Identifying and Analyzing the Barriers to Serving Plant-Based Meat in the National School Lunch Program

Lauren Stone Chatham University Masters in Food Studies Master Thesis August 6, 2019

Table of Contents

1. Introduction 2. Literature Review a. The Problems with Industrial Meat i. Environmental Degradation ii. Foodborne Illness & Antibiotic Use iii. Animal Welfare iv. Human Health b. Alternatives to Industrial Meat i. Grass-Fed/ Pastured-Raised Meat ii. Cell-Based Meat iii. Vegetarian/Vegan Whole Foods iv. Plant-Based Meat c. The National School Lunch Program i. A Brief History ii. Price iii. Regulations 1. Meat/Meat Alternate 2. APP 3. CN Label/Product Formulation Sheet 4. Protein Digestibility Corrected Amino Acid Score iv. Distribution v. Nutrition 3. Methods a. List of Interviews 4. Results a. Price b. Regulations c. Distribution d. Nutrition e. Taste/Acceptance 5. Discussion a. Price b. Regulations c. Distribution d. Nutrition e. Taste/Acceptance f. Suggestions 6. Conclusion 7. References

1 Introduction

Research has identified numerous problems with industrial meat production. They include ​ environmental degradation, antibiotic resistance, viral outbreaks, animal abuse, and human health problems. While intra-industry change is needed, wholesale and direct consumers can also help mitigate these problems by changing their buying habits.

There are several different ways for consumers to address these issues: cutting out animal products altogether in favor of a whole foods plant based diet, eating grass-fed or pasture-raised meat, eating meat grown from cells of animals in a bioreactor (“cell-based meat”) or eating products made out of plants that imitate meat (“plant-based meat” or PBM). Each of these four solutions has its own drawbacks and advantages, and thus it is likely that none is uniquely capable of replacing industrial meat or effectively addressing all the issues associated with industrial meat production. However, all together they will provide consumers with more options that do not rely on harmful industrial practices. The focus of my research is on plant-based meat in particular.

In order to produce plant-based meat, scientists are studying the molecular structure of meat and developing new ingredients derived from plants that mimic it in taste and texture (Lagally,

2017). It is a unique alternative to conventional meat, as it acts “as the meaty, center of the plate entrée,” thus appealing to meat-eaters as well as vegans and vegetarians (Lagally, 2017).

2 The plant-based meat market has grown rapidly during the past decade. According to new data published by the Plant Based Foods Association, “U.S. retail sales of plant-based foods have grown 11 percent in the past year, bringing the total plant-based market value to $4.5 billion”

(Simon, 2019). Many companies are already making PBM, and a wide range of meat-mimicking products are on the market, including the Impossible Burger (which uses the iron-containing heme compound to create a meaty texture and taste), Gardein Chicken tenders, Tofurky deli slices, and Beyond Meat sausage, to name a few.

Though plant-based meat has the potential to reduce traditional meat consumption, the Good

Food Institute’s “Plant Based Meat Mind Map” says that it currently only commands “less than one-quarter of one percent of meat sales in the U.S.” However, it also states that “merely bringing plant-based meat to 10 percent of the market share would create a $20 billion market in the U.S. alone, and it would have significant positive impact on our climate, food sustainability, and global health” (Lagally, 2017).

A viable way to increase market share is by focusing on food service. While many plant-based meat companies have products in a wide range of grocery stores and restaurants, including

Burger King, Safeway, and Dunkin Donuts, few are serving their products in food service capacities. American jails, universities, schools, and hospitals together provide billions of meals every year, many of which include (or even mandate) meat. Schools in particular deserve attention since the National School Lunch Program (NSLP) and the School Breakfast Program alone support more than seven billion meals a year (Poppendieck, 2010). If plant-based meat

3 replaced or supplemented lunch meat, it would not only gain market share, but with comparable or superior taste, price, and nutrition, PBM could also introduce and accustom young generations to plant-based eating at an early age.

While serving plant-based meat in schools has many potential benefits, there are numerous social, regulatory, and practical barriers. Plant-based meat companies must have competitive tastes and price not only compared with conventional meat but also with other alternatives in order to appeal to school food purchasers, students, and parents. Additionally, PBM must meet nutritional and food safety requirements laid out by the USDA.

The objective of my research is to understand the barriers to serving plant-based meat in

American schools by investigating the nutritional standards and requirements of the NSLP, identifying plant-based meats currently served in schools, and collecting the opinions of various stakeholders and experts interested in this issue. I use this data to compile a broad analysis of opportunities for and barriers to serving plant-based meat in schools and potential solutions to each one.

I anticipate my findings will primarily be useful to plant-based companies in general as they attempt to serve food in schools as well as school food buyers interested in providing alternatives to conventional meat and the general population interested in these issues.

4

Literature Review

The Problems with Industrial Meat

In 2016, 8.9 billion chickens, 245 million turkeys, 118 million pigs, and 31 million cows were slaughtered in the United States. Estimates suggest that of these, 99.9% of chickens raised for meat, 99% of turkeys, 95% of pigs, and 78% of cattle come from the system of factory farms

(Fauntalytics, n.d.). Moreover, global demand for meat is predicted to increase more than 70% in the next 30 years (McLeod, 2011). The wide-ranging problems with this conventional meat production system have been written about extensively; they include environmental degradation, animal abuse, antibiotic use, viral outbreaks, and human health problems. Understanding the scope of each of these is important for understanding the need for alternatives.

Environmental Degradation While the exact figures are contested, there is no question that ​ industrial meat production creates a number of adverse environmental impacts. The Food and

Agriculture Organization of the United Nations (FAO) estimates that with “emissions estimated at 7.1 gigatonnes CO2 -eq per annum, representing 14.5 percent of human-induced GHG emissions, the livestock sector plays an important role in climate change” (Gerber et al, 2013).

Greenhouse gas emissions from the livestock industry can be broken down as follows: 44% of livestock emissions are in the form of methane from the gas of confined animals and confinement operations’ manure lagoons (3.1 gigatonnes per year globally), 29% nitrous oxide, largely from synthetic fertilizers used for growing feed crops (2 gigatonnes per year), and 27%

5 carbon dioxide, from the actions associated with feed crop production, including cutting down trees to clear land, planting, harvesting, and transporting feed crops, the automated equipment for feeding, lighting, waste disposal, and temperature control in confinement buildings (2 gigatonnes per year) (Gerber, 2013; Kim et al., 2015). Cattle are the species responsible for the most emissions, contributing to 65% of livestock sector emissions (Gerber, 2013).

Additionally, research shows 23% of the planet’s fresh water is devoted to livestock and their feed crops. In 2016, 38.4% of corn production in the United States went to animal feed, the majority of which went to poultry and beef cows (“World of Corn,” 2017). It takes 147 gallons of water to produce one pound of corn (Water Footprint Network, 2019). Additional water is required to hydrate animals, and even more is needed in the processing and cleaning of feedlots and slaughterhouses. For instance, Cargill’s slaughter and packing facility in Wyalusing, PA processes approximately 2,000 head of cattle daily and uses 200 gallons of water per cow, for a total of 400,000 gallons of water per day, five days per week (Aretta Stroud, personal communication, March 26, 2019). While some of this water is almost certainly recycled, cleaned, and re-used, this is nevertheless only one of five Cargill plants in the U.S., and Cargill is only one of many companies producing beef (Aretta Stroud, personal communication, March 26,

2019). Research suggests that it takes on average about 1,800 gallons of water to produce one pound of meat (Water Footprint Network, 2019). Meanwhile, the World Health Organization found that at least 2 billion people globally lack access to an uncontaminated drinking souce and that by the year 2025, half of the world’s population will be living in a water-stressed area

(“Drinking Water Key Facts,” 2019). While steps can be taken to improve water sanitation and

6 infrastructure, reducing meat and feed crop production has the potential to conserve billions of gallons of water per year.

Moreover, studies show that 9.9 million acres of forests are destroyed annually to make room for feed crops. Between 2006 and 2011, 1.3 million acres were converted to corn and soy fields in the U.S. alone, leading to the loss of diverse animal and plant life (Foley, 2013). Herbicide and pesticide use also kill insects and their food sources; for instance, herbicides have damaged milkweed plants, causing a mass decline in the population of monarch butterflies (Sherwood,

2013). Destruction of forests also leads to loss of rainwater and can disrupt rainfall patterns.

According to the World Wildlife Fund, roughly 17% of the Amazon has been destroyed in the ​ last 50 years, largely due to forest conversion for cattle ranching and feed crops (“Deforestation and Forest Degradation,” n.d.). The mass production of feed crops like corn and soy also ​ contributes to soil degradation and erosion from tilling and monocropping. Approximately

800,000 tons of synthetic fertilizer are used annually for corn and soy production (Marcotty,

2017). Excess nitrogen from synthetic fertilizer leeches into waterways, contaminating water sources. When the nitrate from corn and soy fields reaches the ocean where the contaminated plainland rivers let out, it causes massive algal blooms which deprive all other aquatic life of oxygen, creating “dead zones” (Royte, 2017). The dead zone in the Gulf of Mexico in 2017 was estimated to be more than 8,700 miles wide, approximately the size of New Jersey (Smith,

2017).

7 Due to the wide-ranging environmental impacts of livestock and animal feed industries, the

U.N. urges that “in the absence of major corrective measures, the environmental impact of livestock production will worsen dramatically” (Livestock’s Long Shadow, 2006). Others warn that “if global trends in meat and dairy intake continue, global mean temperature rise will more than likely exceed 2° C, even with dramatic emissions reductions across non agricultural - sectors” (Kim et al., 2015). Studies suggest that reducing animal product intake would have significant positive impact on GHG emissions and land use and also reduce water consumption and pollution (Ranganathan et al., 2016).

Many of the environmental problems associated with industrial meat production come from feed crop production. While consuming less industrially-produced meat can mitigate these effects, organizations like Forum for the Future are also attempting to address these issues by researching new animal feed production methods, by scaling up more sustainable feed ingredients like algae or insects, or using food production by-products as animal feed (Forum for the Future, n.d.).

Foodborne Illness & Antibiotic Use A Center for Disease Control and Prevention study ​ ​ attributing foodborne illness outbreaks to food commodities from 1998 to 2008 found that 4.9 million illnesses in the United States were attributed to plant commodities, 4 million to land animal commodities, and 600,000 to aquatic animal commodities. While produce accounted for a greater percentage of these illnesses than meat , more hospitalizations and deaths were attributable to meat from land animals (Painter et al., 2013). Moreover, the foodborne illness cases in plants are attributed to supply-chain failures, which could happen at any point in the

8 harvesting and packaging but can often be traced back to water streams contaminated by livestock fecal matter (Shogren, 2018).

