f rrlawom endonre ecouraing de cr'mlg to older bnn and irh of larger amounts o wected foods tha a specid la the Type A unch requrvet

GAO Note: For 

beans 

6- to l0-year-old boys and girls, only 1/3 cup of cooked dry or peas, or 3 ablespoo.is of peanu: butter are required.

Source: Food and Natrcttio Service

23
APDA..nT? TT APPENDIX II

(ENCLOSURE 11)

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to-Z. ~ ~ ~ ~ o s

7''

*4 -a . . -

V-' V I

aa a

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S. S · ,E

-6' UII * a a - pU

4.2

-5,

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LI·~~~~~~~~~~~~~~~

o a

I * '. * * I 

p. p. p - :1

~I ~ C, , S -

Y~~~~~~~~~~ 

S

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cc C r2
APPENDIX 11 PPD-CnTX TT

(ENCLOSURE III!

ESTIMATE OF TEE WEIGHTED AVERAGE OF

TEDERAL REIMBURSEMENT FOR EACH LUNCH

Lunch. Average daily Reimbursement reimbursement number of rate Average daily category lunches (note a) (note b) reimbursement

(cents)

(1) (2) (1) (2)

Paid 37,985 13.25 $ 5,033

Reduced 1B,078 63.25 11,434

Free 509,751 73.25 373,393

Total 565,814 c/68.90 $389,860

a/Average daily number of lunches served in November 1976.

b/Reimbixrsement rates for the period January to June 1977.

c/Weig:.;.ed average reimbursement rate:

Total daily reimbursement _ $389,860 - 68.90 cents tal average number of lunches 5E5,814 per lunch

(02392)

25