National Research Center
for Women & Families

November 3, 2006

Patricia N. Daniels
Director
Supplemental Food Programs Division
Food and Nutrition Service, U.S. Department of Agriculture
3101 Park Center Drive, Room 528
Alexandria, VA 22302

RE: Docket ID Number 0584-AD77, WIC Food Packages Rule

Dear Ms. Daniels:

The National Research Center for Women & Families strongly supports the WIC Food Packages Proposed Rule. A healthful diet is a family responsibility, but WIC policies are essential in encouraging the best possible nutrition for low-income families, and a healthy start for young children.

We applaud the U.S. Department of Agriculture (USDA) for working to update and strengthen the WIC food packages to better align them with the Dietary Guidelines for Americans 2005¹ and the American Academy of Pediatrics' infant feeding recommendations and to better address current nutritional concerns for WIC participants. As USDA finalizes the regulations, we strongly urge you to strengthen the final rule in the following areas:

Fruits and Vegetables. A vital improvement proposed for the WIC food packages is the addition of more fruits and vegetables, including the addition of fruits and vegetables for infants between the ages of six and eleven months. We strongly encourage USDA to follow the recommendations listed in the Institute of Medicine (IOM) report, WIC Food Packages: Time for a Change, and to provide WIC mothers and children with the full cash value voucher amount ($10/month and $8/month) for fruits and vegetables.

Most Americans, including WIC families, consume less then half of the fruits and vegetables recommended in the Dietary Guidelines. Given the health benefits of increasing fruit and vegetable consumption, this vulnerable population should be given the full benefit recommended by the IOM. The IOM estimated that the $10/month and $8/month vouchers would help mothers and children obtain at least one additional serving of fruits or vegetables each day.

Also, we recommend that the final rule require that the value of the fruit and vegetable benefit regularly receive cost of living adjustments (COLA); the COLA should not be optional. Without a COLA, the vouchers will buy fewer fruits and vegetables over time, resulting in participants receiving fewer fruits and vegetables than recommended by IOM.

We support allowing fruit and vegetable vouchers to be used to buy fresh, canned, frozen, and dried fruits and vegetables to provide maximum choice and variety for WIC participants.

In addition, we recommend limiting sodium in canned or frozen vegetables to no more than 480 mg per serving (the disqualifying level for the Food and Drug Administration's [FDA] "healthy" claim). Though canned vegetables contribute relatively little to Americans' sodium intake,² limiting sodium consumption is an important recommendation in the Dietary Guidelines.

We support the restrictions on added sugars, starches, or salt in infant food in the proposed rule.

We urge that WIC state agencies require small vendors to provide more than just two varieties each of fruits and vegetables. Each vendor should be required to carry a wide selection of fruits and vegetables. This would have the potential to increase participants' access to fruits and vegetables. For example, in the Calaveras County WIC Fruit and Vegetable Project, "Mom-and-Pop" stores increased the variety of fruits and vegetables available for sale as a result of the WIC fruit and vegetable voucher.

Juice. We strongly support the proposed elimination of fruit juice for infants and decreases in the quantity of juice for children and women in the food packages. We share pediatricians' concerns about over-consumption of fruit juice by infants and young children.³

Whole grains. We strongly support the emphasis on whole grains in the revised food packages. Those changes will help WIC participants consume more whole grains as recommended by the Dietary Guidelines.

We recommend that USDA replace its proposed definition of whole grains with the definition from the HealthierUS School Challenge. We recommend that whole grain WIC cereals and bread meet at least one of the following standards:

Consumption of whole grains is associated with lower risk of type 2 diabetes,⁴ coronary heart disease,⁵ ischemic stroke,⁶ and weight gain. ^7,8 Whole grd manganese that may help to prevent disease. Unfortunately, on average, low-income individuals consume 40% less whole ains contain fiber, antioxidants, and the components of antioxidant enzymes such as selenium, copper, angrain foods than individuals with high socio-economic status.⁹

We support allowing soft corn or whole wheat tortillas as an alternative to whole grain bread. However allowing only tortillas with no added fat or oils is too restrictive. We recommend allowing tortillas that are low in saturated fat and contain less than 0.5 g trans fat per serving.

