1. ARE SCHOOLS MAKING
THE GRADE?
SCHOOL NUTRITION POLICIES
ACROSS CANADA

2. ARE SCHOOLS MAKING
THE GRADE?
SCHOOL NUTRITION POLICIES
ACROSS CANADA
OCTOBER 2007
This report was written by Aileen Leo, Senior Policy Advisor, Centre for Science in the Public
Interest, Ottawa, Canada.
CSPI wishes to thank provincial and territorial government officials for their helpful input and
the ten external reviewers from universities and health- and education-related NGOs who
generously provided comments on an earlier version of this report. Their advice improved our
analysis.
The author also wishes to thank Bill Jeffery, LL.B., National Coordinator; Joy Johanson, Senior
Nutrition Project Associate; Bruce Silverglade, J.D., Director of Legal Affairs; and CSPI
Executive Director Michael F. Jacobson, Ph.D., for reviewing this report. Any defects or
omissions are the responsibility of the author.
The Centre for Science in the Public Interest (CSPI) is a consumer health advocacy organization
specializing in nutrition and food safety with offices in Ottawa and Washington, D.C. CSPI's
Ottawa advocacy efforts are supported by more than 100,000 subscribers to the Canadian edition
of Nutrition Action Healthletter. CSPI does not accept industry or government funding.
Nutrition Action Healthletter does not carry advertisements.
Suite 2701, CTTC Bldg.
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Ottawa, Ontario K1S 5R1
Tel.: 613-244-7337
www.cspinet.org/canada

3. Table of Contents
Open Letter to Federal, Provincial and Territorial Ministers
Executive Summary
I. Introduction – The human and economic toll of diet-related diseases, including
childhood obesity...........................................................................................................................1
II. The need to standardize and improve nutrition criteria for school foods......................................3
III. Investing in nutritious food............................................................................................................5
IV. Overview of provincial nutrition criteria for school foods............................................................9
V. How provincial nutrition criteria were rated ...............................................................................15
VI. Weaknesses of provincial nutrition criteria.................................................................................16
VII. Conclusions and recommendations .............................................................................................24
Charts:
1. US federal government and Canadian federal, provincial and territorial government financial
investments in school meals, 2005-06.......................................................................................6
2. Report card on school nutrition standards (summary).............................................................13
3. How provincial school nutrition criteria stack up against IOM core nutrient
standards (detailed)..................................................................................................................17
Appendices:
1. Key findings from publicly available provincial school nutrition surveys .............................26
2. List of provincial nutrition criteria for school foods ...............................................................28
3. Excerpt from the US Institute of Medicine’s “Nutrition Standards for
Foods in Schools”....................................................................................................................31
4. Excerpt from Canada’s Food Guide (2007) relevant to institutional food service for school-
aged children ...........................................................................................................................33
5. Provincial/territorial government and Breakfast for Learning investments in
school food programs ..............................................................................................................34
6. Legal analysis: Putting to Rest Constitutional Excuses for Inaction on School
Foods .......................................................................................................................................35

4. Open Letter
October 3, 2007
Federal, Provincial and Territorial Ministers of Health and
Provincial and Territorial Ministers of Education and Child Protection
Dear Ministers:
As you know, diet-related diseases, including cancer, heart disease, stroke, and diabetes,
represent a major public health threat, with many of their causes well-known. Many Canadians,
including children, consume too few fruits, vegetables, and whole grains and too many foods
high in saturated fat, trans fat, salt, and added sugars. As a report commissioned by Health
Canada noted, “poor nutrition is a key preventable risk factor for the major chronic diseases that
take a huge toll in morbidity, disability and premature death in Canada.” Fortunately, means are
available to prevent those diseases.
Obesity is a major risk factor in the development of many diet-related diseases and
increases in childhood obesity portend higher rates of those diseases. The House of Commons
Standing Committee on Health found that childhood obesity is attributable in large part to
increases in portion sizes and in the intake of foods and beverages high in fats and sugars. The
Committee fears that, if this trend is not reversed, today’s generation of children may be the first
in a long time to live shorter, sicker lives than their parents. Economic ramifications, including
additional strains on publicly funded medicare, could be enormous.
Schools can be effective venues to encourage healthy eating. However, our review of
provincial school food policies, as detailed in our new report, Are Schools Making the Grade?,
reveals that they are governed by inadequate nutrition criteria and recent school food surveys
demonstrate that many foods offered in schools are high in saturated fat, trans fat, salt, and sugar.
In 2005, under the Integrated Pan-Canadian Healthy Living Strategy, health ministers
committed to develop school nutrition standards as part of comprehensive school health efforts.
Most have done so, but, unfortunately, all of those nutrition standards currently in place fall short
of the US Institute of Medicine (IOM) school nutrition standards issued in 2007. Current
provincial nutrition programs also offer inadequate incentives for students to consume more
fruits, vegetables, and whole grains, as recommended in the 2007 edition of Canada’s Food
Guide

5. To improve school foods, we urge you to take the following actions:
1. Develop and support the implementation of comprehensive Pan-Canadian school
nutrition policies that contain nutrition standards for all foods distributed in school
and reflect Canada's Food Guide (2007) as well as the US Institute of Medicine’s
Nutrition Standards for Foods in Schools (2007).
2. Support the establishment of a pan-Canadian school meals program that is based on
health-protecting nutrition standards and encourages healthy eating habits.
3. Conduct regular surveillance of school food policies and guidelines, food offerings,
and student consumption measured against benchmarks.
While we are cognizant of inter-jurisdictional political sensitivities, Canada's children are
entitled to nutritious fare at school regardless of where they live.
We urge you to implement these recommendations to ensure that all children can learn in a
healthy school nutrition environment. These measures will help children improve their diets and
learn to eat better as adults, thereby ensuring the health of future generations and reducing the
high incidence—and price—of diet-related disease.
Sincerely,
Bill Jeffery, LL.B.
National Coordinator
Aileen Leo
Senior Policy Advisor
2 of 2

6. Executive Summary
Diet-related disease is a serious public health problem in Canada. Many Canadians,
including children, consume too many calories, too much saturated and trans fats, salt, and added
sugar, and not enough fruits, vegetables, whole grains, and legumes. Every year, diet-related
diseases, including heart disease, stroke, diabetes, and certain cancers, prematurely end the lives
of tens of thousands of Canadians and cost the economy billions of dollars in healthcare
expenses and lost productivity.
The epidemic of childhood obesity is especially worrisome. According to the 2007
House of Commons Standing Committee on Health, Canada has one of the highest rates of
childhood obesity in the world. Obesity-related health problems are now occurring at a much
earlier age and continue to progress into adulthood.
The health and economic implications of these trends are alarming. In fact, today’s
generation of children may be the first in some time to have shorter life expectancies and poorer
health outcomes than their parents. If left unchecked, diet-related diseases are likely to fetter
access to health services and strain the capacity to finance publicly funded medicare.
Schools are ideal fora in which to begin reversing this trend and to encourage children to
choose healthier foods, such as fruits, vegetables, and whole grains, as recommended in
Canada’s Food Guide (2007). However, we have found that a disturbing number of school food
choices are high in saturated and trans fat, salt, and sugar, perhaps because cafeterias focus more
on optimizing product sales than students’ health. This report card examines the adequacy of
nutrition criteria for school foods as set out by each province (called policies, standards or
guidelines depending on the jurisdiction).
Because there are virtually no current, publicly available data about what is actually
being served in schools since these nutrition standards came into effect—and, more importantly,
what and how much children are actually eating—we were not able to evaluate the nutritional
merit of the school food environment directly. However, anecdotal evidence indicates that
adherence to these standards in those schools where they are intended to apply is the exception
rather than the rule. Furthermore, depending on the province, nutrition criteria may apply
broadly to all foods distributed in any manner for students K-12 (e.g., New Brunswick), or only
to foods distributed through vending machines in elementary schools and volunteer-organized
meal programs (e.g., Ontario). The narrow scope of some criteria, the inadequacy of
enforcement measures in most jurisdictions, as well as the paucity of government fiscal support
for healthy eating in schools must be fixed as governments revisit their nutrition criteria to
respond to the recently revised Canada’s Food Guide (2007) and important guidance from the
U.S. Institute of Medicine’s Nutrition Standards for School Foods (2007).
In 2005, under the Integrated Pan-Canadian Healthy Living Strategy, health ministers
committed to develop school nutrition standards and healthy eating programs. Nutrition criteria
for school foods are now in place in eight out of ten provinces. Alberta's draft guidelines are
currently undergoing consultation, and the government of Quebec has announced that its new