Prior to 2017, subtherapeutic doses of antibiotics were administered liberally to animals to promote growth. One report estimated that 80% of all antibiotics in the U.S. were used as feed additives for livestock. In 2011, 30 million pounds of antibiotics were sold for use in livestock

(Food and Agriculture Organization of the United Nations, 2011). Therapeutic doses of antibiotics are also administered in confinement operations to treat or prevent illnesses. More than half of these drugs are classified as “medically important” for treating humans (Landers et al., 2012).

With this standard and consistent antibiotic use, more and more bacteria are becoming drug-resistant. These bacteria can spread to humans through the consumption of meat or produce that has been contaminated by livestock bacteria, which in turn cause infections in humans.

According to the Centers for Disease Control and Prevention, “Salmonella and Campylobacter, ​ ​ ​ ​ two of the many bacteria commonly transmitted through food, cause an estimated 410,000 antibiotic-resistant infections in the United States each year.” Two million people contract ​ resistant infections annually and 23,000 die from them, and roughly 20% of drug-resistant infections are caused by germs from food and animals (Antibiotic Resistance from the Farm to the Table, CDC, 2017).

9 A study funded by the British government projects that “if policies are not put in place to slow the rise of drug resistance, 10 million people could die worldwide of all such infections in 2050, eclipsing the eight million expected to die that year from cancer” (Richtel & Jacobs, 2019). The

United Nations states that “high levels of antimicrobial resistance already seen in the world today are the result of overuse and misuse of antibiotics and other antimicrobials in humans, animals

(including farmed fish), and crops,” adding that “resistance to antibiotics is considered the greatest and most urgent global risk requiring international and national attention” (“At UN, global leaders commit to act on antimicrobial resistance,” 2016).

Due to these concerns, medically important drugs used for growth promotion or feed efficiency in the U.S. were banned in 2017, and therapeutic use is now required under veterinary oversight

(The Facts About Antibiotics in Livestock & Poultry Production, 2017). However, enforcement ​ ​ ​ ​ of these policies remains an issue. Plant-based meat does not contain antibiotics given to animals and can therefore play a part in reducing irresponsible antibiotic use globally.

Animal Welfare In addition, conventionally-produced meat is the cause of extensive animal ​ cruelty. In 1979, the Five Freedoms of animal welfare framework was developed by Dr. John

Webster and defined as: freedom from thirst, hunger and malnutrition, freedom from discomfort, freedom from pain, injury and disease, freedom to express normal behavior, and freedom from fear and distress (Gill, 2015). Numerous undercover investigations carried out by animal welfare groups, like Mercy for Animals, have produced footage revealing that many factory farms fail to provide these freedoms to the billions of animals kept in them. Undercover footage has revealed

10 violence and cruelty against animals in confinement operations, with widespread injuries, fear and disease (Runkle, 2017). Several states have passed laws that aim to improve animal welfare in these large operations, by eliminating or phasing out the use of extreme animal confinement structures, like battery cages for laying hens, gestation crates for sows, and veal crates for young calves (ASPCA, 2018). Other measures to prevent cruelty, like the Humane Methods Slaughter

Act, exempt chicken and fish. Despite these reform efforts, however, many operations continue to use these cruel practices. This cruelty is hidden from view, but schools directly support it when they provide factory farmed meat to their students.

Human Health There are several health concerns associated with high intake of protein, ​ ​ specifically of red and processed meat. Many studies have linked red meat and processed meat consumption with chronic diseases such as cardiovascular disease, and type 2 diabetes, as well as certain types of cancer. A 2017 study found that “for the consumption of 50 g/day of processed ​ meat (just over two ounces), the risks were statistically significantly increased for most of the studied diseases: 4% for total prostate cancer, 8% for cancer mortality, 9% for breast, 18% for colorectal and 19% for pancreatic cancer, 13% for stroke, 22% for total mortality and 24% for cardiovascular mortality and 32% for diabetes” (Wolk, 2017). The International Agency for ​ Research on Cancer has classified red meat consumption as “probably carcinogenic to humans… based on strong mechanistic evidence supporting a carcinogenic effect.” Likewise, processed meat (which “refers to meat that has been transformed through salting, curing, fermentation, smoking, or other processes to enhance flavour or improve preservation”) was classified as

“carcinogenic to humans… based on sufficient evidence in humans that the consumption of

11 processed meat causes colorectal cancer” (“Q&A on the carcinogenicity of the consumption of ​ red meat and processed meat,” 2015). In a study of half a million people aged 50-71, men and ​ women who consumed more red and processed meat were found to have elevated risks for overall mortality and cancer mortality, and cardiovascular disease mortality (Sinha et al., 2009).

A further study found a link between consumption of processed meats and higher incidence of ​ coronary heart disease and diabetes (Micha et al., 2010). The American Institute for Cancer ​ Research accordingly advises “eat no more than moderate amounts of red meat and little, if any, processed meat” (“Limit Red and Processed Meat,” n.d.).

Moreover, in the United States, protein consumption in general currently exceeds the dietary requirements, which range from 19g to 46g for females ages 4 - 51+, and 19g to 56 g for males age 4 - 51+ (Dietary Guidelines for Americans 2015-2020). One study found that “US citizens ​ (ages 2 years and over) consume 125.9-166.5 g of total meat per day. Meat constitutes the majority of intake within the Protein Foods Group, and red meat and processed meat constitute the majority of total meat intake. Nutrient supply data indicate that total meat represents an estimated 43.1 % of the total protein available in the US food supply… per capita protein intake is best estimated by dietary recall data to be 79.9 grams per day” (Fehrenbach et al, 2015).

Accordingly, the current United States Dietary Guidelines suggest that males and females ages 4 ​ to 18 lower their overall protein intake and increase their fruit and vegetable intake (Dietary

Guidelines for Americans 2015-2020).

12 Given the urgency of these problems and the growing demand for meat globally, it is clear that alternatives are needed. However, despite this wide range of problems, industrial and processed meats are ubiquitous in school lunches across the country, in the form of hot dogs, chicken nuggets, pepperoni pizzas, hamburgers, and more. The primary advantage that industrial meat production has over alternative forms of meat is its price and availability, which compare favorably to grass-fed and plant-based meat. Because of the large scale at which it is produced, factory-farmed meat is an economically viable option for many schools in particular that are operating on small budgets.

Alternatives to Industrial Meat

There are several alternatives to conventionally produced meat that could supplement or replace the meat currently used in school lunches in order to mitigate its wide-ranging problems. Each has unique advantages and disadvantages and thus it is likely that none are solely capable of replacing conventionally produced meat. However, the severity and urgency of the problem calls for multiple solutions, where different ones are appropriate to different scenarios.

Grass-Fed/Pasture Raised Meat One viable alternative to conventionally produced meat is ​ pastured-raised or grass-fed meat. Grass-fed animal operations involve raising animals on pastures, allowing them to eat grass rather than, or in combination with grain, depending on the animal. Some research suggests that this system of raising animals addresses most of the problems with industrial meat production, including human health, animal welfare, and climate change: the animals eat a more healthful diet of grass and are not confined in small spaces, thus

13 requiring less drug treatment (Cheung, 2017); grass-fed beef has a more favorable omega-6 to omega-3 ratio and higher concentrations of conjugated linoleic acids, which are beneficial nutrients; the risk of bacterial infection or antibiotic resistance is lowered (Daley, 2010); and while cows will emit gas in both industrial and pastured setting, some studies have shown that well-managed regenerative grazing may actually sequester carbon (Teague, et al., 2016).

However, in addition to conflicting climate research, additional drawbacks to grass-fed meat include scale, price, and slaughter. Labeled grass-fed operations beef makes up only 4% of total beef sales in the U.S. (Cheung, 2017). While this market has doubled in retail sales every year since 2012, there are barriers to producing this type of meat at scale. In order to scale up this production, large amounts of land currently used for feed crops would need to be converted to pasture (Cheung, 2017). Moreover, because raising animals on grass takes more time and space, this type of meat is often priced much higher; grass-fed beef commanded a 71% premium over conventional beef in 2016 (Cheung, 2017). Furthermore, unlike conventional meat, grass-fed meat is not subsidized by the USDA (while meat is not a subsidized commodity at all, conventional meat is often considered to be indirectly subsidized, in that cattle are typically fed corn and soybeans, which are subsidized commodities) (Cheung, 2017). While some consumers are able to afford these price points, this may be an impediment for food service operations operating on small budgets. There are also challenges related to distribution. Conventional meat producers often partner with large broadline distributors, whereas grass-fed operations often do not have such networks, which can lead to inefficiencies in the supply chain (Cheung, 2017).

While grass-fed meat may have a useful role in the country and the NSLP, its current high price

14 and high land use present significant challenges for scaling up. Lastly, grass-fed meat still involves the slaughter and consumption of animals. Grass-fed operations would not be a viable option for those who seek to eliminate animal products altogether due to ethics, religious beliefs, or other reasons.

Cell-Based Meat Cell-based meat is meat that is grown in a bioreactor from the cells of animals. ​ The first cell-based beef burger was made in the Netherlands in 2013 and production cost

$325,000. Since then, many startups and university researchers have begun to produce cell-based meat, and many high-profile individuals and companies such as Bill Gates, Richard Branson,

Tyson and Cargill have invested in this technology, causing the price to fall dramatically

(Schwartz, 2015). However, this technology has yet to be scaled up and is still not available commercially. Several anticipatory studies suggest that cell-based meat would have positive impacts on the environment compared to conventional meat. Land use, water use and greenhouse gas emissions are predicted to be lower, although energy use may be greater (Tuomisto, et al.,

Mattick, et al., 2011). Potential challenges to cell-based meat include consumer acceptance of this technology and regulatory or labeling hurdles. At present, this technology is too young to consider for adoption in the National School Lunch Program, but is worth paying attention to as it nears market.

Vegetarian/Vegan Whole Foods A plant-based whole foods diet is also a viable option for ​ mitigating the problems with the meat industry by avoiding animal consumption altogether.

These diets may include a variety of grains, legumes, fruits, vegetables, nuts, and seeds. Dairy

15 foods and eggs are included by vegetarians but not vegans. The Academy of Nutrition and

Dietetics states that well-planned vegetarian diets, including vegan diets, are “healthful, ​ nutritionally adequate, and may provide health benefits for the prevention and treatment of certain diseases… for all stages of the life cycle, including pregnancy, lactation, infancy, childhood, adolescence, older adulthood, and for athletes” (Melina, 2016). Additionally, research ​ shows that plant-based diets also mitigate the effects of climate change since they do not rely on harmful industrial practices of the meat industry (Lacour, et al., 2018, Ranganathan et al., 2016).