Also, we support retaining the proposed limit on sugars in WIC cereals. Even with USDA's proposed limit on sugars and the definition for whole grains proposed above, there will be plenty of cereal options available to WIC participants. In October 2006, one large grocery store (Safeway) in Washington, D.C. had 95 cereals for sale that met both the whole grains definition above and USDA's proposed limit on sugars. Those criteria also will provide an incentive for companies to introduce new products and reformulate existing products, which would make it easier for WIC participants to increase their intake of whole grains and decrease their intake of sugars, as recommended in the Dietary Guidelines.

Milk. We strongly support the proposed rule bringing the quantity of milk in the WIC food packages in line with the Dietary Guidelines. It has not made sense for the WIC food packages to provide more milk than is recommended. In addition, we support the removal of whole milk from the food packages for children ages 2 to 4 years (some recipients of Food Package IV) and women (Food Packages V, VI, and VII).

Cheese. To help WIC participants limit their saturated fat intake, we urge USDA to require all cheese offered in the food packages to be light, reduced, or low in fat to be consistent with the recommendation in the Dietary Guidelines to select milk products that are low fat or fat free. Cheese is the leading source of saturated fat in the diets of American adults¹⁰ and the second largest source in children's diets.¹¹

Dairy substitutes. We support the proposed rule regarding allowing soy-based beverages and calcium-set tofu as substitutes for milk in Food Package IV, V, VI, and VII. However, we recommend that USDA remove the medical documentation requirement for children to receive soy beverages in Package IV. The medical documentation requirement unnecessarily restricts access to these dietary options, especially for low-income families who have limited access to medical care. In addition, medical documentation is irrelevant for women who prefer not to have their child consume dairy products for cultural, religious, or other non-medical reasons. By allowing children better access to calcium-fortified soy products as a substitute for milk, the USDA could help to ensure adequate calcium intake during formative years for children with milk allergies or cultural or religious preferences.

In addition, we recommend that USDA establish an alternative minimum nutrient standard for soy beverages. Currently, there are no calcium-fortified soy beverages in the marketplace that meet the proposed nutrient standard of 8 grams of protein and 349 milligrams of potassium per 8-ounce serving. We recommend that USDA follow FDA and industry standards for protein (6.25 grams per 8-ounce serving) and potassium (250 milligrams per serving) for calcium-fortified soy beverages. Since protein is no longer a priority nutrient for WIC and the addition of fruits and vegetables contribute to the food packages' potassium content, these adjusted specifications should not negatively affect the nutritional status of participants.

Also, we recommend that USDA clarify that, for tofu, there is no limit on naturally occurring fat. The type of fat that is found naturally in tofu is heart-healthy.

Eggs. We strongly support the proposed rule on reducing the quantity of eggs in the WIC food packages to bring them in line with the recommendations in the Dietary Guidelines for decreasing cholesterol and saturated fat intake. Eggs are the single largest source of cholesterol in the diets of both adults¹² and children.¹³ In addition, reducing the quantity of eggs in the food packages makes sense since protein is no longer a nutrient of concern for WIC participants.

Breastfeeding. We strongly support USDA's proposed revisions to the WIC food packages to provide greater incentive for breastfeeding. According to the USDA, breastfeeding is associated with decreased incidence of lower respiratory infection, otitis media, diarrhea, bacterial meningitis, necrotizing enterocolitis, and urinary tract infection and it may enhance cognitive development.¹⁴ In addition, higher breastfeeding rates among WIC participants would decrease the costs of providing infant formula through the WIC Program.

Cultural and taste preferences. We support the proposed inclusion of a greater variety of options throughout the food packages to promote greater acceptability of WIC foods by participants. As mentioned above, we support allowing the substitution of whole grain tortillas for bread and calcium-fortified soy beverages or tofu for milk. We also support the option of substituting canned beans for dry beans in Food Packages III, IV, V, VI and VII and canned salmon or sardines for light tuna in Food Package VII.