7. criteria will apply as of 2008. The Yukon, the Northwest Territories and Nunavut have no
school nutrition criteria.
Some provincial criteria include measures that could, if followed, help enhance the diets
of Canadian children. Overall, however, Canadian school food criteria are a patchwork quilt of
flimsy, inconsistent standards. They suffer from several shortcomings, including:
• Weak nutrition standards that permit the sale of nutrient-poor foods—New Brunswick, for
example, allows the sale of high-fat and high-salt items such as ice cream and pizza twice a
week. Prince Edward Island allows the sale of high-fat and high-salt foods such as cheese
pizza and pretzels two to three times a week. Alberta's draft criteria allow the sale of dozens
of foods high in fat, sodium, and sugar, such as potato chips, soft drinks, chocolate bars,
candy, ice cream, cakes, cookies, deep fried foods, donuts, pastries, and whipped cream, on a
weekly basis. And Newfoundland and Labrador allows the sale of ice cream, chicken wings,
fried meats, pretzels, and other junk foods on a daily basis so long as such foods comprise
less than 50% of food offerings at school.
• Failure to set explicit limits on saturated and trans fats, salt, and sugar content—In
Saskatchewan and several other provinces, school nutrition criteria merely suggest which
general types of foods can be sold, but provide almost no nutrient criteria to aid such
determinations. Specific nutrient criteria in other provinces, such New Brunswick, Prince
Edward Island, Quebec and Ontario concerning fats, salt, sugars, and calories/portion sizes
exist only on a piecemeal basis or not at all.
• Wide variations in school food nutrition criteria among provinces—These include
approaches to limiting substandard food choices as well as whether criteria apply to all or
only part of the food offerings available within schools.
• Failure to develop school nutrition policies—The northern territories have not yet issued any
school nutrition standards.
• Lack of published information concerning schools’ compliance with provincial nutrient
criteria—Given the lack of publicly available information concerning school compliance, it
is very difficult to determine the extent to which provincial nutrient criteria for schools are
actually being followed.
In addition, all provincial nutrition criteria fall short of the new US Institute of Medicine
(IOM) school nutrition standards issued in April 2007. The IOM standards primarily set upper
limits for unhealthy amounts of nutrients in foods sold on school premises outside of federally
subsidized meals. We compared existing provincial school nutrition criteria to the IOM
standards; Canada’s Food Guide (2007) as well as a report from the US National Alliance for
Nutrition and Physical Activity were also used as interpretive aids to assess the provincial rules
on serving size and/or calorie limits. Each province was assigned a letter grade ranging from
“A” to “F.” The following table outlines how provincial nutrition criteria rated. No province
received an “A” since none has a policy entirely consistent with those standards. Only one
province, Alberta, received a “B”—and it is important to point out that the school food

8. guidelines for this province are only in draft form and will not be confirmed until later this year.
The three northern territories received “No Standards” because these jurisdictions have not
issued nutrition policies.
SCHOOL NUTRITION POLICY REPORT CARD
Province/Territory Grade
British Columbia D
Alberta (*draft guidelines) *B
Saskatchewan F
Manitoba D
Ontario F
Quebec D
New Brunswick D
Nova Scotia C
Prince Edward Island F
Newfoundland and Labrador C
Nunavut No Standards
Northwest Territories No Standards
Yukon No Standards
These results indicate the pressing need to improve school nutrition criteria across
Canada to ensure that children have access to healthy and nutritious food while in school no
matter in which province they live. To improve Canadian standards for foods sold in schools,
we recommend that all governments:
1. Develop and support the implementation of comprehensive school nutrition policies that
include nutrition standards for all foods distributed in school and reflect Canada's Food
Guide (2007) and the US Institute of Medicine’s Nutrition Standards for Foods in Schools
(2007).
2. Support the establishment of a pan-Canadian school meals program that is based on health-
protecting nutrition standards and encourages healthy eating habits.*
3. Conduct regular surveillance of school food policies and guidelines, food offerings, and
student consumption and compare to benchmarks.
*
Ideally, this program should also support local agriculture, and contribute to a sustainable environment, but those
aspects of such a program are beyond the scope of this paper.

9. Financial support of school meals by the federal government is necessary to help ensure
that students consume healthy nutritious fare, as recommended in Canada's Food Guide (2007).
Presently, there is no pan-Canadian publicly subsidized school meal program and provincially-
funded programs are small and piecemeal. While education in Canada is primarily a provincial
responsibility, responsibility for health protection, nutrition, food safety, and consumer
protection has long been assumed by both levels of government.
In light of federal inaction, the responsibility for funding school food programs has fallen
on provincial governments and the non-profit sector. But together, average support per student
is just $5.95 per year. In contrast, US school feeding programs, which are primarily paid for by
that nation’s federal government, provide approximately CAD$212 per child, almost 38 times
more than Canadian governments spend. The time has come for the federal government to step
up and take responsibility for establishing a nutritionally sound, standards-based, subsidized
school meal program that ensures access to healthy foods for all school children and restricts
access to unhealthy foods.
Development and enforcement of nutrition standards for school foods and initiation of a
federally subsidized school meal program will help children improve their diets and learn to eat
better as adults. It will also help protect the health of future generations and reduce the high
human toll and economic costs of diet-related disease.

