Exhibit E - Menu Labeling Final Rule.pdf

An Ancillary Report of the Food Service Guidelines for Federal Facilities

An Ancillary Report of the Food Service Guidelines for Federal Facilities2

Contributors Contributors to the authorship of An Ancillary Report of the Food Service Guidelines for Federal Facilities were from the

Food Service Guidelines Federal Workgroup. This workgroup consisted of more than 60 representatives from the following nine federal departments and agencies:

z U.S. Department of Health and Human Services z U.S. General Services Administration z U.S. Department of Agriculture z U.S. Department of Commerce z U.S. Department of Defense z U.S. Department of Education z U.S. Environmental Protection Agency z U.S. Department of Interior z U.S. Department of Veterans Affairs

Suggested Citation:

Food Service Guidelines Federal Workgroup. An Ancillary Report of the Food Service Guidelines for Federal Facilities. Washington, DC: US

Department of Health and Human Services; 2017.

An Ancillary Report of the Food Service Guidelines for Federal Facilities 3

Contents Introduction

Process for Updating the Food Service Guidelines

Request for Information

Updates to the Food Service Guidelines

Food and Nutrition Standards

Facility Efficiency, Environmental Support, and Community Development Standards

Food Safety Standards

Behavioral Design Standards

Glossary

References

Appendix: Members of the Food Service Guidelines Federal Workgroup and Their Affiliations at the Time of Service

An Ancillary Report of the Food Service Guidelines for Federal Facilities4

Introduction Purpose This document, An Ancillary Report of the Food Service Guidelines for Federal Facilities, was written to complement and provide supporting documentation for the Food Service Guidelines for Federal Facilities. The purpose of this report is to:

zz Describe the methods used to update the 2011 HHS/GSA Guidelines.

zz Provide rationales for the standards in the Food Service Guidelines for Federal Facilities.

The Health and Sustainability Guidelines for Federal Concessions and Vending Operations1 (2011 HHS/GSA Guidelines*) was updated in 2017 and renamed, Food Service Guidelines for Federal Facilities. Updates began in April 2015 and were timed to follow the release of the 2015–2020 Dietary Guidelines for Americans, 8th Edition2 (2015–2020 Dietary Guidelines). The March 2015 release of Executive Order 13693 (Planning for Federal Sustainability in the Next Decade)3 on energy efficiency and environmental performance also supported the need to update the 2011 HHS/GSA Guidelines. This update also included a new section on food safety, guided by the Food Code,4 to ensure protection against foodborne illness. Behavioral design standards were added to facilitate the food and nutrition standards by providing strategies for encouraging consumers to select healthier foods and beverages.

The Food Service Guidelines for Federal Facilities provides specific food, nutrition, facility efficiency, environmental support, community development, food safety, and behavioral design standards for food service concession and vending operations at federal facilities. The standards apply primarily to venues in which food is sold (such as cafeterias, cafés, snack bars, grills, concession stands, sundry shops, micro markets,† and vending machines) but may be adapted to venues in which food is served (such as federal hospitals, correction facilities, or military dining facilities) and the government is responsible for providing individuals with meals that meet all or part of their daily or weekly nutrition needs.‡ Key audiences for the Food Service Guidelines for Federal Facilities are federal acquisition officials and staff who develop requests for food service proposals and negotiate contracts; food service vendors competing for federal food service contracts; participants in the Randolph-Sheppard Vending Facility Program; and people who monitor or advise food service operations, such as worksite wellness stakeholders or contracting officers.

Contracts for food service at federal facilities typically begin with the issuance of a request for proposal (RFP). The RFP usually describes the level and quality of food service expected

* The U.S. Department of Health and Human Services (HHS) and the U.S. General Services Administration (GSA) released the Health and Sustain-ability Guidelines for Federal Concessions and Vending Operations in March 2011. The document is commonly referred to as the 2011 HHS/ GSA Guidelines.

† See glossary for definition.

‡ The Food Service Guidelines for Federal Facilities does not apply to food served to children in child care or school settings that are governed by federal laws and regulations, including the National School Lunch Program, the School Breakfast Program, the Child and Adult Care Food Pro-gram, and the Summer Food Service Program.

An Ancillary Report of the Food Service Guidelines for Federal Facilities 5 for a specific location and outlines to potential bidders how their proposals will be evaluated.

Standards in the Food Service Guidelines for Federal Facilities are intended to be written into these RFPs and can be included in the evaluation criteria for ranking proposals (typically with other criteria, such as corporate capabilities, resources, and staffing). They can help with selection of a vendor by distinguishing the best overall proposal based on the number of standards the bidder is able to implement.

Process for Updating the Food Service Guidelines The process for updating the 2011 HHS/GSA Guidelines1 was coordinated by the U.S.

Department of Health and Human Services (HHS) and the U.S. General Services Administration (GSA). Efforts were led by HHS’s Centers for Disease Control and Prevention (CDC), specifically CDC’s Division of Nutrition, Physical Activity, and Obesity§ and Office of the Associate Director for Policy, in partnership with GSA’s Public Buildings Service and Facility Management and Services Program. The Food Service Guidelines Federal Workgroup was formed and was composed of more than 60 representatives from nine key federal departments or agencies (Table 1). Workgroup members had expertise in various fields, including nutrition, food safety, facility operations and efficiency, implementation of food service guidelines, and behavioral design. All members of the workgroup were federal employees, except for two members who were contract employees for the U.S. Department of Agriculture (USDA) and CDC during the time that they participated in the workgroup. No workgroup members reported any competing interests.