Despite the benefits of a plant-based diet, this solution ignores how deeply ingrained meat is in

American culture. Plant-based diets remain fairly unpopular, including among youth. Studies show that between two and six percent of American adults self-identify as vegetarians, numbers that have been consistent since the 1980s (Šimčikas, 2018). That said, while strict vegan or ​ ​ vegetarian diets remain unpopular, growing numbers of consumers are becoming “flexitarians” or reducetarians, seeking to reduce their consumption of animal production without categorically rejecting them (Stahler, 2012). Nonetheless, this relatively narrow reach of vegetarianism and ​ ​ veganism can still be seen as a significant obstacle to the adoption of whole foods plant-based diets and thus has implications for school lunches. Janet Poppendieck speaks to children’s familiarity with food served at school as key to their acceptance of it, suggesting that doing away with certain foods in schools would be an ineffective way to change habits if the habits are formed at home: “the issue is that we have to give kids what they are used to eating. We can’t be the trendsetters and go back to home-cooked food if that’s not what they’re eating at home”

(Poppendieck, 2010, p. 82). It would be hard to expect children in the large percentage of households that make up meat-eaters to independently choose meals that just contain plants.

16 While many schools have moved to include more whole plants on their menus, due to meat’s cultural prevalence, the categorical rejection of all meat or meat-like products in schools is, at least at this point in time, an unrealistic solution on its own.

Plant-Based Meat The PBM market has been growing steadily across all nine U.S. census ​ regions and is currently valued at $4.5 billion (Simon, 2019). Researchers estimate that the meat substitutes market will be valued at $5.96 billion by 2022. Further research shows that 12% of

U.S. households now purchase plant-based meat (Prasannan, 2018). Many large food service ​ ​ establishments and retailers such as White Castle, Burger King, Whole Foods, Kroger’s and

A&W carry PBM.

Plant-based meat products vary widely and include sausage, beef crumbles, chicken strips, chicken nuggets, deli slices, and burgers, to name a few. Their respective nutritional components also vary widely across different products and companies. They can be composed of a wide variety of different plant ingredients or extracts, such as pea, wheat, or soy protein, yeast extract, coconut oil, various seasonings, or potato starch. Plant-based meat differs from some veggie burgers (like Trader Joe’s black bean and roasted corn burger), which are made of recognizable vegetable pieces. While veggie burgers such as these are aimed at replacing the occasion of animal meat, plant-based meat is aimed more specifically at replacing the experience of animal meat.

17 The key players in the PBM market were identified by an Allied Market Research report as

Amy’s Kitchen, Beyond Meat, Cauldron Foods, Garden Protein International, Inc., Meatless ​ B.V., Quorn Foods, Vbites Food, Ltd., Morningstar Farms, MGP Ingredients, and Sonic

Biochem Extractions Limited (Prasannan, 2018). In June 2019, Tyson Foods, one of the largest meat producers in the country, announced a line of plant-based meat products, Raised & Rooted

(Gustafson, 2019). While some of the products in Tyson’s line of plant-based meat contain animal products, such as egg whites, and while others are blended with animal meat, this nonetheless shows intra-industry recognition of this trend.

There are several reasons why PBM should be included in the NSLP including its environmental benefits, nutritional profile, convenience and taste. Research indicates that plant-based meat has a lower environmental impact than animal meat. A life cycle assessment of the second generation Impossible Burger, funded by the Impossible Foods, found that “compared to conventional ground beef, the Impossible Burger reduces environmental impacts across every impact category studied in this report -- 87% less water, 96% less land, 89% fewer GHG emissions, and 92% less aquatic pollutants” (Khan et al, 2019). An independent life cycle assessment of the Beyond Burger, conducted at the University of Michigan, similarly found that based on a comparative assessment of the current Beyond Burger production system with the

2017 beef LCA by Thoma et al, the Beyond Burger generates 90% less greenhouse gas emissions, requires 46% less energy, has >99% less impact on water scarcity and 93% less impact on land use than a ¼ pound of U.S. beef” (Heller & Keoleian, 2018). The Good Food

Institute’s fact sheet entitled, “Plant-Based Meat for a Growing World,” compares the following

18 plant-based meats with their animal-meat counterparts, finding that plant-based beef, chicken, sausage, and more traditional veggie burgers all compare favorably to their animal-meat counterparts in land use, GHG emissions, and water use (“Plant Based Meat for a Growing

World,” 2019).

Plant-based meat also has several nutritional advantages over conventional meat. While missing or incomplete protein is cited as a common worry of plant-based diets, plant-based meat is often higher or equivalent in protein than its animal meat counterpart by weight, including the Beyond

Burger (20g vs 20 g), and Hungry Planet’s burger (22g vs 19g). While animal meat contains all nine essential amino acids, plant proteins vary in their amino acid completeness and in many cases, a variety of plant proteins may be needed in a diet to obtain sufficient levels of each essential amino acid. That said, research indicates that “soy (found in many PBM products), ​

19 brown rice, pea (the Beyond Burger’s source of protein), corn, and potato protein have essential amino acid profiles that meet the requirements as recommended by the WHO/FAO/UNU

(WHO/FAO/UNU Expert Consultation 2007” (Gorissen, 2018). Moreover, the Beyond Burger ​ ​ ​ has less saturated fat than beef and contains no trans fat. Hungry Planet’s burger has less total fat than its beef equivalent and no saturated fat (Davis 2019).

Beyond Meat does not provide all of the minerals that meat does, including zinc and vitamin B12

(Davis, 2019). However, the Beyond Burger does contain fiber and potassium, which are both ​ ​ ​ absent in its beef equivalent. Beyond Burgers provide 30% of daily iron, while a beef burger ​ ​ ​ provides 15%. Given that plant-iron is less absorbable than animal iron, a higher amount of iron in the Beyond Burger is helpful (“Iron,” n.d.). Moreover, plant-based meat does not contain hormones or antibiotics that may be given to animals. Hungry Planet and Beyond Meat are both

GMO-free (while the data on GMO and human health is inconclusive, many schools still seek to eliminate GMO products). Beyond their micro and macro-nutritional compositions, PBM can ​ reduce the risk of foodborne illness, because unlike raw meat, it does not need to be cooked to a particular internal temperature to ensure a lack of pathogens.

Because PBM is made to mimic the taste and texture of meat using plant components, it is a processed food. The danger of processed foods is an active debate, both in academia and popular science. Many processed foods do contain high levels of sugar, trans fats, or sodium, and lack valuable nutrients. However, some research indicates it may be the lack of fiber, rather than the presence of additives in processed foods, that makes them unhealthy (Belluz, 2019). Likewise,

20 there is no strong evidence supporting the claim that a product with fewer ingredients, in and of itself, is inherently healthier than one with more ingredients. The particular process and the particular food likely determine the nutritional and health outcome. There are a plethora of processes that almost all foods undergo before they reach their consumable form (including processes as straightforward as blending) so to categorically reject “processed foods” is fairly meaningless. In response to qualms about Beyond Meat product being so highly processed,

Beyond Meat CEO Ethan Brown has an answer ready: “Well which process do you want, the one that begins with industrial agriculture and ends in a slaughterhouse or one we can walk you through very cleanly?” (Strong, 2017).

While PBM is currently more expensive than conventional meat, prices are expected to fall as volume increases. At present, the current size of most plant-based meat companies limits their ability to negotiate prices for their raw materials. Moreover, many of the raw materials, like soy, are currently optimized for animal feed rather than plant-based meat production. As plant-based meat companies continue to grow, however, they will be able to procure cheaper raw materials that are optimized for their products (Specht, 2019). Production methods will also become more efficient once PBM commands more of the meat market, allowing these companies to produce at larger scales and in turn decrease costs. Meat companies like Tyson, which is entering the plant-based space and which already has vast resources, will be able to produce faster at larger scales (Specht, 2019).

21 Additionally, an analysis by Wild Type, a cell-based meat start up, shows the retail price of beef on an upward trend since 1999, and steadily increasing since 2010, which they attribute to rising costs in the input of meat production, including higher feed, water, and labor costs (“Wild Type food for thought,” 2018).

If this trend continues as the price of plant-based meat falls, then PBM could become cost neutral or cost competitive with conventional meat.

Some plant-based meat companies are already serving their products in schools while others are preparing to. For instance, Lee County, Florida has served Beyond Meat pasta spirals; Santa

Barbara has served a variety of Hungry Planet products (Hamerschlag, 2018) and Don Lee farms is preparing to serve their plant-based chicken nugget in schools beginning in the 2019 school year (Watrous, 2019).

22 Additionally, plant-based meat is recognizable while traditional vegetarian/vegan foods like tofu, lentils, or hummus may not be. In fact, many schools already offer salads and other vegetables that simply don’t get eaten. While some students do have cultural, ethical or religious reasons to abstain from eating meat, most are accustomed to eating meat products. Especially at the elementary school level, school food directors remark that kids seek products that look familiar and are averse to those that don’t. Familiarity with foods can be extremely specific: in

Pittsburgh, a student who was used to eating spaghetti and meat sauce at home would not eat penne and meat sauce at school because he was not used to that pasta shape (M. Hamilton, personal communication, April 12, 2019). Plant-based meat looks and tastes familiar to foods kids already know. In a taste test done in Lee County, Florida, students said that they couldn’t tell Beyond Meat bolognese sauce was not real meat (L. Couchois, personal communication,

April 5, 2019). Furthermore, as PBM broadens its reach to popular restaurant and retail locations, kids may even be familiar with specific PBM products (for instance, the Impossible Whopper is now served at Burger King). As Jody Boyman says of Hungry Planet, “our foods look and taste like what [kids] are used to but without the health and environmental consequences” (J. Boyman, personal communication, April 7, 2019). While some schools have the capacity for education programs to teach children about new plant-based foods such as hummus, lentils, or beans, plant-based meat is a viable option for those that don’t.

Finally, PBM has a high convenience factor and can be swapped one-for-one for processed meats. Many school kitchens have limited cooking capabilities, and the kitchen staff is usually not trained culinarians. The job of school kitchen staff is also hot and busy, and the additional

23 time, knowledge and effort required for cooking whole foods plant-based diets is often infeasible

(K. Watts, personal communication, April 5, 2019). Serving plant-based meat does not require more staff training, new equipment, or any sort of upheaval or overhaul. For schools with limited budgets, unequipped kitchens, and unskilled staff, plant-based meat is a low-effort way to improve nutrition and the environmental sustainability of their menus.

Of the alternatives to meat that do not involve animal consumption, plant-based meat is a fast growing market with relatively high consumer acceptance, low environmental impact, positive nutritional value, precedence in schools, high convenience factor, and feasible scalability with existing agricultural infrastructure. For these reasons, PBM is a promising starting point for the reduced consumption of conventional meat in school lunches. Despite these advantages, however, there are still barriers to serving plant-based meat in schools. In order to further its reach in public schools, stakeholders must understand the history of federal and state regulations and how they can be applied to plant-based meats as the demand for it grows (the process for approval in private schools, who don’t necessarily have to abide by all these same regulatory guidelines, will vary across schools and could be the focus of other research).

The National School Lunch Program

A Brief History Various cities in the United States started serving meals in public schools in the ​ early 20th century, an initiative largely led by social reformists. Subsequently the National

School Lunch Act was officially passed in 1946 (Poppendieck, 2010, p. 51). In these early years of the lunch program, a lot of the food was donated to schools in order to remove depression-era

24 agricultural surplus from the market: “the focus was on using available foods, not on a balanced diet” (Poppendieck, 2010, p. 45).