10. 1
I. Introduction – The human and economic toll of diet-related diseases,
including childhood obesity
Diet-related diseases have emerged as serious public health problems in Canada. Many
Canadians — including children — consume too many calories, too much saturated and trans fat,
salt, and added sugar and not enough vegetables, fruit, whole grains, and legumes.1
Every year, diet-related illnesses such as cardiovascular disease, diabetes, and certain
forms of cancers prematurely end the lives of tens of thousands of Canadians2
and rob the
Canadian economy of $6.6 billion due to healthcare costs and lost productivity.3
As a report
commissioned by Health Canada has noted, “poor nutrition is a key preventable risk factor for
the major chronic diseases that take a huge toll in morbidity, disability and premature death in
Canada.”4
Rising obesity rates and other health problems have the potential to exacerbate
waiting times for treatment and strain our capacity to finance publicly funded medicare. In fact,
a recent report to Congress of the US Medicare Advisory Commission noted that the share of
spending attributable to obese enrollees increased from about 9% in 1987 to about 25% in 2002,
a substantially larger increase than was seen in the obesity rate for the medicare population. (In
the US, medicare enrollees are mainly senior citizens.)5
The epidemic of childhood obesity is especially worrisome. According to the April 2007
report on this issue by the Standing Committee on Health of the House of Commons:
Canada has one of the highest rates of childhood obesity in the developed world,
ranking fifth out of 34 OECD countries. Recent data reveals [sic] that 26% of
young Canadians aged 2 to 17 years are overweight or obese. Even more
1
Physical activity also plays an important role in health promotion, but a detailed discussion of its importance is
beyond the scope of this report.
2
See PT Katzmarzyk, et al. “The Economic Burden of Physical Inactivity in Canada,” CMAJ, 2000; 163(11):
1438, http://www.cmaj.ca/cgi/reprint/163/11/1435, last accessed September 23, 2007. Katzmarzyk estimated both
the number of annual deaths at 21,340 and the healthcare costs attributable to physical inactivity at $2.1 billion
annually; this estimate is likely conservative now given the rising rate of obesity. The Centre for Science in the
Public Interest is not aware of any published estimates of the death toll from diet-related illness in Canada, however,
by extrapolating from estimates such as Katzmarzyk on annual deaths from inactivity-related illnesses and Health
Canada's estimate for the economic burden of diet-related disease, we estimate it to be roughly 25,400 deaths per
year.
3
See Diane Gorman, Assistant Deputy Minister of Health. Speech at the stakeholder meeting on the review of
Canada's Food Guide to Healthy Eating in Ottawa, January 20, 2004, p. 3.
4
Diane McAmmond and Associates. Food and Nutrition Surveillance in Canada: An Environmental Scan.
(Prepared for Health Canada), March 2000, p. 9, http://www.hc-sc.gc.ca/fn-an/alt_formats/hpfb-
dgpsa/pdf/surveill/environmental_scan_e.pdf, last accessed September 23, 2007.
5
Medicare Payment Advisory Commission, Report to the Congress: Promoting Greater Efficiency in Medicare,
June 2007, p. 9, http://www.medpac.gov/documents/Jun07_EntireReport.pdf, last accessed September 23, 2007.

11. 2
distressing is the evidence that about 55% of First Nations children on reserve and
41% of Aboriginal children living off reserve are either overweight or obese.6
The 2006 Canadian Clinical Practice Guidelines on the management and prevention of
obesity notes that “obesity-related health problems are now occurring at a much earlier age and
continue to progress into adulthood.”7
For example, the Canadian Diabetes Association has
observed that a decade ago, type 2 diabetes was an adults-only disease. “Today, childhood
obesity, unhealthy eating habits and inactivity are leading to more and more children, as young
as nine years of age, being diagnosed with type 2 diabetes.”8
Other conditions associated with
obesity include hypertension, dyslipidemia, coronary artery disease, stroke, osteoarthritis, some
forms of cancer,9
orthopedic problems as well as negative self-esteem, withdrawal from
interaction with peers, depression, anxiety, and feelings of rejection.10
Indeed, the Standing
Committee on Health concluded that today's children may be the first generation for some time
to have poorer health outcomes and a shorter life expectancy than their parents.11
The Committee went on to note that this rise in caloric intake by Canadian children and
youth is attributable to:
increased portions, increased intake of fatty and processed foods as well as greater
consumption of sugary drinks. The link between obesity and the increased
consumption of sweetened drinks is particularly disturbing. It has been estimated
that sugary drinks may be responsible for as much as one pound per month weight
gain in adolescents.12
Recent surveys of the eating habits of Canadian children and youth confirm excessive
consumption of nutrient-poor foods. For example, the Statistics Canada’s 2004 Canadian
6
Standing Committee on Health, House of Commons (Canada). Healthy Weights for Healthy Kids: Report of the
Standing Committee on Health, March 2007, p. 1,
http://cmte.parl.gc.ca/Content/HOC/committee/391/hesa/reports/rp2795145/hesarp07/hesarp07-e.pdf, last accessed
September 23, 2007.
7
David C.W. Lau et al. “2006 Canadian clinical practice guidelines on the management and prevention of obesity
in adults and children” [summary], Canadian Medical Association Journal, April 10, 2007; 176 (8), p. S1,
http://www.cmaj.ca/cgi/reprint/176/8/S1, last accessed September 23, 2007.
8
Canadian Diabetes Association. “Type 2 Diabetes In Kids: A Crisis In Progress?” News Release, October 16,
2003, http://www.diabetes.ca/section_main/NewsReleases.asp?ID=79, last accessed September 23, 2007.
9
Lau et al., p. S1.
10
See also for example Richard J. Deckelbaum, Christine L. Williams. “Childhood Obesity: The Health Issue,”
Obesity Research, November 4, 2001, 9(S4), p. 239S-243S,
http://www.obesityresearch.org/cgi/reprint/9/suppl_4/S239, last accessed September 23, 2007.
11
Healthy Weights for Healthy Kids: Report of the Standing Committee on Health, op.cit.
12
Ibid, p. 4.

12. 3
Community Health Survey found that, on average, 33% of 14-18 year-olds reported that they had
consumed prepared fast-food the previous day compared with 25% of overall respondents.13
Similarly, in 2007, Breakfast for Learning, a national non-profit organization that
supports child nutrition programs in Canada, found that:
• Only 50% of children surveyed consume the minimum number of daily servings of
vegetables and fruit.
• Only 25% meet the new Canada’s Food Guide (2007) recommendations for grain
products.
• 28% eat french fries two or more times per week.14
These figures indicate a trend toward disturbing dietary patterns that must be reversed.
II. The need to standardize and improve nutrition criteria for school foods
Schools are, by far, the most effective public venues for introducing healthy eating
initiatives to improve children's health. Most Canadian children aged 4-18 spend more of their
waking hours at school than any other single place—for many kids, even more time than at
home, at least during week-days. The centrality of schools in children’s everyday lives makes
schools attractive and efficient sites for health promotion programs, including efforts to improve
diet. As the Heart and Stroke Foundation of Canada has noted,
schools are an ideal setting to establish and promote healthy eating amongst children and
youth. Schools have an important influence on what children and youth eat. The school
environment influences healthy eating in children and youth through the foods that are
available, nutrition policies, school nutrition and the health curricula, and teacher
and peer-modelling.15
Similarly, the World Health Organization points out that “schools have been identified as
13
Statistics Canada (Didier Garriguet). Nutrition: Findings from the Canadian Community Health Survey –
Overview of Canadians' Eating Habits, p.8, http://www.statcan.ca/english/research/82-620-MIE/82-620-
MIE2006002.pdf, last accessed September 23, 2007. Statistics Canada surveyed more than 35,000 people
concerning what they had eaten during the previous 24-hour period.
14
Breakfast for Learning. Canada's Kids Still Don't Make the Grade
http://breakfastforlearning.ca/english/resources/index_ReportCard2007.html, last accessed September 23, 2007.
The BFL Report Card surveys 500 households by telephone with children aged 6 - 12 and adolescents aged 13 - 18
concerning their eating habits.
15
Heart and Stroke Foundation of Canada, “Schools and Nutrition,” Position Statement,
http://ww2.heartandstroke.ca/images/english/Nutrition_in_SchoolsPS(06)-English.pdf, last accessed September 23,
2007. See also: Institute of Medicine and National Academies. Preventing Childhood Obesity–Health in the
Balance, The National Academies Press, Washington. D.C., 2005; and Kubik, M.Y., Lylie, L.A., Story M.
“School-wide food practices are associated with body mass index in middle school students,” Arch Pediatric
Adolescent Med, 2005 (159) p. 1111-1114.