Three subcommittees—Food and Nutrition, Facility Efficiency and Procurement, and Food Safety—were formed from the larger Food Service Guidelines Federal Workgroup (Table 2).

Subcommittee members reviewed the 2011 HHS/GSA Guidelines and made recommendations to keep, modify, or drop existing standards or to develop new standards. In making their recommendations, members considered existing federal policy documents, industry standards, stakeholder input, implementation feasibility, and expert opinion. The members of each subcommittee agreed on the final standards for their section. A Behavioral Design Working Group was formed from the three subcommittees and consisted of 13 representatives from five federal departments or agencies (Table 2). Decisions about specific behavioral design standards took into consideration the 2011 HHS/GSA Guidelines, the feasibility of implementation in federal facilities, stakeholder input, expert opinion, and research and practice-based evidence.

Promising strategies from the literature were determined by selective examination of 11 review articles, six of which were systematic reviews.

The Project Support Team (consisting of CDC, HHS, and GSA staff ) provided logistical assistance to the subcommittees and working group. The Food Service Guidelines Federal Workgroup reviewed and approved the Food Service Guidelines for Federal Facilities.

§ The Division of Nutrition, Physical Activity, and Obesity is in CDC’s National Center for Chronic Disease Prevention and Health Promotion.

An Ancillary Report of the Food Service Guidelines for Federal Facilities6

Table 1. Federal Departments or Agencies and Operating Divisions on the Food Service Guidelines Federal Workgroup

Federal Departments or Agencies Operating Divisions

U.S. Department of Health and Human Services (HHS) zz Centers for Disease Control and Prevention (CDC) zz U.S. Food and Drug Administration (FDA) zz National Institutes of Health (NIH) zz Office of the Assistant Secretary of Health (OASH) zz Office of the Assistant Secretary for Planning and Evaluation (ASPE) zz Program Support Center (PSC)

U.S. General Services Administration

(GSA)

zz Public Buildings Service (PBS)

U.S. Department of Agriculture

(USDA)

zz Agricultural Marketing Service (AMS) zz Center for Nutrition Policy and Promotion (CNPP) zz Food Safety and Inspection Service (FSIS) zz Office of the Chief Economist (OCE) zz Office of the Secretary (OSEC)

U.S. Department of Commerce (DOC) zz National Oceanic and Atmospheric Administration (NOAA)

U.S. Department of Defense (DOD) zz Defense Health Agency (DHA) zz Under Secretary of Defense for Personnel and Readiness (P&R)

U.S. Department of Education (ED) zz Office of Special Education and Rehabilitative Services (OSERS)

U.S. Environmental Protection Agency

(EPA)

zz Office of Land and Emergency Management (OLEM) zz Office of Research and Development (ORD)

U.S. Department of Interior (DOI) zz National Park Service (NPS)

U.S. Department of Veterans Affairs

(VA)

zz Veterans Canteen Service (VCS) zz Veterans Health Administration (VHA)

An Ancillary Report of the Food Service Guidelines for Federal Facilities 7

Table 2. Participation of Federal Departments or Agencies and Operating Divisions on the Subcommittees and Behavioral Design Working Group of the Food Service Guidelines Federal Workgroup

Food and Nutrition Subcommittee

(35 representatives)

Facility Efficiency and Procurement

Subcommittee (21 representatives)

Food Safety Subcommittee

(24 representatives)

Behavioral Design Working Group

(13 representatives)

HHS: CDC, FDA, NIH, OASH,

PSC

HHS: CDC, ASPE HHS: CDC, FDA, OASH, PSC HHS: CDC, NIH, OASH

GSA: PBS GSA: PBS GSA: PBS GSA: PBS

DOD: DHA, P&R DOC: NOAA DOD: P&R DOD: P&R

ED: OSERS DOD: P&R DOI: NPS ED: OSERS

USDA: CNPP, OSEC DOI: NPS ED: OSERS USDA: CNPP, OSEC

VA: VCS, VHS ED: OSERS USDA: FSIS, OSEC -

- EPA: OLEM, ORD - -

- USDA: AMS, OCE, OSEC - -

- VA: VCS - -

Note: The number of representatives refers to individuals, not departments and agencies. Some representatives served on more than one subcommittee or working group.

Request for Information GSA, in conjunction with HHS, sought public input on implementation of the 2011 HHS/ GSA Guidelines from the vending and food service industry, worksite leadership, public and environmental health organizations, and other parties interested in food service guidelines.

To obtain public input, GSA issued a Request for Information (RFI) that remained open from July 30, 2015, through September 30, 2015. The intent of the RFI was to gather insights on the successes and barriers encountered when implementing the 2011 HHS/GSA Guidelines, the impact of implementing the 2011 HHS/GSA Guidelines on the workforce and profits, and the ability to source products.

The RFI was disseminated through FedBizOpps, which is used for federal government procurement opportunities. The FedBizOpps link to the RFI was distributed widely through agency communication channels, such as CNPP’s MyPlate e-mail delivery system, CDC’s chronic disease and community health programs and listservs, VA nutrition managers, and NOAA’s partners and stakeholders.