Just prior to this time, in 1941, the Recommended Daily Allowances (RDA) were published, which specified what quantities of which nutrients were recommended per person per day for a healthy diet. With the passing of the National School Lunch Act, the federal government used the RDAs to help determine which meals would be reimbursable “Type A” meals based on their nutrient content; a Type A reimbursable meal provided one-third to one-half of the RDAs for all required nutrients for children (Poppendieck, 2010). In 1979, Type A meals were exchanged for what is now called “school lunch meal patterns,” which are composed of five elements: fruit, vegetables, grain, milk, and meat/meat alternate. The meal pattern format allows more options within a food group framework while still providing one-third of the RDAs. The “offer vs. serve” (OVS) option, introduced in the 1970s and widely used today, allows students to decline any two of the five elements of the meal pattern without making the meal ineligible for reimbursement (Poppendieck, 2010, p. 119).

While the RDAs focus on specific nutrients, the Dietary Guidelines for Americans (DGAs) were first published in 1980 to provide further advice to Americans on what they should or should not eat as a response to the increasing incidence of obesity and diet-related chronic diseases, such as heart disease and type 2 diabetes. The DGAs encouraged Americans to reduce their consumption of fat, sodium, and cholesterol and increase whole grains, fruits, and vegetables. The 1990 version of the DGAs was expanded to specifically include children over the age of two (History

25 of Dietary Guidelines for Americans, 2018). Accordingly, the School Meals Initiative for

Healthy Children of 1995 required that school meals comply with DGAs as well as providing ⅓ of RDAs, on a daily basis. The School Nutrition Dietary Assessment was formed to assess how closely schools were adhering to DGAs (Poppendieck, 2010, p. 78). The most recent update to the meal pattern requirements was under the 2010 Healthy Hunger-Free Kids Act, the first update in 15 years. The updates include limits on sodium, unhealthy fats and calories, and requirements for more whole grain, fruits, and vegetables (Nutrition Standards in the National

School Lunch and School Breakfast Programs; Final Rule, 2012).

There are several government players involved in the school lunch program. At the federal level,

Congress sets nutrition standards and funding levels for the NSLP and the USDA Food and

Nutrition Service (FNS) implements the program by offering commodities and reimbursing districts. On the local level, School Food Authority (SFA) buys and distributes the food, designs menus, processes student applications, and reports back to FNS for reimbursement. SFAs are comprised of purchasing officers, kitchen staff, dietitians, school food directors, and others.

SFAs are usually at the district level, but can also be comprised of several districts or individual schools (Navigating the National School Lunch Program, n.d.).

Today, the National School Lunch Program is made up of over 100,000 schools and serves lunch to 30 million students per day. In total, 4.9 billion lunches are served annually. The cost to the

US government is about $13.6 billion annually, with 12.2 billion spent on reimbursements and

1.4 billion in commodity costs (School Nutrition Association, n.d.). Navigating the school lunch

26 landscape is not necessarily intuitive, due to its size and complex regulations. Additionally, school food is often also influenced by politics, school funding, influential agricultural groups, convenience, and social norms, which can vary by state, region, or district. The following provides an overview of current costs, regulations, nutrition, and distribution in the NSLP and how each relates to PBM.

Price The NSLP uses a three-tiered pay system: free lunch, reduced price lunch, and full priced ​ lunch. Children from families with incomes below or at 130% of the poverty level ($32,630 for a family of four) receive free meals, while children with families with incomes over 185% of poverty pay full price. In the 2018-2019 school year, the NSLP provided 20 million free lunches,

2 million reduced price lunches, and 8 million full priced lunches. The federal reimbursement rates were $3.31 for free meals, $2.91 for reduced price meals, and $0.31 for full price meals.

While school meal prices vary by district, the average full price lunch for meals in 2016-2017 were $2.48 for elementary school, $2.68 for middle school, and $2.74 for high school. The

USDA School Lunch and Breakfast Cost Study-II breaks this cost down as 37% for food, 48% for ​ labor, 5% for supplies, and 10% for indirect costs. According to the USDA, the new regulations added 10 cents to the cost of preparing each school lunch. The cost to produce a meal still remains higher than the amount of reimbursement in many cases.

The Community Eligibility Program (CEP) “is a non-pricing meal service option for schools and school districts in low-income areas. CEP allows the nation’s highest poverty schools and districts to serve breakfast and lunch at no cost to all enrolled students... CEP are reimbursed

27 using a formula based on the percentage of students categorically eligible for free meals based on their participation in other specific means-tested programs, such as the Supplemental Nutrition

Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF)

(Community Eligibility Website, n.d.). Several districts across the country are CEP districts, including Pittsburgh Public Schools and Lee County, Florida.

There are several ways for CEP and non-CEP school districts to save money or generate additional revenue to cover the cost of school lunches. For instance, USDA Foods (formerly referred to as commodities) are U.S. foods purchased by the USDA and provided to schools at discounted costs, which include both raw and processed foods. Each state’s Distributing Agency administers the USDA Foods program by working with the local School Food Authorities to determine how much and which products to order. USDA Foods account for 15-20% of federal school lunch food expenditures. In school year (SY) 2006/2007, meat made up 35% of USDA foods purchased by states (the largest of any food category).

In addition to the reimbursable NSLP food, many schools often also provide so-called

“competitive foods,” including soft drink vending machines and a la carte food options, such as pizza, soft pretzels, nachos, ice cream, cookies and drinks, in order to generate additional revenue. While unhealthy a la carte foods have been criticized heavily for providing students with a way to circumvent nutrient requirements, some school food directors say that they need revenue from a la carte lines in order to break even (Poppendieck, 2010, p. 41). Thus if most

28 PBM is more expensive than animal meat, it may be difficult for schools to include it on their menus while keeping to their tight budgets.

Regulations The current Meal Pattern Requirements for reimbursable food (not a la carte items) ​ are broken into: fruit, vegetable, grain, milk, and meat/meat alternate, where each of these categories has specific stipulations regarding preparation, variety of foods, and serving size. In addition to meal pattern requirements aimed at adhering to RDAs and DGAs, HHFKA stipulates that the NSLP increase fruit and vegetable offerings, limit sodium and fat, adhere to specified calorie levels, provide reduced fat milk and set whole grain targets (though the Trump administration has rolled back on several of these restrictions, including those regarding flavored and full-fat milk).

The regulations themselves are often lengthy and complex and, with the exception of HHFKA, have not been updated in recent decades. In some places they have not been updated to meet changing nutrition science, but instead reflect the interest of lobbying groups and certain food industries. For instance, the current science makes it clear that with a carefully planned diet, children do not need animal milk, though it is still its own category in the meal pattern requirements (Melina, 2016). Furthermore, certain district impose their own regulations, such as prohibiting common allergens.

Schools do not get reimbursed for items that do not credit toward the meal pattern requirements, so PBM companies must create products that fit into these guidelines if they hope to form

29 contracts with schools. Developing a product that fits into these guidelines can be a difficult process to navigate given the complex and political nature of the regulations. For plant-based meat to be served in schools, it must not only be affordable, but it must also abide by the

HHFKA and fit into the alternative protein product category of the meat/meat alternate component of the meal pattern requirements in order to receive reimbursement.

Meat/Meat Alternate The Meat/Meat alternative for the Lunch Meal pattern is as follows: for ​ ​ grades K - five, 8-10 ounces of meat per week, with a 1 ounce minimum per day. For grades six to eight, 9 - 10 ounces per week with 1 ounce minimum per day. For grades nine to twelve, 10 -

12 ounces per week with 2 ounces minimum per day (Nutrition Standards in the National School

Lunch and School Breakfast Programs, n.d.). Additionally, FNS stipulates that the “the meat/meat alternate component must be served in a main dish or in a main dish and only one other food item. Schools with a daily choice in this component should not serve any one meat alternate or form of meat more than three times in the same week.” The meats/meat alternates are

“grouped based on a collection of nutrients that include protein, B vitamins, selenium, choline, phosphorus, zinc, and copper.”

While many schools do provide vegetarian options, there is no federal requirement for them to do so. In addition to animal meat, there are several meat alternates that can count toward part or all of the meat/meat alternate component of school lunches. They include:

● Yogurt, plain or flavored, sweetened or unsweetened which may be used to meet all or part of the meat/meat alternate component. ● Nuts and seed butters: (excluding acorns, chestnuts, and coconuts) which may be used to meet no more than one half of the meat/meat alternate component: almond butter,

30 cashew nut butter, peanut butter, sesame seed butter, soy nut butter, and sunflower seed butter. ● Legumes: cooked dry beans and peas, such as black beans, black-eyed peas, edamame, garbanzo beans, kidney beans, lentils, navy beans, soybeans, split peas, and white beans. A ¼ cup (4 tablespoons) serving of legumes credits as 1 ounce equivalent of the meat alternate component. Beans and peas can meet all of the requirement of the meat alternate component. ● Tofu and tofu products that are recognizable as meat substitutes, for example, a tofu burger or sausage, and the tofu ingredient must contain at least 5 grams of protein in a 2.2-ounce serving by weight (1/4 cup volume equivalent) to meet the full meat/meat alternate requirement. ● Tempeh: As of April 2019, “program operators now may credit 1 ounce of tempeh as 1 ounce equivalent of meat alternate.” ● Alternative Protein Products- see below.

Alternative Protein Products In addition to the whole foods that fit meal pattern requirements ​ for meat alternates, there is also a category for Alternate Protein Products (APP), where PBM fits in. APPs are processed proteins from soy or other vegetables and may be in the form of dehydrated granules, particles, or flakes. Examples include soy flours, soy concentrates, soy isolates, or whey protein concentrate. APPs can either be used alone or be added to animal meat products, such as beef patties, tuna salad, burgers, or burrito filling. For instance, a veggie burger can contain APP but cannot be considered an APP itself since it has other ingredients like seasonings or breading. APPs can be credited toward the meat alternate component of the meal pattern at a one to one ratio (while fillers like soy concentrate can be used to save money by extending animal meat, PBM that contains soy product is usually more expensive than animal meat as a finished product).

APP regulations found in Appendix A to 7 CFR 210, 220, 225, and 226 (Appendix A) stipulate that the product must be processed so that “some portion of the non-protein constituents of the food is removed.” Other regulations state that:

31 ● The biological quality of the protein in the alternate protein product must be at least 80 percent that of casein (a highly digestible milk protein), determined by performing a Protein Digestibility Corrected Amino Acid Score (PDCAAS, see below). ● The alternate protein product must contain at least 18 percent protein by weight when fully hydrated or formulated, and the manufacturer must provide proof that the products meet the aforementioned criteria. ● The APP must contain 0.5 ounces of equivalent meat alternate per serving and must be produced under federal inspection. ● Recent updates to the Alternate Protein Product removed the limit on how much APP could be used, no longer requires APP to be specially fortified, and updated the test used to determine protein quality (Child Nutrition Labeling for Non-Meat Products, n.d.). ● If the dish does not contain at least ⅛ cup of a recognizable component, then the blended foods do not contribute to the meal requirements. For instance, a soft tofu, pureed into a soup, does not credit because it is not recognizable and does not represent a meat substitute. Therefore, the blended tofu is not creditable (Questions & Answers on the Final Rule, “Nutrition Standards in the National School Lunch and School Breakfast Programs,” n.d.) (the USDA rationalizes this rule by stating that “the nutrition education aspect of the School Meal Programs is important and one of the goals of these Programs is to help children easily recognize the key food groups that contribute to a healthy meal”).