13. 4
one of the fundamental settings for health promotion and establishing healthy eating
and lifestyle patterns,”16
noting the beneficial effects of healthy nutrition on improved learning
ability, academic performance, attendance, behaviour, and child-teacher relationships.17
However, schools can also have major adverse effects on children’s health if the food
available in cafeterias, vending machines, tuck shops, and at special events and fundraisers is
dictated by appealing to children’s palates or cost-cutting measures.18
School food environments
thus present both a threat and an opportunity to improve children’s health. While public schools
face fiscal pressures due to chronic under-funding by governments,19
selling nutrient-poor foods
to children and undermining children's health should not be the answer to the fiscal challenges
these institutions face.20
The US Institute of Medicine (IOM) has recognized the importance of improving school
food nutrition standards. (Scientific advice
from the IOM is often used as the basis for
Canadian government policy.) In April 2007,
the IOM proposed model nutrition standards
for foods sold outside the US National School
Lunch Program entitled Nutrition Standards
for Foods in Schools: Leading the Way
Toward Healthier Youth21
(see Appendix 3).
Such items are typically sold in vending
machines and snack bars and as à la carte
items in cafeterias in American schools.
16
World Health Organization. Food and nutrition policy for schools: A tool for the development of school nutrition
programmes in the European Region, 2006, p. 8, http://www.euro.who.int/Document/E89501.pdf, last accessed
September 23, 2007.
17
Ibid, p. 6.
18
In the words of John Alm, CEO of Coca-Cola until 2005, “the school system is where you build brand loyalty.”
Leith, S. “A lesson for Coke: Atlanta-based CCE takes on critics, defends soft-drink sales in schools,” Atlanta
Journal-Constitution, April 6, 2003.
19
See: Canadian Teachers’ Federation Canadian Centre for Policy Alternatives, Fédération des syndicats de
l'enseignement. Commercialism in Canadian Schools: Who's Calling the Shots? 2006, http://www.ctf-
fce.ca/commercialism_in_school/en/FullReport.pdf, last accessed September 23, 2007.
20
While underfunding forces many schools to rely upon junk food sales as a form of revenue, this is particularly the
case for schools in low-income areas. As such, policy development to eliminate junk food in schools should be
undertaken in such a way to ensure that poor schools do not suffer punitive effects when junk food sales are
eliminated.
21
See The National Academies Press, Washington, D.C., http://books.nap.edu/execsumm_pdf/11899.pdf, last
accessed September 23, 2007. Such items are known as "competitive foods" since they compete with National
School Lunch Program choices.

14. 5
If implemented, the IOM standards would ensure that such foods meet limits on calories,
sodium, saturated and trans fats, and sugars, and would include water, 100% juice, low-fat dairy
products, whole grains, fruit, and vegetables. Caffeine-free diet soft drinks would be available
only in high schools and only after the school day has ended; sports drinks could only be
available, at the coach’s discretion, to students engaged in programs that include more than an
hour of vigorous physical activity.
Several states in the US have already finalized new nutrition standards for foods sold at
schools. Mandatory regulations established by the states of California22
and Kentucky23
incorporate some of the most health-promoting criteria for foods sold in US schools.
III. Investing in Nutritious Food
Any examination of provincial school food standards must also note the complete
absence of a federally subsided school meal program and meager provincial subsidies. In
contrast, the US has had a federally subsidized school meal program since 1946.24
Last year in
the US, federal government support for this program surpassed US $10 billion, or approximately
CAD $212.26 per student.25
However, despite the obvious need, there is no comprehensive,
national publicly subsidized school meal program; the federal government contributes nothing to
help ensure proper nutrition for Canadian children while in school and there is little parity or
coordination among provincial and territorial programs.
Most provincial and territorial governments and the non-profit sector do make some
efforts to feed our children. But together, their combined annual funding per student (i.e.,
elementary and secondary school enrollees) ranges from a low provincially of $0.31 in Alberta
(where public funding is non-existent) 26
to $23.77 in British Columbia (where the provincial
22
See California Department of Education. “Restrictions on Food and Beverage Sales Outside of the School Meal
Program in the State of California,” Management Bulletin 06-110: Restrictions on Food and Beverage Sales Outside
of the School Meal Program, http://www.cde.ca.gov/ls/nu/sn/mb06110.asp, last accessed September 23, 2007.
23
See Kentucky Board of Education. “Minimum Nutritional Standards for Foods and Beverages Available on
Public School Campuses During the School Day in Kentucky.” Board Notes: Board Approves 702 KAR 6:090,
Minimal Nutritional Standards for Foods and Beverages Available on Public School Campuses During the School
Day, 13(4), August 3-4, 2005, http://education.ky.gov/users/spalmer/Board%20Notes%20August%202005.pdf, last
accessed September 23, 2007.
24
See United States Department of Agriculture. “School Meals, USDA Food and Nutrition Service,”
http://www.fns.usda.gov/cnd/, last accessed September 23, 2007.
25
See United States Department of Agriculture. Federal Costs of School Food Programs,
http://www.fns.usda.gov/pd/cncosts.htm. Costs for 2006 of US$10,249 million were multiplied by the Canadian
exchange rate of $1.0252 (September 4, 2007), for a total of US$10,507 million, then divided by 49.5 million, the
total number of children enrolled in elementary and high school in the US in 2003; see "School Enrollment
Surpasses 1970 Baby-Boom Crest, Census Bureau Reports," Press Release, US Census Bureau News, June 1, 2005,
http://www.census.gov/Press-Release/www/releases/archives/education/005157.html, last accessed September 23,
2007.
26
See Assessment of Provincial/Territorial Government Support for School Food Programs (as at May 2006),

15. 6
government spent $14 million in 2005-06). The average provincial/territorial subsidy per
student in 2005-06 was just $5.95. If non-profit support is subtracted, this leaves just $5.54 per
student in public funding to support school meal programs across Canada – 38 times less than US
federal government funding per student (see Appendix 5).
Chart 1:
US federal government and Canadian federal, provincial and territorial government
financial investments in school meals, 2005-06 (Canadian $ per student)
0 50 100 150 200 250
BC [23.48]
AB [0]
SK [8.52]
MB [0.54]
ON [4.00]
QC [1.62]
NS [6.88]
NB [10.67]
PEI [8.93]
NL [6.29]
YK [7.69]
NWT [0]
NU [0]
CAN FED AVG [0]
P/T AVG [5.54]
US FED AVG [212.26
British Columbia has recognized the importance of subsidies to ensuring that children eat
healthy and nutritious food: the province’s fruit and vegetable snack program is a promising
example of public dollars providing nutrient-rich foods to ensure a healthy school food
environment. The program provides one serving of vegetables or fruit twice per week to
children at participating schools. A recent expansion will enable up to 50 schools across the
Breakfast for Learning, http://breakfastforlearning.ca/english/images/provincial_territorial_gov-
supp_may_2006.pdf, last accessed September 23, 2007.