GSA received 32 responses to the RFI. Respondents included 19 nonprofit 501(c)(3) organizations that support health, nutrition, people who are blind, environmental protection, animal welfare, and consumer interests; four food service operators; two state health

An Ancillary Report of the Food Service Guidelines for Federal Facilities8 departments; two academic institutions; two trade associations; one state Department of Employment, Training and Rehabilitation; one professional society; and one private citizen.

Comments covered a wide range of issues, such as facilitators and barriers to implementation, and recommendations for the inclusion of standards for specific topics such as beverages, calories, cereals and grains, cooking methods, dairy products, fruits and vegetables, local and organic foods, meat and poultry, plant-based protein, pricing and promotion, saturated fat, vending, waste reduction, water, and worker justice. Responses were summarized and categorized by the Project Support Team and provided to the leaders of the subcommittees for consideration in their deliberations of standards for inclusion in the Food Service Guidelines for Federal Facilities. Comments specific to facilitators and barriers will help inform development of implementation guidance documents, tools, and other resources.

Updates to the Food Service Guidelines Details about how the Food Service Guidelines for Federal Facilities was modified from the 2011 HHS/GSA Guidelines are described in this section. To summarize:

zz The Food and Nutrition standards were updated to align with the 2015–2020 Dietary Guidelines.2 zz The Facility Efficiency, Environmental Support, and Community Development standards were updated to align with the March 2015 release of Executive Order 13693,3 which directed federal agencies to increase efficiency and improve their environmental performance.

zz A new section on Food Safety standards that is based on FDA’s Food Code4 was added to minimize the risk of foodborne illnesses.

zz A new section on Behavioral Design standards was added to facilitate implementation of the Food and Nutrition standards by encouraging consumers to select healthier foods and beverages.

Standards in the Food Service Guidelines for Federal Facilities are categorized by two levels of implementation: Standard and Innovative. Standard criteria are considered to be widely achievable within food service and are expected to be implemented. Innovative criteria promote exceptional performance in various areas of food service and are encouraged. Both implementation levels are supported by the scientific literature as being beneficial to health or the environment (or both) or in alignment with existing national policies or guidance.

An Ancillary Report of the Food Service Guidelines for Federal Facilities 9

Food and Nutrition Standards The Food and Nutrition standards in the Food Service Guidelines for Federal Facilities are used to increase the availability of healthier food and beverages in federal food service facilities so that consumers can more readily choose healthier options. In determining the Food and Nutrition standards, subcommittee members began with a review of the 2011 HHS/GSA Guidelines, and then, as described previously, made decisions to keep, modify, or drop existing standards or develop new standards. Because the update process began before the 2015–2020 Dietary Guidelines2 was released, preliminary decisions were made using the Dietary Guidelines for Americans, 2010,5 the Scientific Report of the 2015 Dietary Guidelines Advisory Subcommittee,6 and USDA’s Smart Snacks in School7 nutrition criteria. Once the 2015–2020 Dietary Guidelines was released, the Food and Nutrition standards in the Food Service Guidelines for Federal Facilities were reviewed and modified as needed to be consistent. As part of their decision-making process, subcommittee members also considered FDA’s food regulations and other relevant federal laws, regulations, and policies, as well as research and practice-based evidence, industry standards, stakeholder input, and expert opinion.

Classifications of the Food and Nutrition Standards Prepared Foods This category includes foods that are fresh, cleaned, cooked, assembled (e.g., salad, sandwich), or otherwise processed and served “ready-to-eat.” Prepared foods include those that are made and served on-site or those prepared at a central kitchen and then packaged and distributed to other locations. These foods have a relatively limited shelf life (compared to Packaged Snacks) and can be sold in any food service venue. Examples of prepared foods include hot entrées, side dishes, soups, salads, deli sandwiches, and fresh whole fruits and vegetables.

Packaged Snacks This category includes processed foods that are packaged in small portions or individual servings, are widely distributed, and have a relatively long shelf life (compared to Prepared Foods). Packaged snacks include food items such as granola bars, chips, crackers, raisins, nuts, and seeds. These foods can be sold in any venue, such as vending machines or “grab-n-go” areas of cafeterias.

Beverages This category includes drinks such as water, milk, 100% juice, soft drinks, energy drinks, teas, and coffees.

An Ancillary Report of the Food Service Guidelines for Federal Facilities10

The Food and Nutrition Subcommittee reclassified the Food and Nutrition standards from Concessions and Vending in the 2011 HHS/GSA Guidelines1 to Prepared Foods, Packaged Snacks, and Beverages in the updated Food Service Guidelines for Federal Facilities. This change was intended to simplify guidance for vendors and make standards for similar products apply across all types of food service venues, regardless of whether the food is sold in a vending machine or served in a cafeteria. Unless otherwise noted, these standards apply across all vending and concessions, including cafeterias, cafés, snack bars, grills, concession stands, sundry shops, micro markets,** and vending machines.