These requirements exist for the stated reason of “providing menu planners with more flexibility to incorporate these products into their menus along with the traditional protein sources of meat, poultry, and seafood” (Requirements for Alternate Protein Products in the National School

Lunch Program and School Breakfast Program, n.d.). While PBM companies use APPs in their animal meat-free products, school food directors often combine them with meat to save on costs.

So in order to serve PBM, it must fit broadly within the protein regulations, more narrowly within the meat alternate regulations, and even more narrowly into the APP regulations. Because of the recent and rapid growth in the PBM space, not all products have formulas that meet the

FNS standards, which have not been updated recently. Thus it is a significant challenge for PBM manufacturers to conform their products to these complex and arguably outdated regulations.

32 CN Label/Product Formulation Sheet In processed alternate protein foods, the nutrients’ ​ ​ contributions to the meat alternate meal pattern requirements are not always obvious. Therefore, the CN label program helps schools determine what and how much a certain purchased product contributes to the meal pattern requirement (Appendix C, CFR, n.d.). A CN label also means that the manufacturer, not the school, is responsible if the school is audited and the food is found to not meet its specified criteria (Lund, 2010). The CN label only applies to items that contribute to the meat or meat alternate component of the meal pattern requirements or juice drinks and juice drink products. Additionally, the CN label process is voluntary for school and food producers.

Once approved, a food item receives a CN label, which states precisely how much the product contributes to the meat requirement: for example, “each 2.3 oz fully cooked roasted chicken provides 2.0 oz equivalent meat for Child Nutrition Meal Pattern requirements” or “each 1.34 oz fully cooked Veggie Breakfast Link provides 1.0 oz equivalent meat alternate for Child Nutrition

Meal Pattern Requirements.” A product with a CN label will include a CN logo, the meal pattern contribution, a unique 6 digit product identification number assigned by FNA, an authorization statement, the month and year of approval, and the product name, inspection legend, ingredient statement, signature line, and net weight. The December 2018 verification report includes all foods with CN labels. The report includes a chart which lists the CN number, (a 6 digit number), a product description, the serving size, the CN crediting, the expiration of the label, the estate number and the company (Verification Report 2019).

Example CN label:

33 Once companies obtain a label for their products, they are required to develop and maintain a

Quality Control program. In 2010, AMS reviewed 3,052 label applications, where 2,813 were approved (92%). As of May 2011, there were 440 authorized manufacturers producing CN labeled products. A CN label costs more than non-CN labeled products, due to the inspection costs, and costs of monitoring quality control.

To be eligible for a CN label, products must have the product formulation and CN label approved by FNS and be produced under inspection. Food manufacturers must then submit an application for approval. The application materials include a FSIS Form 7234-1, Application for

Approval of Labels, Marking or Device, a product label, the Alternative Protein Product documentation if applicable, the Enriched Macaroni with Fortified Protein approval letter from

FNA (if applicable), and the confirmation of inspection for products inspected by FSIS, if applicable. The application is then reviewed by AMS and manufacturers are given feedback, which they can correct and submit again if necessary. Quality control requirements provide verification that CN labeled items are produced using the approved product formulation.

Manufacturers that successfully pass four consecutive reviews are reduced to 2 reviews per year

(Lund, 2010). Products with a CN label do not need a Nutrition Facts panel.

While a Child Nutrition label is not required for any food product, many PBM product ingredients are not in the Food Buying Guide, a guide for school food directors that shows foods’ specific contributions toward the meal pattern requirement. When a product does not have CN label and is not in the Food Buying Guide, the burden of calculating each of their contributions

34 to the meal pattern would fall on the school food service director, which may make them less likely to source it.

However, because obtaining a Child Nutrition label can be burdensome and costly, manufacturers instead have the option to provide schools directly with a product formulation sheet. Those who do not participate in the CN label program must provide program operators with certified product formulation statements (Questions and Answers on Alternate Protein

Products, n.d.). However, many companies many be reluctant to pursue this route as this would mean relinquishing their proprietary recipes.

Protein Digestibility Corrected Amino Acid Score: The CN label application has a specific track ​ for Alternative Protein Products (APP), which encompasses plant-based meat. The specific APP requirements are derived from Title 7 (Agriculture) of the Code of Federal Regulations and the

Protein Digestibility Corrected Amino Acid Score (PDCAAS). The PDCAAS was adopted by the Food and Drug Administration as the primary method used to evaluate the quality of protein based on its amino acid composition and digestibility. It is calculated by multiplying the amino acid score of a protein by its fecal true digestibility percentage. The fecal true digestibility is the number of nutrients absorbed from the small intestine. Protein is given a score from 0 to 1.0. A score of 1.0 means that after digestion, the protein provides 100% or more of the essential amino acids. Soy protein isolate has a score of 1, for example. The APP requirements determine which plant-based meat products can qualify as the protein component of the meal and in what balance.

While some proteins have similar PDCAAS scores and amino acid profiles to soy (such as pea, ​

35 amaranth, or quinoa protein), they have not been recognized by the NSLP as creditable protein ​ sources. This may have to do with the difficulty of updating regulations or the power of meat lobbying groups who may oppose products that seek to replicate meat.

Distribution Another barrier to increasing school districts’ use of PBM relates to issues of ​ ​ distribution. In order to procure their food from manufacturers or farmers, schools must work with distribution companies. While the distribution process is widespread and necessary, it can be difficult for schools and food manufacturers to navigate, as it involves many moving parts and large, monopolized companies. Pittsburgh school food director Malik Hamilton, for instance, describes the distribution process as a “back and forth” that is “never perfect” (M. Hamilton, personal communication, April 12, 2019).

To procure food, many school districts form coalitions or coops and order their food jointly through a bidding process (Pittsburgh’s consortium has approximately 130 districts, for example, though some of the larger districts have their own bids). The group bid method increases the purchasing power of the schools, because the more schools that are involved, the lower the prices. However, this system also means that districts are more restricted in how quickly they can add new products (the consortium of schools as a whole may only be able to add new foods every six months, for instance). Together, the school districts and the distribution companies agree on a range of products. Food items that reach the immediate acceptance threshold number of cases (800 cases in Pittsburgh’s coalition) are automatically placed on a sheet requiring the item to be stocked. However, distributors can also decline to stock certain items based on what is

36 financially feasible for them. Items that fall below that number are decided on a one-to-one basis, though if they are far enough below the case minimum, they will not be stocked. Likewise, if too many similar items are on a bid (six different types of chicken nuggets, for example), only the ones with the highest case numbers will likely be stocked. Because of this, the larger districts in a given consortium can also influence what other districts in the bid use. For instance, Pittsburgh, the largest district in its consortium, is phasing out soy. In choosing soy-free products, it can influence the other districts in their coop to do the same by eliminating the smaller orders of nuggets containing soy. Once the list is agreed upon, distributors then either procure the products directly from manufacturers or from manufacturing hubs. The distributor stores the products in a centralized warehouse and delivers to the schools’ centralized warehouses or individual school sites. While most schools contract with large broadline distributors, some may also use smaller, local distributors for produce or direct farm purchasing.

Nutrition While USDA NSLP guidelines ostensibly exist to provide students with healthy meals ​ (and specifically ⅓ of the RDAs), they are also influenced by many external factors, including lobbying groups, food industries, and politicians. Subsequently, there is room within the existing guidelines to provide meals that are low in nutrients and high in fats and sodium. For instance, as

Janet Poppendeick points out, pepperoni pizza, chocolate milk, and tater tots counts as a federally reimbursable lunch.

While processed meat is ranked as a Group 1 carcinogen, of the six most popular USDA commodity food products, four are meat: pork (end products are cooked sausage patties and

37 links, pizza topping, or pork barbeque), beef (end products are charbroiled patties, crumbles, or meatballs), chicken (end products include nuggets, patties, roasted pieces, or breaded chicken), and turkey (ham, bologna, breast deli slices). (National Alliance for Nutrition and Activity, n.d.).

Moreover, the cooking capacity of each school varies by district and can have an effect on the nutrition of the food. School food production systems can include on-site kitchens, central kitchens, and intermediate systems, where food is prepared at one school and distributed to others in the district (Poppendieck, 2010, p. 90). On-site kitchens often just have what is referred to as “heat-and-serve” capacities, where most of the food is pre-prepared and just needs to be stored in a freezer and heated up in a convection oven before it is served. This type of operation requires less equipment and less skill, and accordingly the food is often pre-prepared, packaged food such as processed meat or french fries (Poppendieck, 2010, p. 90).

Until the 2010 Healthy Hunger Free Kids Act (HHFKA), a la carte items and competitive foods were not subject to the meal pattern requirements or dietary guidelines (Poppendieck, 2010, p.

41). This too can create difficulties for PBM companies seeking to serve their food as pat of the reimbursable school lunch, as students who can afford to can circumvent school lunch by purchasing a la carte offerings instead.

Recent Changes In recent decades, school nutrition has gained the attention of activists, ​ ​ politicians, scholars, and celebrities. Due to concerns about child nutrition, environmental sustainability, animal welfare, food safety, and more, many schools are participating in programs

38 aimed at upgrading school lunch programs to include more vegetables, more scratch cooking, and more nutrition education. These programs often involve reducing meat consumption and focusing more on vegetarian options, including several schools that have already started to serve plant-based meat (Hamerschlag, 2018).

Some of these progressive school lunch programs include but are not limited to the Good Food

Purchasing Program, Edible Schoolyards, Food Corps, the Coalition for Healthy School Food, the Chef Ann Foundation, the Humane Society’s Forward Food Program, and the Lifetime

Foundation. Each of these programs has slightly different goals, but overlap and share overarching values. Some are more focused on sustainability, some are focused on nutrition, ​ while others encompass many goals simultaneously. The School Nutrition Association’s survey results confirm the trend that schools are focusing more on plants and nutrition education. For instance, they found that 67.6% of schools now offer salad or produce bars and 57.4% have ​ nutrition education, 59.9% offer locally sourced fruits and vegetables, while 52.2% include preferences for local or regional sourcing of foods in solicitations or purchase specifications,

47.8% have implemented Farm to School initiatives, and finally 34.2% utilize school gardens to promote healthier food choices (SNA Survey Reveals Innovative Efforts to Boost Consumption,

Curb Waste in School Cafeterias, 2018).