16. 7
province to join the program, and by 2010 the province hopes to make the program available to
all schools.27
Several options for school feeding programs (scope and level of investment required) are
outlined within the Children’s Health and Nutrition Initiative (CHNI), supported by a broad base
of diverse stakeholders. The initiative calls for a nutritious breakfast, snack, or lunch to be
available to any Canadian child under age 19 through nutritious food programs. Under the
proposal, universal access regardless of circumstance is recognized as a critically important way
to ensure that all children receive nutritious food in a non-stigmatizing way. This is particularly
important to the school-aged children among the 1.2 million children who live in poverty,
according to Campaign 2000. Many of those kids rely on food banks and often go to school
hungry with a compromised opportunity to learn. In the words of one child quoted within the
Campaign's 2006 Report Card on Child and Family Poverty in Canada, poverty is “pretending
that you forgot your lunch.” Rates of child poverty are especially acute among people with
disabilities, racialized communities, aboriginal and First Nations people, and single parent
(usually female-headed) households.28
The CHNI also calls on the federal government to invest in expanding pre-existing programs
and stimulate efforts where independent programs do not yet exist. The initiative also urges the
federal government to develop program standards for healthy foods, with an emphasis on
nutrition education, cooking and growing skills, and inclusion of locally and sustainably sourced
foods. Long-term monitoring and evaluation of standards and implementation are regarded as
essential to the success of a school feeding program.
CHNI has estimated the annual investment required to provide all children aged 4-18 years
(6.1 million) with breakfast for 190 days of operation to be $1.76 billion, about $1.50 per child
daily, a cost that could be shared among federal provincial and municipal governments (e.g, the
City of Toronto now contributes $2.8 million to its city program), and parents, where possible.29
Ultimately, the goal of a school nourishment program should be to provide one-third of the
recommended intake of nutritious foods as recommended by federal dietary advice, including
Canada’s Food Guide (2007).
Sound nutrition standards and subsidies for nutritious school meals should work together to
ensure the healthy choice is the easy choice for students. Pricing is also critically important to
27
See “Expansion of School Fruit and Vegetable Snack Program” and “Over 70 Fridges in B.C. Schools,”
Backgrounder, Ministry of Tourism, Sport and the Arts, Government of British Columbia, January 22, 2007,
http://www2.news.gov.bc.ca/news_releases_2005-2009/2007TSA0005-000034-Attachment1.htm, last accessed
September 23, 2007.
28
See Campaign 2000. 2006 Report Card on Child and Family Poverty in Canada. This estimate was derived using
data from Statistics Canada and the Canadian Economic Observer,
http://www.campaign2000.ca/rc/rc06/06_C2000NationalReportCard.pdf
Last accessed September 23, 2007.
29
See Total Cost of Providing Breakfast to School Aged Children in Canada for the Entire School Year,
http://breakfastforlearning.ca/english/prog_events/pdfs/Federal%20Grant%20Analysis%202.pdf.

17. 8
ensuring a healthy diet for school children. As noted by the Ontario Society of Nutrition
Professionals in Public Health in its 2004 report on the school nutrition environment in that
province:
Healthy foods such as salads, sandwiches, and muffins,30
are more
expensive than french fries, hamburgers, and cookies. Students say
they are choosing freshly baked chocolate chip cookies for breakfast
from the cafeteria because they are cheap (three cookies can be
purchased for the price of one muffin).31
Similarly, as noted by Ostry et al. in their 2007 review of food sales, availability, and the
extent of nutrition policy implementation in British Columbia schools, “price can have an impact
as well, as healthier options often cost more than ‛junk’ foods. When faced with price reductions
on healthy foods such as fresh fruit or baby carrots, students tend to choose these options over
traditional high-fat snack foods.”32
Despite the familiar rejoinder that education is an exclusive provincial responsibility,
school foods are not the exclusive domain of provincial ministers of education. While the
provinces have broad (but not exhaustive) powers to manage the affairs of schools, the federal
government has long had broad, undisputed authority to regulate the food supply throughout
Canada. Also, Supreme Court jurisprudence makes it clear that both levels of government have
broad concurrent authority over health protection, nutrition, food safety, child protection, and
consumer protection that courts would be reluctant to limit. And the federal government has
virtually unlimited legal authority to establish nutrition standards by exercising its spending
power through conditional grants (see Appendix 6); assertions by the federal government that it
has no authority to act should be regarded with skepticism. Federal government subsidies for
school food programs that ensure Canada's children receive at least a third of their daily intake
(during the school week) of whole grains, vegetables, and fruits as recommended by Canada's
Food Guide (see Appendix 4) could help reach vital population health objectives.
30
Note: The healthfulness of muffins varies depending on their content of saturated fat, sodium, and whole grains.
31
Ontario Society of Nutrition Professionals in Public Health. Creating a Healthy School Nutrition Environment,
March 2004, p. 18, http://www.osnpph.on.ca/pdfs/call_to_action.pdf, last accessed September 23, 2007.
32
K. Rideout, R. Levy-Milne, C. Martin, A.S. Ostry. “Food Sales, Food Availability, and the Extent of Nutrition
Policy Implementation in Schools in British Columbia,” Canadian Journal of Public Health, 98(4), July/August
2007, p. 249, http://www.cpha.ca/en/cjph/articles/ABS098N04.aspx#1007 (abstract), last accessed September 23,
2007. S. French. Pricing Effects on Food Choices," J. Nutr., 133, March 2003, 841S-843S,
http://jn.nutrition.org/cgi/reprint/133/3/841S.

18. 9
IV. Overview of provincial nutrient criteria for school foods
Many dedicated health and education professionals work in schools, municipal public
health units, government departments, and other public institutions to enhance nutritional
opportunities for children at school. Similarly, committed non-profit organizations, such as
Breakfast for Learning, support the delivery of child nourishment programs to feed thousands of
Canadian children.33,34
However, we must ask whether school nutrition criteria—in jurisdictions where they
exist—are adequate to protect children’s health. Unfortunately, the answer appears to be no.
Surveys of school food service in several provinces and one national survey conducted from
2000 through 2006 reveal that a disturbing amount of foods high in fat, salt, and sugar are
available for sale to students.35,36,37,38,39
(See Appendix 1.) For example:
• A 2005 survey by the British Columbia ministries of education and health noted that
“the most common foods available in cafeterias were pastries/cookies.”40
Ostry's
review of school foods in that province concluded that “‛junk’ foods were widely
available in elementary, middle and secondary schools through a variety of outlets.”41
33
See: Joint Consortium for School Health Secretariat. An Environmental Scan of Activities Related to Schools
and Nutrition, 2006 (updated by the Canadian Association for School Health February 2007),
http://www.safehealthyschools.org/NutritionandSchools.pdf, last accessed September 23, 2007. Child nourishment
programs exist in all provinces and territories, often in partnership with Breakfast for Learning, which is the only
national non-profit organization exclusively dedicated to supporting child nutrition programs in Canada; see in
particular. pp. 16-18, 26.
34
See, for example, the Breakfast for Learning website, http://www.breakfastforlearning.ca/, last accessed
September 23, 2007.
35
Coalition for School Nutrition. Key Findings, Survey of Food and Nutrition Policies and Services in
Newfoundland Labrador, 2000, http://www.nlta.nf.ca/HTML_Files/coalition/findings.html, last accessed September
23, 2007.
36
Ministry of Education and Ministry of Health, Government of British Columbia. School Food Sales and Policies
Provincial Report, 2005, http://www.bced.gov.bc.ca/health/sales_report.pdf, last accessed September 23, 2007.
37
Dr. Shawna Berenbaum. Nutrition in Saskatchewan Schools: Policy, Practice and Needs, April 2004,
http://ww1.heartandstroke.sk.ca/Images/English/SK-Nutrition-Report-April-2004.pdf, last accessed September 23,
2007. (Prepared for the Heart and Stroke Foundation of Saskatchewan.)
38
Ontario Society of Nutrition Professionals in Public Health. Creating a Healthy School Nutrition Environment,
March 2004, http://www.osnpph.on.ca/pdfs/call_to_action.pdf, last accessed September 23, 2007.
39
Department of Health, Government of Manitoba. Manitoba School Nutrition Survey, 2006,
http://www.gov.mb.ca/healthyschools/foodinschools/documents/survey.pdf, last accessed September 23, 2007.
40
School Food Sales and Policies Provincial Report, 2005, p. 5.
41
“Food Sales, Food Availability, and the Extent of Nutrition Policy Implementation in Schools in British
Columbia,” op.cit.