The primary sources used for the Food and Nutrition standards were the 2015–2020 Dietary Guidelines2 and the Smart Snacks in School food and nutrition criteria.7 The 2015–2020 Dietary Guidelines informs the development of federal food, nutrition, and health policies and programs. Aligning the Food and Nutrition standards with the 2015–2020 Dietary Guidelines helps to ensure that the Food Service Guidelines for Federal Facilities is consistent with the latest science and recommendations and that foods and beverages are available to help people achieve a healthy eating pattern.†† The 2015–2020 Dietary Guidelines provides five overarching Guidelines that are intended to “encourage healthy eating patterns, recognize that individuals will need to make shifts in their food and beverage choices to achieve a healthy eating pattern, and acknowledge that all segments of our society have a role to play in supporting healthy choices.”2 The standards in the Food Service Guidelines for Federal Facilities address all five Guidelines of the 2015–2020 Dietary Guidelines: (1) Follow a healthy eating pattern across the lifespan; (2) Focus on variety, nutrient density, and amount; (3) Limit calories from added sugars and saturated fats and reduce sodium intake; (4) Shift to healthier food and beverage choices; and (5) Support healthy eating patterns for all.2 They also focus on the more detailed Key Recommendations in the 2015–2020 Dietary Guidelines, which provide further guidance on quantitative amounts needed to meet a healthy eating pattern.

The Smart Snacks in School food and nutrition criteria align with USDA’s interim final rule for all foods sold outside the National School Lunch Program and School Breakfast Program.8 The rule was established to make competitive foods consistent with the criteria used in these federal programs8 and is based on the Dietary Guidelines for Americans, 2010.5 Although the Food and Nutrition Subcommittee decided to adapt the Smart Snacks in School7 criteria for the Packaged Snacks category of the Food Service Guidelines for Federal Facilities, it did not include a limit on total fat because the 2015–2020 Dietary Guidelines does not have a quantitative Key Recommendation for this nutrient. The 2015–2020 Dietary Guidelines emphasizes the types and amounts of fats (such as consuming low-fat or non-fat dairy and lean meats, getting less than 10% of total calorie intake from saturated fats, and shifting from solid fats to oils) instead of limiting total fat, which can vary according to individual calorie levels.‡‡ The decision to use Smart Snacks in School criteria was based on the many food and beverage products developed

** See glossary for definition.

†† The 2015–2020 Dietary Guidelines provides examples of three healthy eating patterns: the Healthy U.S.-Style Eating Pattern, the Healthy

Mediterranean-Style Eating Pattern, and the Healthy Vegetarian Eating Pattern.

‡‡ Although it is not a Key Recommendation, the 2015–2020 Dietary Guidelines includes a recommendation that total fat consumption should be within the Adequate Micronutrient Distribution Range, without exceeding calorie limits.

An Ancillary Report of the Food Service Guidelines for Federal Facilities 11 for schools that can be used for federal facilities. Packaged snack foods that meet Smart Snacks in School criteria meet the Food Service Guidelines for Federal Facilities packaged snack standards.

The rationales for each of the Food and Nutrition standards in the Food Service Guidelines for Federal Facilities are shown in Tables 3, 4, and 5. Rationales for standards from the 2011 HHS/GSA Guidelines that are not included as stand-alone standards in the Food Service Guidelines for Federal Facilities, but whose elements are incorporated into other standards, are shown in Table 6.

Table 3. Rationales for Food and Nutrition Standards for Prepared Foods, Food Service Guidelines for Federal Facilities

Category Standards

(Implementation Levela)

Rationales

Fruits and Vegetables

Offer a varietyb of at least 3 fruitc options daily, with no added sugars.

Fruit can be fresh, canned,d frozen, or dried.e

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to broaden the sources (fresh, canned, frozen, or dried) of fruit included and to emphasize that all sources of fruit should not contain added sugars (only canned fruit was mentioned previously).

The standard emphasizes offering a variety of fruits by recommending that at least 3 fruit options are offered daily. In the 2015–2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to include fruit, especially whole fruit, in the diet.2 Whole fruits can be in the following forms: fresh, canned, frozen, or dried. The recommendation of 3 options is based on the wide variety of fruits available in the U.S. marketplace.

Providing at least 3 fruit options daily can help people meet the 2 cups of fruit per day recommendations from the Healthy U.S.-Style Eating Pattern at the 2,000-calorie level.2

Offer a varietyb of at least 3 non-fried vegetable options daily. Vegetables can be fresh, frozen, or canned, and served cooked or raw.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to include an increase from 2 to 3 options and to broaden the sources of vegetables (fresh, canned, or frozen) and serving form (cooked or raw).

In the 2015–2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to include “a variety of vegetables from all of the subgroups—dark green, red and orange, legumes (beans and peas), starchy, and other.”2 The recommendation of 3 options is based on the wide variety of vegetables available in the U.S. marketplace.

Providing at least 3 vegetable options daily can help people meet the 2½ cups of vegetables per day recommendations from the Healthy U.S.-Style Eating Pattern at the 2,000-calorie level.2

Offer seasonal fruit and vegetables.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to include both fruits and vegetables in one standard.

Some fruits and vegetables are available in the U.S. marketplace year-round and others seasonally. Offering fresh fruits and vegetables when in season and at peak flavor is a strategy for providing a variety of these foods while controlling food costs.

Grains

Offer half of total grains as “whole grain-rich” products,b daily.

(Standard)

This standard is new to the Food Service Guidelines for Federal Facilities. The intent of this standard is to increase the overall offerings of whole grains. In the 2015–2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to include “grains, at least half of which are whole grains.”2

Providing whole grains can help individuals meet the recommendation of at least 3-ounce equivalents of whole grains for the Healthy U.S.-Style Eating Pattern at the 2,000-calorie level.2

Continued

An Ancillary Report of the Food Service Guidelines for Federal Facilities12

Category Standards

(Implementation Levela)

Rationales

Grains (continued)

Offer a “whole grain-rich” productb as the first (i.e., defaultf) choice.