Overall, we strongly support USDA's proposed rule for updating the WIC food packages. The proposed changes will better support WIC participants' efforts to eat healthfully and comply with the Dietary Guidelines. We urge USDA to publish the final rule promptly, by spring 2007 at the latest, to bring these improvements to WIC participants as soon as possible.

Sincerely,

Diana Zuckerman, PhD
President
The National Research Center for Women & Families

[1] U.S. Department of Health and Human Services and U.S. Department of Agriculture. Dietary Guidelines for Americans, 2005. 6th Edition, Washington, D.C.: U.S. Government Printing Office, January, 2005.

[2] Cotton P, Subar A, Friday J, Cook A. "Dietary Sources of Nutrients among U.S. Adults, 1994-1996." Journal of the American Dietetic Association 2004, vol. 104, pp. 921-930.

[3] Committee on Nutrition, American Academy of Pediatrics. "The Use and Misuse of Fruit Juice in Pediatrics." Pediatrics 2001, vol. 107, pp. 1210-1213.

[4] Fung T, Hu F, Pereira M, Liu S, Stampfer M, Colditz G, and Willett W. "Whole-Grain Intake and the Risk of Type 2 Diabetes: a Prospective Study in Men." American Journal of Clinical Nutrition 2002, vol. 76, pp. 535-540.

[5] Liu S, Stampfer M, Hu F, Giovannucci E, Rimm E, Manson J, Hennekens C, and Willett W. "Whole-Grain Consumption and Risk of Coronary Heart Disease: Results from the Nurses' Health Study." American Journal of Clinical Nutrition 1999, vol. 70, pp. 412-19.

[6] Liu S, Manson J, Stampfer M, Rexrode K, Hu F, Rimm E, and Willett W. "Whole Grain Consumption and Risk of Ischemic Stroke in Women." Journal of the American Medical Association 2000, vol. 284, pp. 1534-1540.

[7] Ludwig D, Pereira M, Kroenke C, Hilner J, Van Horn L, Slattery M, and Jacobs D. "Dietary Fiber, Weight Gain, and Cardiovascular Disease Risk Factors in Young Adults." Journal of the American Medical Association 1999, vol. 282, pp. 1539-1546.

[8] Liu S, Willett W, Manson J, Hu F, Rosner B, and Colditz G. "Relation between Changes in Intakes of Dietary Fiber and Grain Products and Changes in Weight and Development of Obesity among Middle-Aged Women." The American Journal of Clinical Nutrition 2003, vol. 78, pp. 920-927.

[9] Putnam J, Allshouse J, and Kantor L. "U.S. per Capita Food Supply Trends: More Calories, Refined Carbohydrates, and Fats." FoodReview 2002, vol. 25, pp. 2-15.

[10] Subar A, Krebs-Smith S, Cook A, Kahle L. "Dietary Sources of Nutrients among U.S. Adults, 1989 to 1991." Journal of the American Dietetic Association 1998, vol. 98, pp. 537-547.

[11] Subar A, Krebs-Smith S, Cook A, Kahle L. "Dietary Sources of Nutrients among U.S. Children, 1989-1991." Pediatrics 1998, vol. 102, pp. 913-923.

[12] Subar A, Krebs-Smith S, Cook A, Kahle L. "Dietary Sources of Nutrients among U.S. Adults, 1989 to 1991." Journal of the American Dietetic Association 1998, vol. 98, pp. 537-547.

[13] Subar A, Krebs-Smith S, Cook A, Kahle L. "Dietary Sources of Nutrients among U.S. Children, 1989-1991." Pediatrics 1998, vol. 102, pp. 913-923.

[14] Weiner J. Food and Rural Economics Division, Economic Research Service, USDA. The Economic Benefits of Breastfeeding: A Review and Analysis. Washington, D.C.: USDA, 2001.