19. 10
• A 2004 review prepared for the Heart and Stroke Foundation of Saskatchewan found
that “vending machines typically serve pop, chips/chocolate bars, candy and juice.”42
• A 2006 review by the Manitoba Department of Health noted that 49% of the schools
surveyed sold products from restaurants (31% from local pizza restaurants and 18%
from fast food chains).43
• A 2004 survey of school foods in Ontario found that food offered for “special food
days” include hot dogs, potato or nacho chips, pop, cookies, milk (chocolate and
white), fast food restaurant items (e.g., burgers, cheeseburgers, french fries, ice cream
bars, fried chicken, sub sandwiches), chili, pasta, chocolate bars, Rice Krispies
Squares, water, and ice cream/sherbet.44
• A 2000 review of foods available in schools in Newfoundland for the Coalition for
School Nutrition found that “in those schools with canteens, the most commonly sold
foods are ice cream and potato chips.”45
While most of these surveys were completed before many school nutrition criteria were
introduced, The Globe and Mail still concluded in January 2007, after conducting its own
national survey of school boards in early 2006, that most Canadian schools are “nutritional
wastelands.”46
Reliance by publicly funded schools on profits from commercial food sales to fund
programs and activities—a phenomenon noted in The Globe and Mail survey as well as some
provincial surveys—is plainly contributing to the problem. A 2004 survey of schools by the
Canadian Teachers’ Federation, the Canadian Centre for Policy Alternatives, and la Fédération
des syndicats de l'enseignement found that 16% of all schools reported a marketing arrangement
with Coke, 11% had a similar arrangement with Pepsi, and 6% participated in Pizza Hut’s “Book
It!,” a program that provides for educational materials while encouraging pizza consumption.47,48
According to the survey, the average amount of money raised from food and non-food-related
42
Nutrition in Saskatchewan Schools: Policy, Practice and Needs, p. 4.
43
Department of Health, Government of Manitoba. Manitoba School Nutrition Survey, p. 9.
44
Creating a Healthy School Nutrition Environment, p. 18.
45
Survey of Food and Nutrition Policies and Services in Newfoundland Labrador.
46
Caroline Alphonso. “Nutritious fare is tough sell in schools,” The Globe and Mail, January 20, 2007, p. A7.
The survey assessing a variety of factors influencing health was sent to 139 school boards across Canada at the end
of the 2005-06 academic year. Seventy-four boards responded.
47
See Commercialism in Canadian Schools: Who's Calling the Shots? op.cit.
48
Note that in the 2005 Integrated Pan-Canadian Healthy Living Strategy, health ministers undertook to develop
school nutrition standards “as part of comprehensive school health efforts.” While this was a step in the right
direction, this strategy was released before the 2007 IOM school food standards, and therefore provincial nutrition
standards need to be updated. Secretariat for the Intersectoral Healthy Living Network, F/P/T Healthy Living Task
Group, F/P/T Advisory Committee on Population Health and Health Security. Integrated Healthy Living Strategy,
October 22-23, 2005, p. 36, http://www.phac-aspc.gc.ca/hl-vs-strat/pdf/hls_e.pdf, last accessed September 23, 2007.
Reliance on the sales of foods of low nutritional value to fund school activities is inconsistent with that mandate.

20. 11
sources was approximately $16,000 per English-speaking school and $13,500 per French-
speaking school (though some schools raised hundreds of thousands of dollars), and school staff
and students reportedly played a much bigger role in fundraising decisions than provincial
governments or school boards.
Since 2005, school nutrition criteria (see Appendix 2)49
have been established in every
province except Alberta (where they were released in draft form in July 2007 and are undergoing
consultation until October 31, 2007) and Quebec (where they will come into force in 2008).
However, the Yukon,50
the Northwest Territories,51
and Nunavut52
—jurisdictions with the
greatest need and the highest federal presence—have no school nutrition criteria.
This report assesses provincial nutrition criteria for fats, sodium, added sugars, and
calories/serving sizes for food offerings within schools by measuring those criteria against the
benchmarks set by the US Institute of Medicine’s report: Nutrition Standards for Foods in
Schools. Provincial governments set out nutrition criteria in documents variously called
guidelines, standards or policies; it is often unclear whether these are truly binding requirements
for schools, or simply roadmaps offered to educators that volunteer to address the issue.
All provincial school nutrition criteria are based, to some extent, on the Canada's Food
Guide (1992)53
food groups: grains, vegetables and fruit, milk and milk products, and meat and
alternatives or, in the case Quebec and Alberta, the food groups in the 2007 edition of the
Guide.54
However, since most of these policies were developed, the Guide was revised; a new
edition with school-age-appropriate dietary advice was released earlier this year. The IOM
49
Guidelines in Ontario, New Brunswick, and Prince Edward Island were released prior to the Healthy Living
Strategy. Some provincial policies, e.g., Nova Scotia’s, are to be phased in over time.
50
The Yukon Ministry of Education does have a policy (#1023) concerning the school sale of home-prepared foods
to the public; see: http://www.education.gov.yk.ca/policy/policy_prepared_foods.pdf, last accessed September 23,
2007. Other activities such as “Drop the Pop” encourages Grades K-12 to make healthier drink choices and
“Healthy Eating Resources for Yukon Schools” is designed to help children grades K through 8 build and maintain
healthy habits with diabetes prevention in mind. But currently no nutrition guidelines exist for food and beverages
sold and/or served within Yukon schools. See An Environmental Scan of Activities Related to Schools and
Nutrition, op.cit, pp 5, 15, 21.
51
School nutrition guidelines are being developed by regional school boards within the Northwest Territories. In
preparation for this, a school nutrition survey was developed for the fall of 2006 and coordinated by the NWT
Departments of Health and Social Services and Education, Culture and Employment. The NWT also participates in
the “Drop the Pop” campaign. See An Environmental Scan of Activities Related to Schools and Nutrition, pp 4, 15.
52
Like Yukon and the NWT, Nunavut also participates in “Drop the Pop” but has yet to develop school nutrition
guidelines. See An Environmental Scan of Activities Related to Schools and Nutrition, p. 15.
53
Canada's Food Guide was revised earlier in 2007. As such, with the exception of Alberta's draft guidelines and
Quebec's new standards, provincial nutrition policies, standards, and guidelines are based on the previous iteration
of the Guide (1992).
54
Some provinces such as British Columbia include additional food groupings such as nuts and seeds, mixed
entrées, soups, candies and chocolates, energy bars, beverages (milk-based, juice-based, and other kinds), and
condiments and add-ins.