There has also been a trend toward climate-friendly school food on the state level. For instance, in March 2019, California passed legislation that “establishes within the California Department of Education (CDE) the California Climate-Friendly Food Program to provide incentives for

39 making plant-based food and beverages available to students,” which stipulates specifically that

“a single meal with both a plant-based food option and a plant-based milk option is eligible to receive reimbursement for both options, not to exceed the cost of the meal” and that

“reimbursement for this program be in addition to any other state or federal funding or reimbursement received” (“Plant-Based Meal Options in CNPs,” n.d.)

While some of the progressive school lunch programs do not specifically advocate for plant-based meat (and some even oppose it), a trend in some areas of the country toward climate-friendly, healthy, plant-heavy school lunches is evident, even as barriers remain.

Methods

In order to gain a better understanding of the barriers to integrating PBM into public school menus, I conducted a set of interviews alongside a literature review. Conducting interviews ​ ​ ​ ​ allowed me both to reach an array of experts in different but related fields, and to compare and contrast the opinions of different stakeholders who hold similar positions. As such, I conducted three categories of interviews: interviews aimed at understanding the barriers to serving plant-based meat from the school side, interviews aimed at understanding the barriers from the manufacturing side, and interviews aimed to delve deeply into each barrier. The first set included interviews with five school food directors and two third-party employees who work with school districts on increasing plant-based menu options. The second set included interviews with two plant-based meat company employees. The final set included an interview with Chris Keilly, an expert in distribution.

40

I reached out to all my interviewees by email, explaining that I was interested in the barriers to serving more PBM in the NSLP. From there I set up phone conversations with each interviewee

(with the exception of Malik Hamilton and Kaleigh Talbert who I interviewed in person, and

Jody Boyman, with whom I corresponded via email). These interviews each lasted between 30 minutes and one hour.

For the first set of interviews, I spoke with five different school food directors across four different states and two third-party employees at the Humane Society’s Forward Food program. I purposely chose to interview school food directors who have expressed concern for child nutrition, the environment, and animal welfare (which are the primary benefits I identify with the adoption of plant-based meat). While several of these directors currently or have previously served plant-based meat, I also deliberately sought out school food directors who do not. To identify these directors, I relied on the Friends of the Earth report entitled “Scaling Up Healthy

Climate-Friendly School Food,” which profiles schools that have adopted progressive and sustainable food sourcing initiatives. Three of the five directors I interviewed (excluding

Pittsburgh and San Francisco) were profiled in this report. Pittsburgh was chosen both because of its physical proximity to me, and their adoption of a progressive food sourcing program. All five districts have demonstrated steps to increase the environmental sustainability and healthfulness of their menus, often by reducing animal meat.

41 Due to time and resource capacity, I did not include interviews with districts uninterested in changing the healthfulness or sustainability of their menus. Because of this, my results do not demonstrate the altogether different challenges that PBM companies may face in districts that are uninterested in change or altogether unfamiliar with PBM. Further interviews to understand the barriers from the school side may have included more school food directors in other regions of the country, particularly ones who do not actively share these values, and other third-party employees, such as lunch monitors and cafeteria staff, teachers, parents, and students.

In each conversation I had with a school food director, I first asked about their school district and what, if any, sourcing philosophies they held. Then I discussed plant-based meat with them, asking whether they had heard of it, whether they served it or might serve it; if so, how often and what type; if not what their reservations were, and finally if they perceived any additional barriers to its wider adoption in the NSLP from the school side.

The second set of interviews, which included my interviews with Kristie Middleton and Jody

Boyman, was aimed at understanding the barriers to serving plant-based meat from the PBM manufacturer’s side. I sought out plant-based meat companies seeking to serve or currently serving their products in schools. I had a personal contact at Rebellyous foods, and identified

Hungry Planet though google searches involving plant-based meat in schools.

Again, due to time capacity, I did not conduct interviews with certain other categories that may have provided further perspective on why some companies choose not to serve their products in

42 schools and what the benefits of avoiding that route altogether may be. Further interviews in this category may have included other plant-based meat companies serving or seeking to serve their product in schools, plant-based meat companies who are not focusing on schools, or animal-meat or other food companies that serve their products in schools. Such interviews could be a topic for further research. These interviews I did conduct focused on the challenges of producing and distribution plant-based meat to schools from the manufacturer side, and covered topics such as production capacity, distribution, nutrition, and locating and partnering with school districts.

In the third category, I sought out people who had expertise in the barriers I had identified from my other interviews, such as distribution, price, taste, and nutrition. However, despite reaching out to several content experts, I was only able to connect with one. I was put in touch with

Sysco’s Vice President of Merchandising, Chris Keilly, through a professor. Further interviews in this category may have included interviews with pediatricians or child nutritionists (to learn more about the nutritional aspects of PBM), regulators at the USDA’s Food and Nutrition

Service (to learn about regulatory hurdles), and finally students (to learn about taste and acceptance).

After conducting and recording these interviews, I took notes from each recording. Using these notes, I solidified the list of barriers I had from my interview guide into five categories: price, regulations, taste, distribution, and taste/acceptance. I color coded each interview by barrier (for instance, highlighting every response related to price in red). Once color-coded, I reorganized the notes from all twelve interviews by color, so that I had five sections, each covering a particular

43 barrier, supported by findings from my interviews. I then used these sections as the basis for my

discussion.

List of Interviews (2019)

School Side San Francisco Unified School Alexandra Emmott Culinary Manager District, California March 19 Director of Food and Nutritional Novato Unified School District, Miguel Villarreal Services California April 3 Boulder Valley School District, Ann Cooper Director of Food Services Colorado April 3 Lauren Couchois Director of Food and Nutrition Amy Carroll Services & Dietitian Lee County Schools, Florida April 5 Malik Hamilton Purchasing Supervisor, Pittsburgh Public Schools, Kaleigh Talbert Dietician & Menu Planner Pennsylvania April 12

Karla Dumas Senior Manager at Forward Food Humane Society of the United States March 20

Kate Watts Food & Nutrition Specialist Humane Society of the United States April 5 Manufacturing Side Kristie Middleton Vice President, Business Development Rebellyous Foods, Seattle April 3

Jody Boyman Co-Founder Hungry Planet, California April 7 Content Experts Chris Keilly VP of Merchandising Sysco April 12

Sarah Olson* Deputy Administrator USDA FNS Child Nutrition Division Pending *Began Communication

44 Results

While there are many reasons to include PBM in the NSLP, there are still several barriers that manufacturers and schools face to accomplish this. These barriers are faced both by schools that have never served PBM and schools that currently serve it. Based on my literature review and interviews, the primary barriers I have identified to getting more plant-based meat options into the National School Lunch Program include price, regulations, nutrition, distribution, and taste/acceptance. The following shows how and to what extent each of the five barriers come into play for the stakeholders I interviewed.

Price Price is one of the primary obstacles to getting plant-based meat options in schools. Because school districts are often working with such small budgets, new products must be affordable in order for school food directors or menu planners to bring them in. Four out of five of the school food directors I spoke with cited price as a large concern in determining their menu items. This also held true in Kate Watts and Karla Dumas’ experience working with various school districts through the Forward Food program.

Plant-based meats are currently more expensive than animal protein for schools, especially if districts are using their USDA funds to purchase cheap commodity meat, which is provided to schools at very reduced prices. For instance, the Beyond Meat Pasta sauce costs 71 cents per serving while ground beef spaghetti costs only 44 cents per serving (L. Couchois, personal communication, April 5, 2019). A Michigan State University report found that one serving of commodity chicken can cost as little as $0.30 (“The Cost of School Lunch,” n.d.).

45 Hungry Planet’s Jody Boyman reiterated that “it is nearly impossible to compete against commodity beef and other meats that are subsidized by the federal government.” While some wealthier districts are willing to pay more for higher quality ingredients and products, many districts are struggling financially even without the admission of new more expensive menu items.

Usually school food directors must find a way to provide five different food groups on one plate for around $1.20- $1.40. Therefore, even if the protein option is only $1.00, that constitutes over

80% of the price of the plate. As Pittsburgh school food director Malik Hamilton puts it, a particular food “might be the right thing to do, it might be best product out there, it might hit every value standard we have, but if it costs me a $1.00 or a $1.50 just to put that one item on a plate, I can’t do it” (M. Hamilton, personal communication, April 12, 2019). Even in districts that are focused on environmental sustainability and child nutrition, price can be prohibitive:

“Numerous consumer attitude surveys have reported that a large majority of consumers are interested in buying brands with an environmental benefit. However, this research often disregards other factors. When product attributes such as price and quality are thrown into the mix, the relative importance of the environment to purchasing decisions falls significantly for all but a small minority” (Ranganathan et al 2016). ​ ​

Regulations Even if a PBM product is affordable, it must still meet USDA guidelines to be ​ included in the NSLP. Several aspects of the current regulations make this difficult. The names of the Meal Pattern Requirements, for instance, put plant proteins at a disadvantage. The

Humane Society’s Kate Watts describes the category of meat alternate as a “psychological

46 negative” (K. Watts, personal communication, April 5, 2019). Other research echoes this: “The very language of the school meal program is co-opted to disenfranchise food choices that do not include meat. The vegetarian food on the menu is discussed in terms of ‘meat’ instead of requiring a certain amount of servings of ‘protein’ every meal—a comparatively neutral nutritional guideline. Thus, when the USDA requires ‘meat’ or ‘meat alternatives’ as meal components, it requires that even vegetarian food conform to certain dominant cultural views about the centrality of meat at the table” (Mortazavi, 2014).

Krisite Middleton of Rebellyous Foods suggests that not only are many of these guidelines

“quizzical and archaic,” but they can also interfere with children’s acceptance of the food. For instance, one school tried a lentil-based pasta that would have credited as a meat alternate but due to the APP requirements, it had to have another bean in the recipe, recognizable as a whole bean, to comply with regulations. Middleton speculates that the dish ended up being unpopular, as the students who may have otherwise eaten pasta were turned off by presence the whole beans

(K. Middleton, personal communication, April 3, 2019).

Additionally, companies are limited by the proteins that can credit in the NSLP. For instance, wheat gluten is used in a lot of PBM as the protein source, but the USDA does not credit wheat protein (which has a PDCAAS of 0.25). Even Ann Cooper, who does not approve of plant-based meat, argues that there should be “more flexibility on the protein piece, and at the very least, quinoa should be included [as a reimbursable protein].” However, even in the event of federal regulation updates, schools may not menu new protein options in the near future. Pittsburgh

47 menu planner Kaleigh Talbert expressed satisfaction with the current protein options, such as beans and peanut butter, noting that she felt foods like quinoa or seitan would be unappealing to students who are unfamiliar with these products (K. Talbert, personal communication, April 12,

2019).