(Innovative)

This standard is updated from the 2011 HHS/GSA Guidelines1 to include the term “whole grain-rich” product versus a 100% whole grain product.

The intent of this standard is to always offer a whole grain-rich product as the pre-set choice when a grain is offered. In other words, to receive a non-whole grain, a consumer would specifically have to request or select a non-whole grain option.

Studies from multiple fields suggest that people are more likely to keep the default selection rather than to change it.9,10 Therefore, this standard may help people meet the recommendation of at least 3 ounce-equivalents of whole grains from the Healthy U.S.- Style Eating Pattern at the 2,000-calorie level,2 while still maintaining choice.

Dairy

Offer a variety of low-fat dairy productsb (or dairy alternatives) daily, such as milk, yogurt, cheese, and fortified soy beverages.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to specify a daily offering of a dairy product and to be consistent with the 2015–2020 Dietary Guidelines.2 In the 2015–2020 Dietary Guidelines2 a Key Recommendation for a healthy eating pattern is to include “fat-free or low-fat dairy, including milk, yogurt, cheese and/or fortified soy beverages.”2

When yogurt is available, offer at least one low-fat plain yogurt.

(Innovative)

This standard is updated from the 2011 HHS/GSA Guidelines1 to remove the 2% criteria for yogurt to be consistent with the 2015–2020 Dietary Guidelines2 and to remove the specifications for caloric sweeteners. The standard as written in the 2011 HHS/GSA Guidelines was difficult to implement because added sugars were not required to be included on the Nutrition Facts label. Because most low-fat yogurts available in the marketplace are below the Smart Snacks in School sugar limit of ≤35% of weight from total sugars in foods,7 yogurt was included in the dairy group as a standard criterion and low-fat plain yogurt that does not contain added sugars was added as an innovative criterion.

The intent of this standard is to allow customers to choose low-fat yogurt while also limiting their intake of added sugars. Plain yogurt does not contain added sugars. In addition to meeting the 2015–2020 Dietary Guidelines Key Recommendation for the dairy group, this standard also helps consumers meet the Key Recommendations for a healthy eating pattern, which is to “consume less than 10 percent of calories per day from added sugars” and to “consume less than 10 percent of calories per day from saturated fats.2

Protein Foods

Offer a varietyb of non-fried protein foods, such as seafood,b lean meats and poultry,b eggs, legumes (beans and peas), nuts, seeds, and soy products, daily.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to broaden the variety of protein foods to align with the 2015–2020 Dietary Guidelines, which states that a Key Recommendation for a healthy eating pattern is to include “a variety of protein foods, including seafood, lean meats and poultry, eggs, legumes (beans and peas), and nuts, seeds, and soy products.”2

An Ancillary Report of the Food Service Guidelines for Federal Facilities 13

Standards

(Implementation Levela)

Rationales

Protein Foods (continued)

Offer protein foods from plants such as legumes (beans and peas), nuts, seeds, and soy products at least three times per week.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to specify the type of protein foods from plants and to increase the frequency from twice a week to three times a week.

A Key Recommendation in the 2015–2020 Dietary Guidelines2 is to consume a “variety of protein foods, including seafood, lean meats and poultry, eggs, legumes (beans and peas), and nuts, seeds, and soy products.” For balance and flexibility, the Healthy U.S.- Style Eating Pattern includes weekly recommendations for these various subgroups. This standard ensures that plant-based proteins are included among the variety of protein foods available and can help increase the availability of options that meet the Healthy Vegetarian Pattern2 for those choosing that pattern of eating.

Offer protein foods from plants, such as legumes (beans and peas), nuts, seeds, and soy products, daily.

(Innovative)

This standard is new to the Food Service Guidelines for Federal Facilities. The intent of this standard is to increase the availability of options that meet the Healthy Vegetarian Pattern2 for those choosing that pattern of eating. To increase availability, legumes, nuts, seeds, and soy products could be offered at multiple food stations within a cafeteria, including the deli, salad bar, and hot or cold food counters.

Offer seafoodb at least two times a week.

(Standard)

This standard is new to the Food Service Guidelines for Federal Facilities. In the 2015–2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to include a variety of protein foods (which includes seafood). The 2015–2020 Dietary Guidelines recommends at least 8 ounce-equivalents of seafood per week as part of the Healthy U.S.-Style Eating Pattern.2 Offering seafood twice per week can help people meet this recommendation.

Desserts

When desserts are available, offer 25% of desserts containing ≤200 calories as served.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to suggest a calorie limit (≤200 calories) that one-fourth of desserts offered would meet. The intent of offering some desserts with ≤200 calories is to help people limit added sugars and saturated fats in their diets and to stay within their discretionary calorie limits. Two Key Recommendations for a healthy eating pattern in the 2015–2020 Dietary Guidelines are to “consume less than 10 percent of calories per day from added sugars” and to “consume less than 10 percent of calories per day from saturated fats.”2 The 2015– 2020 Dietary Guidelines also states, “Most calorie patterns do not have enough calories available after meeting food group needs to consume 10 percent of calories from added sugars and 10 percent of calories from saturated fats and still stay within calorie limits.”2

For a Healthy U.S.-Style Eating Pattern at the 2,000-calorie per day level, a limit of 270 calories is suggested for other uses after food group recommendations are met in their nutrient-dense forms.2 Thus, the threshold of ≤200 calories was chosen to stay within this limit of 270 calories.2

An Ancillary Report of the Food Service Guidelines for Federal Facilities14

Standards

(Implementation Levela)

Rationales

Sodium

All mealsb offered contain ≤800 mg sodium.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to change sodium requirement from ≤900 mg to ≤800 mg per meal.