21. 12
released new specific guidelines for school foods in 2007 as well. These developments beg a
reconsideration of existing provincial school food criteria that were developed prior to the
publication of these key benchmarks.55
Efforts shown in some provincial policies to promote better nutrition education in the
curriculum are laudable, but these must be supported by applying sensible nutrition standards to
foods actually distributed on school grounds. The true measure of schools’ commitment to
nutrition is what they are actually feeding students. Because there is so little evidence about
food consumption at school—and even that evidence is discouraging—monitoring the actual
menus and consumption at school is a vital part of government’s political commitment to
ensuring school food service providers apply what public health authorities and nutrition
educators recommend.
With the exception of Ontario and Quebec’s guidelines, all provinces group food
offerings within schools according to their perceived health benefit. The healthiest foods are
grouped under “maximum nutrition” or “choose most” (to be served the most often, e.g., daily).
Foods that may have some health benefits, but are higher in fat, sodium, or sugar are grouped
under categories such as “moderate nutrition” or “choose sometimes” (definitions of which vary
widely). Nutrient-poor foods high in fat, sodium, or sugar are grouped under “minimal
nutrition” or “choose least” (definitions of which also vary widely). By contrast, under the IOM
approach, it is rarely justifiable for schools to sell health-eroding foods to children.
Some aspects of provincial school nutrition criteria could—if followed and enforced—
help improve the diets of Canadian children and youth in school. For example:
• In 2004, Ontario called on school boards to “restrict the sale of all food and beverage
items in elementary school vending machines to those that are healthy and nutritious.”56
• Quebec's recently announced guidelines aim to remove some of the worst junk food
from schools, such as soft drinks and french fries, by 2008.
• By 2008, British Columbia aims for foods in the “not recommended” and “least
recommended” categories to be eliminated from school offerings (January for
elementary schools and September for middle and high schools).57
• New Brunswick’s policy claims to ensure that only foods of moderate and maximum
nutrition be sold in elementary schools cafeterias, vending machines, etc. As of
September 2007, this stipulation also applies to middle and secondary schools.58
55
Alberta's draft guidelines and Quebec's guidelines were released after the release of the new Food Guide in
January 2007 and the IOM standards in April 2007.
56
See Policy/Program Memorandum No. 135, Healthy Foods and Beverages in Elementary School Vending
Machines, Ministry of Education, Government of Ontario, October 20, 2004,
http://www.edu.gov.on.ca/extra/eng/ppm/135.html, last accessed September 23, 2007.
57
See “BC sets national standard in promoting student health,” Press Release, Ministry of Education, and Ministry
of Tourism, Sport and the Arts, Government of British Columbia September 4, 2007,
http://www2.news.gov.bc.ca/news_releases_2005-2009/2007EDU0113-001078.htm, last accessed September 23,
2007.

22. 13
• Nova Scotia requires school boards to report progress on implementation.59
Some provinces appear to have made noteworthy progress toward ridding schools of
unhealthy food choices. For example, in Nova Scotia, preliminary indications are that soda pop,
chips,60
frozen novelties, and other minimally nutritious foods have been removed from
schools.61
In addition, the province has hired nine new public health nutritionists.62
However, despite some particular strengths of certain provincial school nutrition criteria,
such criteria in Canada—where they exist—comprise a patchwork quilt of often weak,
inconsistent guidelines. To compare provincial school nutrition criteria to one another, as well
as to appropriate benchmarks for healthy school eating, this report assigns a grade to each
provincial program. We graded provincial nutrition criteria for school foods as follows:
Chart 2:
School Nutrition Policy Report Card (Summary)
Province/Territory Grade
British Columbia D
Alberta (draft guidelines) B
Saskatchewan F
Manitoba D
Ontario F
Quebec D
New Brunswick D
Nova Scotia C
Prince Edward Island F
Newfoundland and Labrador C
Nunavut No Standards
Northwest Territories No Standards
Yukon No Standards
Explanation of Letter Grades
Letter Grade: Numeric Score: Percentile Score:
A 16 - 20/20 80 - 100%
B 14 - 15.5/20 79 - 70%
C 12 - 13.5/20 60 - 69%
D 10 - 11.5/20 50 - 59%
F 0 - 9.5/20 0 - 49%
58
Personal communication with Department of Education, Policy and Planning Division staff, September 11, 2007.
59
Personal communication with Department of Health Promotion and Protection staff, May 3, 2007.
60
“Nutritious fare is tough sell in schools,” op.cit. The Globe and Mail surveyed a handful of school boards in that
province.
61
Personal communication with Department of Health Promotion and Protection staff, May 3, 2007.
62
Ibid.

23. 14
The grading scheme for provincial school nutrition criteria measures what provincial
government policies declare to be optimally nutritious foods (variously called “maximum
nutritional value,” “choose most,” etc) against the benchmarks established by the standards for
calories, fats, sodium, and sugars set out in the April 2007 IOM Report.
In addition to the IOM report, the following sources were also used as interpretative aides
to evaluate the adequacy of provincial criteria that use serving sizes as proxies for calorie limits:
• Standards for calories as recommended by the US National Alliance for Nutrition
and Activity63
(NANA); and
• Standards for portion sizes as recommended in the 2007 edition of Canada’s
Food Guide.
The April 2007 IOM school food standards are designed to apply to individual foods and
entrées. However, existing Canadian provincial school nutrition criteria focus almost
exclusively on individual foods; 64
only three provinces, Saskatchewan, Ontario, and Quebec
even contemplate complete meals in their guidelines.65
Nutrition standards established by the US Department of Agriculture (USDA) for school
meals are particularly out-of-date in regards to limits on sodium, trans fats, and added sugars.66
63
The IOM standards include calories thresholds [200] for single foods and à la carte entrées [400], but do not
include calorie ranges for full meals. Calories ranges recommended by the National Alliance for Nutrition and
Activity could be used to set calorie limits for meals. They are: breakfast, grades K-5: 350-550; grades 6-8: 400-
550; grades 9-12: 500-700; lunch, grades K-5: 460-730; grades 6-8: 530-730; grades 9-12: 660-920. See NANA
letter to Secretary of Agriculture Mike Johanns, January 24, 2005, at:
http://www.cspinet.org/nutritionpolicy/nanaDGA_schoolmeals.pdf , last accessed September 23, 2007.
Accordingly, calorie ranges recommended by the National Alliance for Nutrition and Activity are used to judge
calorie thresholds for meals where provincial criteria are set-out for meals since a meal may include an entrée, a
drink, a dessert, etc. Calorie ranges, where applicable, are noted within Chart 3.
64
The IOM’s nutrition criteria could theoretically be applied to such food-specific standards. For instance, IOM
limits for fat and added sugars are prescribed as a percentage of total calories, so these could be applied to meals.
Similarly, IOM limits for sodium are designed to apply to both single foods as well as à la carte entrée items; so,
these standards could, theoretically, be used to evaluate whole meals by examining each food element of the meal,
e.g., the drink, side-dish, and entrée.
65
Saskatchewan's policy states that “A meal should contain at least 1 serving from each of the 4 food groups of
Canada's Food Guide to Healthy Eating [grains; vegetables and fruit; milk products; meat and alternatives].”
Ontario's policy states that “A meal (i.e., breakfast and lunch) should contain at least one serving from a minimum
of three out of the four food groups of Canada’s Food Guide with at least one serving from the Vegetables and Fruit
food group and at least one serving from the Milk Products food group.” However, there are no stipulations within
any provincial policy beyond this (no nutrient criteria, limits, or thresholds) for school meals. Quebec's guidelines
require that meals be composed of the four food groups of Canada's Food Guide (2007).
66
While the results are “weak and mixed,” current USDA guidelines for school nutrition programs appear to
improve some dietary outcomes, e.g., lower calories, lower prevalence of vitamin C deficiency, but worsen other
dietary outcomes, e.g., higher fat and saturated fat intakes, low vitamin E and A and iron. See Jayanta
Bhattacharya, Janet Currie, and Steven J. Haider. Evaluating the Impact of School Nutrition Programs (Final
Report), Economic Research Service, USDA, July 2004, p. 20,

