WASHINGTON — Grain millers support Buy American provisions in school meals programs but hope to impress on the federal government the importance of exceptions to ensure US students have access to healthy foods.
Situations ideal for such exceptions, including the sourcing of oats and wheat flour, were outlined this month in a North American Millers’ Association letter to the School Meals Monitoring Branch of the US Department of Agriculture’s Child Nutrition Programs. NAMA President Jane DeMarchi penned the letter on behalf of US millers in response to a request for information from USDA’s Food Nutrition Service in the Aug. 4 Federal Register. The request sought stakeholder feedback on implementation of the Buy American provision, suggestions for potential changes to regulations and guidance, and solutions for better support of local operators sourcing domestic foods and food products.
“As the link between producers and final products, our members are keen to provide thoughts on how Buy American provisions affect the National School Lunch Program (NSLP) and School Breakfast Program (SBP). Specifically, millers would like to share the nuanced challenges that would arise from a change in how the programs currently operate,” the letter said.
Under the current system, school food authorities follow federal procurement and program regulations, including Buy American, in order to claim federal reimbursement for meals served. Buy American provisions require schools in the continental US to purchase domestic agricultural commodities and food products. Unprocessed agricultural commodities must be domestic and processed foods must be manufactured domestically using domestic agricultural food components comprising more than 51% domestically grown items, by weight or volume. A domestic creditable food component is the portion that counts toward a reimbursable school meal in the categories of meats/meat alternates, grains, vegetables, fruits, and fluid milk.
Exceptions to the provision are allowed when a food or food product is not produced or manufactured in the United States in sufficient and reasonably available quantities of a satisfactory quality or competitive bids determine nondomestic product is significantly lower than an equivalent food or food product produced in the United States.
“These Buy American exceptions in the NSLP and SBP allow for real-world flexibilities that reflect the reality that US grain millers face while delivering highly nutritious foods to American consumers,” Ms. DeMarchi said in the letter. “Because of the unique issues faced by US millers, it is vital that these exceptions remain in place.
NAMA’s communiqué explained that more than 90% of US- milled oats are grown in Canada following a multiyear decline in US oat acres as US producers shifted to growing corn, soybeans, and other commodities. Flour millers rely on Canadian wheat to supply specific varieties to provide attributes required by bakers that “may not be available in the US market due to many factors, including weather, farm policy, or specific issues from the farmer. This cross-border trade is fluid throughout the year and would be difficult to capture in a snapshot of one specific food product.”
To meet consumer demand and keep costs low, US millers, particularly in northern US border states, frequently source oats from Canada and often sustain grind for specific flours with Canadian wheat just as Canadian millers do with US supplies. NAMA’s letter called for maintaining consistent application of current rules to meet US consumer demand and ensure oat-based products such as cereals, oatmeal, and breakfast bars remain a foundational component of the school meal programs. NAMA also pointed out discrepancies in the measurement of water content in final food products could make products ineligible if the current flexibilities were modified or eliminated.
Finally, NAMA’s letter touched on the massive labor and transportation shortages disrupting the US supply chain and the resultant increased costs of production and prices at retail. The association said trucks, rail cars, barges, and ocean vessels should all be options for grain shippers, and high transportation costs should be taken into account when determining Buy American exceptions.
“Inclusion of grains in the diet of children is important as we as a nation provide more grain-based solutions to customers and consumers,” NAMA’s letter said. “The option of transportation and origin of grain should not be an obstacle to that goal. It is necessary for the administration to continue to take such costs into account when determining if a product, while available domestically, must be imported due to prohibitive domestic transportation costs and should be allowed as an exception to Buy American rules.”