In the 2015–2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to “consume less than 2,300 mg of sodium per day” for adults and children aged 14 years or older.2 The amount of 800 mg sodium was chosen because it is about one-third of the recommended 2,300 mg.

This standard is similar to USDA’s National School Lunch Program and School Breakfast Program target of <740 mg per meal for grades 9 through 12 by 2022.11 It is also consistent with the standard of ≤800 mg used by two national, nonprofit health organization (American Heart Association12 and the Partnership for a Healthier America for their Hospital Healthier Food Initiative13) and a line of healthier food products from a large food service company (Mindful by Sodexo14). The use of this standard by other organizations and companies demonstrates the feasibility of having a sodium standard at this level.

All entreesb offered contain ≤600 mg sodium.

(Standard)

This standard is new to the Food Service Guidelines for Federal Facilities. The intent of this standard is to limit sodium content of entrees to ≤600 mg to meet the 2015–2020 Dietary Guidelines, Key Recommendation for a healthy eating pattern to include less than 2,300 mg of sodium per day.2 A typical entrée makes up about two-thirds of a meal. Therefore, the sodium standard for the entrée is about two-thirds of the sodium standard for a meal, or about 533 mg. This value was rounded to ≤600 mg.

The criterion of 600 mg of sodium per entrée is feasible for implementation. For example, it is consistent with the standards used by the Los Angeles County Department of Public Health (for their Choose Health LA initiative)15 and a “better-for-you” line of food products from a large food service company (Sensible Selection by Eurest).16

All side itemsb offered contain ≤230 mg sodium.

(Standard)

This standard is new to the Food Service Guidelines for Federal Facilities. The intent of this standard is to limit sodium content of side items to ≤230 mg sodium, as served. In the 2015–2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to include less than 2,300 mg per day of sodium.2 This sodium standard is consistent with the USDA’s final interim rule for all foods sold in school, which is ≤230 mg sodium for sides.8

Trans Fats

All foods do not include partially hydrogenated oils.

(Standard)

This standard was included in the 2011 HHS/GSA Guidelines,1 but minor wording changes were made to simplify the standard. The intent of this standard is to eliminate foods that contain artificial or industrially produced trans fats, rather than naturally occurring trans fats that are found in meats and dairy foods in small quantities. Partially hydrogenated oils are the major source of artificial trans fats in the food supply.17

The 2015–2020 Dietary Guidelines states that “Individuals should limit intake of trans fats to as low as possible by limiting foods that contain synthetic sources of trans fats, such as partially hydrogenated oils in margarines, and by limiting other solid fats.”2 On June 17, 2015, FDA released its final determination that partially hydrogenated oils are not Generally Recognized as Safe.18

An Ancillary Report of the Food Service Guidelines for Federal Facilities 15

Standards

(Implementation Levela)

Rationales

Calorie and Nutrition Labeling

Provide calorie and nutrition information of standard menu items as required by FDA in Menu Labeling Final Rule:

Food Labeling;

Nutrition Labeling of Standard Menu Items in Restaurants and Similar Retail Food Establishments.f

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to reference FDA’s Menu Labeling Final Rule: Food Labeling; Nutrition Labeling of Standard Menu Items in Restaurants and Similar Retail Food Establishments.19 The intent of this standard is to provide customers with calorie and nutrition information to help them make informed and healthy choices.

Other Considerations

Limit deep-fried entréeb options to no more than one choice per day.

(Standard)

This standard was included in the 2011 HHS/GSA Guidelines.1

The 2015–2020 Dietary Guidelines recommends consuming foods in their nutrient-dense form without added saturated fats, sugars, and sodium. In addition, a Key Recommendation for a healthy eating pattern is to “consume less than 10 percent of calories per day from saturated fats.”2 Fried foods may contain added saturated fat, and they contribute excess calories that exceed calorie limits for a healthy eating pattern.

a Standard implementation criteria are considered to be widely achievable within food service; implementation at this level is expected. Innovative implementation criteria promote exceptional performance in various areas of food service; implementation at this level is encouraged.

b See glossary for definition.

c Fruits mixed with foods from other food groups such as grain and dairy do not count towards meeting this standard.

d Canned fruit may be packed in 100% juice with no added sugars.

e Dried fruits are exempted from the sugar criterion for this standard. Dried fruits may contain nutritive sweeteners required for processing and/or palatability.

f The rule “applies to restaurants and similar retail food establishments if they are part of a chain of 20 or more locations, doing business under the same name, offering for sale substantially the same menu items and offering for sale restaurant-type foods.”19 Restaurants or similar retail food establishments (including food service operations) with fewer than 20 locations may voluntarily register to be covered by the rule.19

An Ancillary Report of the Food Service Guidelines for Federal Facilities16

Table 4. Rationales for Food and Nutrition Standards for Packageda Snacks, Food Service Guidelines for Federal Facilities

Category Standards (Implementation Levela) Rationales

Food and Nutrient Profilec

All packaged snacks contain ≤200 mg sodium per package.

(Standard)

This standard was included in the 2011 HHS/GSA Guidelines for vending.