Finally, there is a scientific debate as to whether or not the PDCAAS is the best metric to use in this context. Some studies suggest that PDCAAS is not a holistic measure of digestibility because it only factors fecal digestibility and not ileal digestibility (Schaafsma, 1997). Further studies using rats suggest that “the PDCAAS method is inappropriate for predicting protein ​ quality of those protein sources which may contain naturally occurring growth-depressing factors or antinutritional factors formed during alkaline and/or heat processing” (Sarwar 1997). Krisite

Middleton further suggests that PDCAAS is a “meat-centric scale,” which is inherently biased ​ since measuring digestibility favors animal proteins (K. Middleton, personal communication,

April 3, 2019).

Nutrition The nutritional goal of the NSLP is to provide ⅓ of the RDAs. Federal programs like ​ HHFKA also factor in the DGAs. Private, optional programs, like that in Ann Cooper’s district in Boulder, have more rigorous and specific standards still like prohibition of common allergens or processed foods. Ann Cooper, for instance, does not serve PBM, arguing that “none of us know what long term effects there might be on highly processed pea proteins” and that serving

PBM is “antithetical to teaching kids about real food.” Even though Boulder shares many goals with plant-based meat companies (such as moving away from meat in order to improve child

48 nutrition and address environmental and animal welfare issues), Cooper seeks to phase out processed foods in favor of whole foods, non-GMO foods, and clean ingredient labels. Likewise, while Miguel Villareal of Novato seeks to provide more plant-based options, he simultaneously will not provide food that contains any of the “Harmful Seven” ingredients laid out by the

Lifetime Foundation, which are trans fats and hydrogenated oils, high-fructose corn syrup, ​ hormones and antibiotics, processed and artificial sweeteners, artificial colors and flavors, artificial preservatives, and bleached flour. He will categorically reject any PBM that contains any of these ingredients (M. Villareal, personal communication, April 3, 2019). ​

Additionally, certain school districts, such as San Francisco Unified and Pittsburgh Public

Schools, are also seeking to eliminate common allergens from their menus, including soy in their meat and non-meat products alike (M. Hamilton, personal communication, April 12, 2019; A.

Emmott, personal communication, March 19, 2019). Similarly, in Lee County, Florida, school food director Lauren Couchois purposely chose to source Beyond Meat because it was soy-free and therefore “safe to give to everyone.” Many PBM products contain soy since it is counts as a meat alternate that is high in protein (some soy-containing PBM products include but are not limited to Hungry Planet, Morning Star, Kellogg’s Garden Burger, Before the Butcher, and Dr

Praegger’s). As increasing numbers of districts like Pittsburgh, Novato, and Lee County commit to stricter allergy, nutritional and environmental policies, PBM manufacturers will have an added burden of creating recipes without common allergens, like soy, without GMOs, or without artificial preservatives. Identifying a vegetable protein source that is both creditable under NSLP regulations and free of common allergens may be a significant challenge for PBM companies.

49 Distribution Distribution is another important challenge for PBM companies and schools, since ​ distribution companies act as a crucial middleman with interests and goals that may not align with those of the school district. Broadline distributors are highly consolidated private ​ ​ companies. The limited competition means there is little incentive for them to carry new products from small, young companies, like many of the PBM companies. Instead, they seek a large volume of a certain product from well-known companies, often requiring case minimums or even pallet minimums, or truckloads (C. Keilly, personal communication, April 12, 2019).

Therefore even if a large district wants to contract with a small PBM company, the company may not be producing enough product to meet their distributors’ case minimum. Likewise, a small school district may want to source PBM but may only be able to afford 10 cases, while their contracted distributor might require a minimum of 20 cases to make it financially feasible for them. Therefore, PBM companies have the challenge of finding a balance between a district that is large enough to meet the distributors' case minimum but small enough that the manufacturer can provide enough product (K. Dumas, personal communication, March 20,

2019). Even once a distributor agrees to stock a certain product, it will be discontinued if it does not sell, so PBM companies need a way to ensure that the product continues to get requested by schools once it is in the distribution warehouse.

Moreover, the distribution system makes it advantageous for schools to consolidate down to fewer brands for a higher volume and better price. Consolidating may make it easier for schools to afford some higher quality items, but may also leave less room for some of the more niche items, such as PBM.

50

Acceptance & Taste Many of my interviewees emphasized that even if a PBM product is ​ healthy, affordable, and can make it through regulatory and distribution hoops, all is moot if students won’t try it or don’t enjoy it. As Malik Hamilton of Pittsburgh public schools says, “It doesn’t do us any good to meet every regulation just to have kids dump food in the garbage. We just spent a bunch of money to produce more hungry kids. So we gotta get them where they’re going to eat” (M. Hamilton, personal communication, April 12, 2019). ​

Plant based meat manufacturers are aware of the importance of taste: “Districts might not be ​ ​ proud to be serving nuggets, but they are a favorite, and first and foremost, the most important thing is that kids eat the food because it’s not nutritious if it’s going straight in the trash” (K.

Middleton, personal communication, April 3, 2019). Likewise, Jody Boyman of Hungry Planet emphasized the importance of making food tasty: “Kids are picky. They will not touch anything ​ that looks or tastes ‘weird’. Our foods look and taste like what they're used to but without the health and environmental consequences, and it gets eaten, not thrown in the trash” (J. Boyman, ​ personal communication, April 7, 2019).

Moreover, while the field is growing rapidly, plant-based meat products are still new and unfamiliar to many. For those who are unfamiliar with the issues surrounding animal meat, plant-based meat can have an “ick-factor,” which can be difficult to get around (K. Watts, personal communication, April 5, 2019). Additionally, while research shows that animal protein is not necessary for a healthful diet, large numbers of people still feel they need it. Getting schools (including students and staff) to accept that they don’t need meat every day is the

51 broader educational challenge. Even among those who accept plant protein, there remain those who reject PBM in particular, potentially due to it seeming unfamiliar and unnatural.

Additionally, if the staff are unengaged or uninformed about a product, it is far more likely the students will be.

Because schools risk losing money on uneaten food, many districts will not bring in products that have not been tested and received a 75-80% approval (K. Dumas, personal communication,

March 20, 2019). Because demographics vary so widely across the country, Hamilton warns that food manufacturers should understand Pittsburgh’s demographics specifically if they want to serve their product in Pittsburgh: “ Just because kids in Colorado like their product does not mean the same will hold true in Western, PA” (M. Hamilton, personal communication, April 12,

2019).

Moreover, schools must be careful in the way they position plant-based products. Kate Watts notes that in general, the terms vegetarian, vegan, or healthy should be avoided, since people ​ ​ associate the words vegetarian and vegan with less protein, and associate the word healthy with worse-tasting food (K. Watts, personal communication, April 5, 2019). Likewise, terms like ​ “meat-less” or “meat-free” make consumers feel that the product is incomplete.

Most interviewees expressed concern regarding each of the five barriers to different degrees.

Overall, the school food directors that I chose to interview were all primarily concerned with price, while secondary concerns varied between nutrition, convenience, environmental

52 sustainability, and taste. These secondary concerns were shared by all but varied in importance.

These results are unsurprising given that I identified school food directors who already had demonstrated interest in menu change. The PBM manufacturers I interviewed were also concerned with price (scaling up production to be able to offer cost competitive products), taste, and convenience (especially convenience as it relates to finding and contracting with distributors). Jody Boyman of Hungry Planet identified distribution as the largest hurdle to getting plant-based meat into schools. Content experts expressed concern about acceptance and position of the products, such as how to label them and introduce them in schools. Using the foundational knowledge from my literature review of the general landscape and the information from my interviews that provide nuance and elucidate stakeholders’ priorities, the following section addresses potential solutions to each barrier.

Discussion

Given the barriers I identified to serving PBM in the NSLP, the following are several potential solutions for each one that apply to schools, manufacturers, distributors, and interested third parties. Given that PBM manufacturers likely have the most incentive for PBM to reach the

NSLP, I provide a summary of resources and suggestions for PBM manufacturers to make their way increasingly in institutional contexts. I also provide suggestions to school districts looking to serve PBM, and to the general public.

53 Price

While PBM prices are predicted to fall, there are also short-term ways for schools or companies ​ to ease the burden of cost. PBM companies have several avenues for making their products more affordable to schools. For instance, one third of the Hungry Planet founder's shares are set up to support the Hungry Planet Philanthropy Project which subsidizes foods for select K-12 schools

(J. Boyman, personal communication, April 7, 2019). School food directors can buy commodity ​ fruits and veggies, leaving more money for healthier protein options, such as grass-fed meat or plant-based meat. Schools can also raise additional money with other food, like food trucks or catering, that act as additional income generators, like Santa Barbara’s “Mobile Cafe”

(Hamerschlag, 2018).

Many schools currently use vending machines or a la carte options to help fund their lunch program. In May 2019, the Plant-Based Foods Association, announced the launch of “The Power

Plant,” a vending machine that offers plant based snacks, like plant-based yogurt or smoothies:

“a grab-n-go concept that offers a turn-key solution to meet the high demand for plant-based foods on college campuses, in retail and food service retail spaces, airports, and hospitals, and other destinations across the United States” (Simon, 2019). If these Power Plants are sold to schools, they could be a potential avenue for revenue that could go toward PBM, while still maintaining a nutrition and plant-based focus.

As PBM starts to become cheaper, adopting it might even be cost-saving in some instances. Kate

Watts points out that many schools only have heat and serve capacity. For schools that want to

54 transition away from commodity meat products but cannot afford to implement educational programs, train new staff or buy new cooking equipment, PBM would not add labor costs or other expenses. (K. Watts, personal communication, April 5, 2019).

Regulations

There are several changes that could be made to the NSLP guidelines that would make it easier for plant-based meat to be implemented in schools. Allowing more foods to be credited in the protein category, and the Alternate Protein Product category in particular, would be beneficial for PBM companies, since the limited number that is currently credited is restrictive. Changing the language away from “meat alternate” could make a subtle difference in terms of menu planning. Likewise, updating the metric used to determine protein quality away from PDCAAS may allow for more foods to count toward the protein requirement, helping PBM companies. The annual School Nutrition Association conference is an opportunity for dialogue between the

USDA and school districts around the country, and could be an appropriate venue for broaching this topic. Likewise, the USDA occasionally opens Requests for Information public comment periods on different topics (including on whether tempeh should be credited). This is another avenue for participation, in which districts, PBM companies, or the general public could encourage the USDA to update NSLP regulations.

Nutrition

Kate Watts feels that processed foods, such as hot dogs and chicken nuggets, should be served in moderation where possible but given that, more often than not, the choice is not between

55 plant-based whole foods and processed PBM—it is between potentially carcinogenic, environmentally harmful animal meat and PBM—its preferable to serve plant-based meat.

Schools should consider the health benefits of plant-based meat with an open mind about processing, considering what other dangerous processes they might be avoiding by opting for plant-based meat. Admittedly, the districts like Boulder that have the resources to phase out certain foods in favor of whole food plant-based meals may not have a particular need for PBM in order to meet their nutritional (or sustainability) goals.

