January 7, 2003
Dr. Peter Murano, Associate Deputy Administrator
Special Nutrition Program
USDA Food and Nutrition Service
3101 Park Center Dr., Rm. 510
Alexandria, VA 22302
Dear Dr. Murano:
The Soyfoods Association of North America (SANA) appreciates USDA’s efforts to help
American children consume a healthful diet. USDA plays a vital role in steering the nation toward nutritious federal food assistance programs and effective nutrition education outreach programs. SANA commends USDA for acknowledging the cultural diversity in America’s food choices and presenting soy foods as good sources of several key nutrients in the Dietary Guidelines for Americans and the Food Guide Pyramid for Young Children.
Removing the 30% limitation on soy protein in child nutrition programs has provided children with access to many more low fat, high protein soy/meat blended products and meat alternatives. SANA encourages USDA to continue the commitment to improving the nutritional intake of all children and accommodating their cultural differences. We urge USDA to approve fortified soymilk (soy milk) as part of the WIC food package and to allow fortified soymilk to be served and credited in the child nutrition programs for participants who desire another choice besides fluid milk. In addition, we ask that USDA establish nutritional standards for soymilk (soy milk) served through Child Nutrition Programs.
It is important to note that most soymilk (soy milk) consumers chose products for a variety of reasons, including medical, religious, and ethnic. These consumers add fortified soymilk (soy milk) to a diet that does not otherwise contain fluid milk or other dairy products. Some children participating in USDA nutrition programs do not consume the milk provided with meals because they cannot tolerate lactose, are allergic to bovine protein, or avoid animal products. Children with persistent lactose intolerance are unlikely to drink milk served with their meals because they want to avoid the abdominal discomfort. For these children, including soymilk (soy milk) as part of a reimbursable school or child care meal would provide high-quality protein, wellabsorbed calcium and other key vitamins lacking due to avoidance of fluid milk.
To assure consistency, SANA recommends that USDA set nutritional standards for soymilk served in USDA Child Nutrition programs. Our recommendations, based on nutritional needs of program recipients, include:
Protein – 7 grams per 8 ounce serving, a level for soymilk (soy milk) established in the “Voluntary Standards for Composition and Labeling of Soymilk in the United States,” submitted to FDA by SANA in 1997. This level was established based on the natural protein content of the soybean and is consistent with the 1999 FDA approved Health Claim for soy proteins.
Vitamin A & Vitamin D – Fortification levels as required for fluid milk in FDA regulations (100 IU per 8 ounce serving (400 IU per quart) for vitamin D and 500 IUper 8 ounce serving (2000 IU per quart) for vitamin A.
Calcium – Fortification levels similar to fluid milk of 300 per 8 ounce serving (1200 mg per quart).
Establishing these nutrition standards for soymilk (soy milk) served in USDA child nutrition programs will assure that program participants have access to a non-dairy beverage that provides high quality protein, calcium and key vitamins.
Soy has played an important role in improving the nutritional status of many Americans.
Making soymilk a part of a reimbursable meal for children not drinking fluid milk will contribute to a healthful diet for these children, as presented in the Dietary Guidelines for Americans and the Food Guide Pyramid for Young Children. Soybean farmers, soy processors, and soy food manufacturers are committed to improving the health of American children and SANA looks forward to working with USDA to meet the nutritional needs of all children participating in the Child Nutrition and WIC programs.
American Soybean Association
Soyfoods Association of North America
Archer Daniel Midland
Sunrich Food Group
Central Soya Company, Inc
DuPont Protein Technologies
The Whole Soy Company
Galaxy Nutritional Foods Co/Soyco
Hain Celestial Group
White Wave, Inc./Dean Foods
Steuben Foods, Inc.
Wildwood Harvest Foods, Inc.