However, minor wording changes were made to match the current classification structure of Packaged Snacks that applies in all food service facilities, such as vending machines, micro markets, and grab-and-go areas of cafeterias, rather than only to vending operations.

About 75% of the sodium that Americans consume comes from packaged and restaurant foods,20 with about 14% coming from snack foods.21 Given that snacking frequency and the percentage of people who report snacking on a daily basis has continued to increase over the past few decades,22 sodium reduction in snack foods can help people reduce sodium in their diets.

All packaged snacks have 0 grams of trans fat.

(Standard)

This standard was included in the 2011 HHS/GSA Guidelines for vending operations. However, minor wording changes were made to match the current classification structure of the Food and Nutrition standards.

This standard is part of the Smart Snacks in School7 food and nutrient criteria. This standard applies to packaged snacks sold in all food service facilities, such as vending machines, micro markets, and grab-and-go areas of cafeterias, rather than only to vending operations.

The intent of this standard is to eliminate snack foods that contain industrially produced or artificial trans fats. Partially hydrogenated oils are the major source of artificial trans fats in the food supply.17 On June 17, 2015, FDA released its final determination that partially hydrogenated oils are not Generally Recognized as Safe.18

At least 75% of packaged snacks meet the following food and nutrient standards.

Food Standards:

zz Have as the first ingredient a fruit, a vegetable, a dairy product, or a protein food; or zz Be a whole grain-rich grain product;d or zz Be a combination food that contains at least ¼ cup of fruit and/or vegetable.

AND (continued next page)

This standard is updated from the 2011 HHS/GSA Guidelines1 to include USDA’s Smart Snacks in School food and nutrient standards7 and any exemptions noted in USDA’s interim final rule for all foods sold in school.8 In the Food Service Guidelines for Federal Facilities, this standard applies to packaged snacks sold in all food service facilities, such as vending machines, micro markets, and grab-and-go areas of cafeterias, rather than only to vending operations. All packaged snacks that qualify for Smart Snacks in School will also meet the standard in the Food Service Guidelines for Federal Facilities.

(continued next page)

An Ancillary Report of the Food Service Guidelines for Federal Facilities 17

Category Standards (Implementation Levela) Rationales

Food and Nutrient Profilec

(continued)

Nutrient Standards:

zz Calorie limit: ≤200 calories.

zz Saturated fat limit: <10% of calories.

○ Exemptions: Reduced-fat cheese and part skim mozzarella; nuts, seeds, and nut/seed butters; and dried fruit with nuts/seeds with no added nutritive sweeteners or fats.

zz Sugar limit: ≤35% of weight from total sugars in foods.

○ Exemptions: Dried/dehydrated whole fruits or vegetables with no added nutritive sweeteners; dried whole fruits or pieces with nutritive sweeteners required for processing and/or palatability; products consisting of only exempt dried fruit with nuts and/or seeds with no added nutritive sweeteners or fats.

(Standard)

Rationale for 75% of packaged snacks meeting food and nutrient criteria: Establishing food and nutrient standards for packaged snacks can help people meet the 2015–2020 Dietary Guidelines Key Recommendations for consuming foods in their nutrient-dense form, while limiting saturated fat and total sugars. In addition, for a Healthy U.S.-Style Eating Pattern at the 2,000-calorie per day level, a limit of 270 calories is suggested for other uses after food group recommendations are met in their nutrient-dense forms.2 Thus, having 75% of packaged snack items within a threshold of ≤200 calories can help consumers stay within the limit of 270 calories.2 Because the Food Service Guidelines for Federal Facilities is not intended to limit choice (but rather to ensure healthier food options are available), only 75% of packaged snacks are expected to meet the food and nutrient standards for packaged snacks.

Rationale for not including Smart Snacks in School criterion for total fat: Because the 2015–2020 Dietary Guidelines does not have a Key Recommendation for limiting total fat, the nutrient criteria for this standard does not include the Smart Snacks in School7 criterion that food items must have ≤35% calories from total fat as served.

Calorie Labeling

FOR VENDING: All snack foodse sold in vending machines are consistent with FDA’s Vending Machine Final Rule: Food Labeling;

Calorie Labeling of Articles of Food in Vending Machines.f

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines to align with FDA’s final rule for vending. The intent of this standard is to provide customers with calorie information to help them make informed and healthful selections from vending machines. The standard is the FDA’s Vending Machine Final Rule: Food Labeling;

Calorie Labeling of Articles of Food in Vending Machines.23 a Standards are written to apply per package, irrespective of size or number of servings.

b Standard implementation criteria are considered to be widely achievable within food service; implementation at this level is expected. Innovative implementation criteria promote exceptional performance in various areas of food service; implementation at this level is encouraged.

c The food and nutrient profile standards were adapted from the USDA’s Smart Snacks in School nutritional criteria.7 d See glossary for definition.

e This standard applies to both packaged and unpackaged snack foods sold in vending machines.

f This rule “requires operators who own or operate 20 or more vending machines to disclose calorie information for food sold from vending machines, subject to certain exemptions as specified in the rule.” Vending machine operators with fewer than 20 vending machines may voluntarily register to be covered by the rule.23

An Ancillary Report of the Food Service Guidelines for Federal Facilities18

Table 5. Rationales for Food and Nutrition Standards for Beverages, Food Service Guidelines for Federal Facilities

Category Standards (Implementation Levela) Rationales

Beverages

Provide free access to chilled, potable water.