Ultimately, the onus falls on PBM companies to create recipes that school food directors view as nutritious if they intend to serve their products in schools. Finding a vegetable protein source that is both creditable under NSLP regulations and free of common allergens may be a significant challenge for PBM companies. Depending on the specific formulation, some examples of protein that fit this criteria include wheat and pea protein. Because there are so many PBM products, their nutritional content varies widely and it is often difficult to discuss their specific merits holistically, except in the negative (ex: PBM does not contain antibiotics). However, in many cases, plant-based meat can help schools meet a wide variety of nutritional goals, especially compared to their animal meat counterparts.

Distribution

Chris Keilly, Vice President of Merchandising at Sysco, suggests that a product should have equity, brand loyalty and recognition (what Keilly describes as the “Oprah factor”) in order to appeal to distributors. Distributors are more likely to align with the bigger companies that have

56 more brand recognition, financial backing, and can thus comply with food safety requirements, and do business on a larger scale. Keilly therefore advises PBM companies to focus on larger-budget university dining halls before working with K-12 schools in order to build their brand name and reputation (C. Keilly, personal communication, April 12, 2019).

Some of the largest school districts may have internal warehouses with large storage capacity, meaning that they do not need to go through a distributor for every product. Identifying and reaching out directly to these districts may help PBM companies circumvent the distribution hurdle.

Another possible avenue to circumvent this hurdle is for large companies such as Tyson, which already have established relationships with distributors and school districts, to sell their plant-based products to schools. This would allow PBM to circumvent the scaling up problems associated with young start-ups.

Taste/Acceptance

Acceptance and taste are crucial barriers to serving PBM in schools that fall both to the companies and the schools.

Pittsburgh public schools have noticed an influx of vegetarian requests among the parents of younger kids, indicating that families may be moving toward more plant-based eating (K.

Talbert, personal communication, April 12, 2019). With the rising number of “flexitarians” in the

57 United States, and with growing awareness of the meat industry’s issues, the “ick-factor” associated with PBM may be mitigated. Along with plant-based eating in general, plant-based meat is also becoming more mainstream. Impossible Foods launched the Impossible Whopper at

Burger King in early 2019 and Impossible sliders at White Castle in 2018. Likewise, the Beyond

Burger is served at many large grocery and restaurant chains including TGI Fridays and Krogers

(“Beyond Meat,” n.d.). The growing popularity of these products in the retail market may help familiarize kids with PBM conceptually and ease its acceptance in cafeterias.

While not every plant-based product will be popular with every student, it is nonetheless crucial that the kitchen staff are introduced to each product and know how to prepare it (K. Dumas, personal communication, March 20, 2019). Providing literature with the product or having people on site to explain its benefits to the students can help ensure long-term success. The

Humane Society's Forward Food program helps train staff and introduce them to new products.

They also provide educational materials to students, staff, and parents to support new products and make sure they stay on menus (K. Dumas, personal communication, March 20, 2019).

In terms of language, the Humane Society found that people were turned off by “Meatless

Monday” and instead implemented a “Lean and Green Wednesday.” Hungry Planet found that the best results have been when the school service lists the menu items with a simple asterisk at the bottom saying “made with premium plant-based meat” (J. Boyman, personal communication,

April 7, 2019). Ann Cooper also uses “plant-based” and “plant-forward,” which are concepts that

58 she believes are easier to grasp and that provide a better teaching opportunity than vegan or vegetarian (personal communication, April 3, 2019).

Suggestions

Based on the discussion above, the following are condensed suggestions for plant-based meat manufacturers, schools, and the general public who have an interest in seeing more PBM products in schools. Drawing on the barriers and potential solutions identified in this thesis, these suggestions may be useful to PBM companies in finding the right school districts, learning the

USDA FNS regulations, building brand recognition and formulating regulation-compliant recipes. Likewise, school districts interested in serving PBM products may find these suggestions useful when it comes to affording plant-based meat, positioning PBM products, and maintaining sustainable menus over time. Lastly, these suggestions may help the general public interested in

PBM’s potential positive impact in schools to facilitate this process and raise awareness and enthusiasm.

Advice for Manufacturers

1. Serving in K-12 Schools

Companies focusing on K-12 schools should familiarize themselves with the NSLP regulations, including USDA’s information and instructions on how to credit non-meat processed products.

General Information ● Information on the Meal Pattern Requirements can be found here. ​ ​ ● General information for food manufacturers can be found here. ​ ​ ● Guidance on getting processed products accepted can be found here. ​

Child Nutrition Label ● The USDA’s information about the Child Nutrition label can be found here. ​ ​

59 ● Instructions on how to apply for non-meat CN label can be found here. ​ ​ ● An additional tip sheet can be found here. ​ ​

Alternate Protein Products: ● A Sample APP formulation sheet can be found here. ​ ​ ● The APP requirements can be found here. ​ ​ ● The APP Q&A can be found here. ​ ​

Product Formulation Sheet ● A PFS tipsheet can be found here. ​ ● A sample PFS can be found here. ​

2. Recipe Formulation & Positioning the Product

There is still some flexibility within the regulations. Once a manufacturer is familiar with the regulations, they may consider certain additional qualities in their recipe formulation. For instance, they may consider using a recipe that avoids common allergens, like soy, and instead using creditable proteins like pea protein. It is also important for PBM manufacturers to differentiate themselves from other PBM companies and showcase their products’ individual advantages by paying close attention to the branding and packaging of the product.

3. Choosing the Right Districts a. Size of District Advantages of Small Districts Advantages in Large Districts (ex: LA)

-Product won’t get forgotten or lost in the -Less cooking capacity district wide, harder to shuffle train staff, buy cooking equipment

-Easier to maintain enthusiasm district-wide -More purchasing power with distributors

-Easier to form relationships with staff & -Less likely to be in a purchasing coop students, learn districts’ intricacies

-Reaches more students, can create more media/buzz

60 b. Plant-Forward Districts (ex: Boulder) Advantages of Plant-Forward Districts Advantages of Non- Plant-Forward Districts

-Shared values (child nutrition, animal -Categorically reject processed foods or welfare, environmental sustainability) certain ingredients

-Directors thinking critically about these -May already have highly trained staff, issues scratch cooking capabilities

-Directors actively looking for change in -Students may be used to whole food products and menu plant-based diets, like lentils or hummus

c. Wealth of District Advantages of Wealthier Districts Advantages of Less Wealthy Districts

-Can afford PBM in bulk, can meet case -Can’t afford scratch cooking or staff training requirements

-Can afford promotional materials -Haven’t had money to source more sustainably

-May be more likely to have students who are -Students may be less familiar with more familiar with PBM expensive whole foods

4. Learn your Districts

Once a manufacturer has identified districts, they should take the time to learn about the demographics of the district, form a relationship with the school food director, and sample their product to students.

5. Consider Colleges

Consider serving your product in colleges and universities first, to build brand recognition and scale up production. Colleges and universities do not have the same prohibitive cost or

61 regulatory restraints as K-12. As they build brand name recognition and grow capacity through that channel, prices will fall, in turn making acceptance into the NSLP easier.

Advice for Schools

1. Use the Plant Based Foods Association Power Plant as an a la carte option to make PBM

more affordable without relying on industrial animal agriculture.

2. Contact districts already serving PBM for advice, including advice on distribution.

3. Work with existing programs like HSUS Forward Food for resources and support from

people familiar with and enthusiastic about PBM products.

4. Be thoughtful about how to position PBM. Label it clearly and consider avoiding terms

such as “meatless,” “vegan,” “vegetarian” or “healthy.” Educate staff about the products

and introduce them with education materials. Be prepared to answer questions from

parents, staff, and students regarding PBM.

5. Once menued, work with your staff and students to maintain enthusiasm about

plant-based products.

6. Order PBM from companies that already have their products in your school, like Tyson,

to take advantage of established distribution channels and existing contracts.

7. Short of menuing PBM, continue to provide blended options (such as a lentil and beef

burger), plant-based options, such as hummus wraps or beans and rice, and higher quality

meat (meat with a lower environmental impact or stronger animal welfare policies).

62 Advice For Parents and the General Public:

1. Familiarize yourselves with the environmental and health benefits of PBM over

conventional animal meat. Teach your kids!

2. Try plant-based meat and find your favorite products. Tell your kids’ school food director

you would like to see them on the menu.

3. Participate in open comment periods, encourage USDA to update regulations regarding

permissible non-meat proteins, emphasizing recent USDA moves toward plant-based

options, like recent addition of tempeh.

Conclusion

The plant-based meat industry is growing rapidly, expanding into many retail and restaurant locations. To date, though, it only has limited spread in the foodservice industry, such as prisons, hospitals, universities and schools. There are many potential advantages to incorporating more plant-based meat in the National School Lunch Program, including improving child nutrition, reducing reliance on environmentally harmful and abusive animal meat operations, and reducing the risk of antibiotic resistance. While the inclusion of grass-fed meat, whole foods plant diets

(or cell-based meat in the future) into the National School Lunch Program could also help mitigate these issues, plant-based meat has several unique advantages that make it an important solution alongside the other options. Because it is created to mimic the taste and texture of meat,

PBM may appeal more to students than unfamiliar whole foods plant-based protein sources in some cases. Additionally, because it does not require scratch cooking, it will not add to schools’ labor or equipment costs. If animal meat continues getting more expensive and plant-based meat

63 continues getting cheaper, PBM can be a convenient, affordable, and nutritious option for school districts. Plant-based meat can also help teach kids about plant-based eating at an early age, since schools provide more of an educational opportunity than retail locations.

Despite the urgency of the climate crisis and the spread of antibiotic resistance, it is worth emphasizing that, even in its most successful iteration, the process of acceptance for plant-based meat is slow. It will take time for consumers, including parents, school food directors, and students themselves, to accept plant-based meat. As it gains market share, more and more people will become familiar with its benefits and enjoy its taste. However, changing people’s mindset should not feel like an attack on what they know or like and therefore needs to be done thoughtfully over time. As these products reach more mainstream channels through innovation, market forces and choice, they will have an easier time being incorporated in foodservice operations, like schools. Secondly, the speed at which schools can taste test new products, order them, procure them, and add them to menus, is also deliberate and lengthy. On the manufacturer’s side, developing a tasty and regulation-compliant recipe, and subsequently applying for a CN label is likewise time-consuming. While PBM is already in some schools, the adoption of more could take time.

While the adoption of plant-based meat in American public schools will likely be an uneven, nonlinear, and slow process, it also has the potential to improve child nutrition, reduce reliance on harmful processes, and provide a platform for education regarding important issues with the current meat system. As the plant-based meat market continues to grow, so too will opportunities

64 to integrate PBM products into schools. In the meantime, it is crucial to recognize and support existing efforts and facilitate new efforts, on the local, state and federal level. Doing so could have long-lasting and far-reaching benefits for animals, for people, and for the planet.

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