(Standard)

This standard was included in the 2011 HHS/GSA Guidelines.1 However, minor wording changes were made to eliminate the phrase “no charge” because there may be a charge for beverage cups.

The intent of this standard is to provide people with free access to drinking water with no added sugars. The 2015–2020 Dietary Guidelines states that “choosing beverages with no added sugars, such as water, in place of sugar-sweetened beverages” is a way to “shift” added sugar consumption to less than 10% of calories per day.2

When milk and fortified soy beverages are available, offer low-fat beverages with no added sugars.

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to remove the 2% criteria for dairy to be consistent with the 2015– 2020 Dietary Guidelines2 and to add “fortified soy beverages” and the phrase “with no added sugars.” Low-fat milk and fortified soy beverages contain important nutrients in addition to calories and can be consumed within recommended amounts in place of sugar-sweetened beverages.2

When juice is available, offer 100% juice with no added sugars.b

(Standard)

This standard was included in the 2011 HHS/GSA Guidelines,1 but minor wording changes were made for clarity.

The standard limits added sugars by only allowing juice that is 100% juice. In the 2015–2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to limit added sugars to less than 10% of calories per day. The 2015–2020 Dietary Guidelines state that, when juices are consumed, they should be 100% juice, without added sugars.2

At least 50% of available beverage choices contain ≤40 calories per 8 fluid ouncesc (excluding 100% juice, fortified soy beverages, and fat-free or low-fat [1%] milk with no added sugars).

(Standard)

This standard is updated from the 2011 HHS/GSA Guidelines1 to more clearly quantify the serving size and clarify exclusions.

The standard limits beverages with added sugars. In the 2015– 2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to “consume less than 10 percent of calories per day from added sugar.”2 The 2015–2020 Dietary Guidelines also states that strategies for people to reduce their added sugar intake include choosing beverages with no added sugars, such as water, in place of sugar-sweetened beverages; reducing portions of sugar-sweetened beverages; drinking these beverages less often; and selecting beverages low in added sugars. Low-fat or fat-free milk, fortified soy beverages, or 100% fruit or vegetable juice contain important nutrients in addition to calories and can be consumed within recommended amounts in place of sugar-sweetened beverages.2

An Ancillary Report of the Food Service Guidelines for Federal Facilities 19

(Implementation Levela) Rationales

Beverages (continued)

At least 75% of available beverage choices contain ≤40 calories per 8 fluid ouncesc (excluding 100% juice, fortified soy beverages, and fat-free or low-fat [1%] milk with no added sugar).

(Innovative)

This standard is updated from the 2011 HHS/GSA Guidelines1 to more clearly quantify the serving size and clarify exclusions.

The standard limits beverages with added sugars. In the 2015– 2020 Dietary Guidelines, a Key Recommendation for a healthy eating pattern is to include less than 10% of calories per day from added sugars.2 The 2015–2020 Dietary Guidelines also states that strategies for individuals to reduce their added sugar intake include: choosing beverages with no added sugars, such as water, in place of sugar-sweetened beverages, reducing portions of sugar-sweetened beverages, drinking these beverages less often, and selecting beverages low in added sugars. Low-fat or fat-free milk, fortified soy beverages, or 100% fruit or vegetable juice contain important nutrients in addition to calories and can be consumed within recommended amounts in place of sugar-sweetened beverages.2 a Standard implementation criteria are considered to be widely achievable within food service; implementation at this level is expected. Innovative implementation criteria promote exceptional performance in various areas of food service; implementation at this level is encouraged.

b Vegetable juice contains ≤230 mg sodium per serving.

c Equivalent measures include ≤60 calories per 12 fluid ounces or ≤100 calories per 20 fluid ounces.

Table 6. Standards from the 2011 HHS/GSA Guidelines Not Included as Food and Nutrition Standards in the Food Service Guidelines for Federal Facilitiesa

Standards from the 2011 HHS/GSA Guidelines How Standards Are Addressed in the Food Service Guidelines for Federal Facilities

At least 50% of breakfast cereals contain at least 3 g of fiber and less than 10 g total sugars per serving.

Whole grain cereal is covered by the “whole grain-rich” products standard of the Food Service Guidelines for Federal Facilities.

Offer as a choice a non-dairy, calcium-fortified beverage (such as soy or almond beverage); these beverages must not provide more sugars than milk (thus be 12 g sugar/8 oz serving or less), provide about the same amount of protein (at least 6 g/8 oz), calcium (250 mg/8 oz), and provide less than 5 g total fat (equivalent to 2% milk).b

Soy beverages were added to the dairy beverage standard. Because almond beverages do not meet the nutrient criteria for dairy, they will be subject to guidance in the Beverages category.

If cottage cheese items are offered, only offer low fat (2% or less) or fat-free items.

All types of fat-free and low-fat (1%) cheese are included in the dairy standard.

Vegetable offerings contain ≤230 mg sodium, as served.

The sodium criterion for vegetables is addressed in the sodium standard for side items. Sodium criteria in the Food Service Guidelines for Federal Facilities were established for meals, entrees, or sides rather than for individual food groups, as in the 2011 HHS/GSA Guidelines. These criteria are consistent with current public health initiatives for sodium reduction and are appropriate for feasibility of implementation.

An Ancillary Report of the Food Service Guidelines for Federal Facilities20

Standards from the 2011 HHS/GSA Guidelines How Standards Are Addressed in the Food Service Guidelines for…