24. 15
The USDA has acknowledged that its meal standards will be revised over the next several years
to better comport with the 2005 US Dietary Guidelines for Americans.67
V. How provincial nutrition criteria were rated
In comparing the provincial polices to the April 2007 school nutrition standards
recommended by the IOM for fats, sodium, added sugars, and calories,68
the highest a province
could score is five points per nutrient, for a total of 20 points. Demerit points were assigned
according to the degree to which the criteria were inconsistent with the IOM standards. For
example, if a province sets no limits whatsoever for sodium, it received “0” out of five points. If
a province has weak sodium limits, then it received a low score depending how much higher the
sodium limits are than the IOM standard or how many types of high-sodium foods are exempted
from the limit. And if a province has good criteria across all food groups for sodium, then it
received a score closer to five.
One demerit point for each nutrient standard was assigned to provincial criteria that
categorize food choices according to “maximum,” “moderate,” and “minimal” nutrition or any
similar categorization. (All except Ontario and Quebec present their criteria in this way.) That
practice significantly undermines the stricter criteria for “maximum nutrition” foods by allowing
foods of low nutritional value to be sold to children a portion of the time or as a percent of
choices. British Columbia, New Brunswick, and Newfoundland and Labrador criteria were
penalized somewhat less for this practice since these jurisdictions have either eliminated the
“minimally nutritious” food category (NB), will soon eliminate this category (BC, along with
“not recommended foods”), or only ever permitted “maximum nutrition” and “moderate
nutrition” foods within their criteria (NL). (It should be noted here that foods called “moderately
nutritious” within several jurisdictions are in fact nutrient-poor; see below.)
These ratings are limited in that they do not address the adequacy of provincial policies to
promote the consumption of whole grains, vegetables and fruit, and other healthy foods.
Instead, the IOM standards are designed to act as a barrier to distributing nutrient-poor foods in
school. Keeping junk foods away from children in school is important but, as noted earlier,
ensuring that students consume healthy food can best be achieved by government subsidies for
http://www.ers.usda.gov/publications/efan04008/efan04008.pdf, last accessed September 23, 2007. A more recent
USDA study found that children who consume mainly National School Lunch Program food report “a higher intake
of most nutrients, milk, fruits, and vegetables and lower intakes of sweetened beverages and candy than students
who consumed mainly non-NSLP food, including à la carte items, food from vending machines, and food from
home.” However, “students in the ‛mainly NLSP’ group also consumed more sodium, fat, and saturated fat . . . and
calorie intake was also higher for this group, although it was only 80 percent of the NSLP requirement for calories
served at lunch.” See Karen Cullen, Kathy Watson, and Issa Zakeri. Middle School Student Lunch Consumption:
Impact of National School Lunch Program Meal and Competitive Foods, June 2007,
http://www.ers.usda.gov/Publications/CCR30/, last accessed September 23, 2007.
67
USDA. “Johanns discusses USDA nutrition goals during National Nutrition Month.” News Release, March 26,
2007, http://www.fns.usda.gov/cga/PressReleases/2007/PR-0075.htm, last accessed September 23, 2007.
68
As noted above, the NANA suggested ranges for calories for meals, and the portion sizes recommended under the
2007 version of Canada’s Food Guide were also used as interpretive aids.

25. 16
truly nutritious fare like vegetables, fruits, whole grains This aspect of school nutrition is not
included in the grading scheme, however, considering the extremely low level of provincial
government subsidies across the board, all provinces would fare very poorly if the adequacy of
school food funding for healthy food comprised a significant part of the report card evaluation.
The following table on pages 17-18 indicates an overall grade for each province’s school
nutrition criteria. No province received an “A” since no policy is entirely consistent with the
IOM standards. Only one province (Alberta) received a “B”; two provinces (Nova Scotia and
Newfoundland and Labrador) received a “C”; four provinces (British Columbia, Manitoba,
Quebec and New Brunswick) received a “D”; and three provinces (Saskatchewan, Ontario, and
Prince Edward Island) received an “F.” The three northern territories received “No Standards”
since they have not issued policies.
Some provincial school nutrition criteria include measures that could—if followed—help
enhance the diets of Canadian children. But with some exceptions, provincial criteria also suffer
from a number of serious weaknesses. These results speak to the pressing need to examine and
enhance school nutrition criteria across Canada to ensure that Canadian children, wherever they
live, have access to healthy and nutritious food while in school.
VI.Weaknesses of provincial nutrition criteria
Specific flaws within provincial school nutrition policies include:
• Weak policies that permit the frequent sale of nutrient-poor foods
Our grades for provincial school food criteria are based on a comparison of the nutritional
values of foods that are to be served most under those programs (known as “maximum nutrition
foods,” “choose most,” or a similar name) with the April 2007 IOM core nutrient standards
concerning calories, fats, sodium, and sugars. However, all provinces except Ontario and
Quebec group foods into “maximum nutrition,” “moderate nutrition,” and “minimal nutrition”
categories (or similar categories).
For example, while British Columbia's guidelines require that “choose least” foods
comprise less than 10% of available choices (i.e., not 10% of sales volumes), there is no
mechanism to ensure that students would not simply choose these 10% of possibilities more
often than the more healthy choices comprising 90% of possible choices. Limiting to 10% the
number of “minimally nutritious” menu items available on any given school day is certainly no
guarantee that such foods will comprise 10% of a child’s diet at school.

26. 17
Chart 3:
How Provincial School Nutrition Standards
Stack Up Against IOM Core Nutrient Standards
INSTITUTE OF MEDICINE
STANDARD
FAT
• Total fat: ≤ 35% of total calories
• Saturated fat: <10% of total calories
• Trans fat: ≤ 0.5g per serving
• Milk: ≤1% milk fat (MF)
SODIUM
• ≤ 200 mg/serving
• ≤ 480 mg/entrée
SUGARS
(Excl. sugar from fruit and dairy.)
• Total sugar ≤ 35% of total calories
• Yogurt: ≤ 30g/8 oz.
• Milk: ≤ 22g/8 oz.
• Elementary: water w/o flavouring,
additives or carbonation
• High school: uncaffeinated, unfortified
beverages with < 5 calories/serving.
CALORIES/
SERVING SIZES
• ≤200 calories, single
foods
• ≤400 calories, à la
carte entrée items
• Juice: ≤4 oz. for
elementary/middle
school and ≤ 8 oz. for
high school
BRITISH COLUMBIA: 11/20
GRADE: D
Sale of “choose
sometimes,” “choose least”
and “not recommended”
foods with weak controls
(e.g., “minimally
nutritious” food as ≤ 10%
of choices) undermines
stricter criteria. This
weakness is mitigated by
the planned elimination of
“choose least” and “not
recommended” foods by
2008. This policy is very
complicated and, even with
strong nutrition criteria,
difficulties interpreting the
policy would likely impede
compliance.
2 out of 5 Points:
• Weak or no fat limits in most food
groups, e.g., 14.9 g for grains, vegetables
and fruit; 12 g of saturated fat in mixed
entrees and 5 g in grains; 14.9g of total
fat in soups, 15 g in milk and allows 2%,
3.25% milk and up to 20 g in other dairy,
e.g., cheese; up to 12g fat per 60g
serving for meats and alternatives; and
high-fat condiments permitted in the
"choose most" category.
3 out of 5 Points:
• Good sodium limits for
other beverages (50
mg), vegetables and
fruit (150 mg), nuts
and seeds (200 mg),
energy bars (200 mg),
and milk-based
beverages (200 mg).
• Higher sodium limits
for milk-based foods
(300 mg), meat (375
mg), mixed entrees
(750 mg); high-sodium
condiments in the
"choose most"
category.
3.5 out of 5 Points:
• Strong, but sometimes confusing (and
perhaps lax) sugar limits for grains (up to
16 g if fruit is the 1st or 2nd ingredient);
“Choose Most” sugar criteria may be
more lenient on sugar in foods with less
fruit (i.e, 28g per serving); no artificial
sweeteners.
• Strong sugar limits for milk-based foods
(20 g/175 mL) and beverages (20g/250
mL); no artificial sweeteners.
• Allows up to 8g sugars/250 mL of non-
fruit, non-milk beverages if fortified with
calcium; no added sugars if calcium <
20% of DV.
• Sugars may not be even the 2nd
ingredient and no artificial sweeteners
for vegetables and fruit.
• Sugars are neither the 1st nor 2nd
ingredient for nuts and seeds; no
artificial sweeteners.
• Sugar-free gum and mints allowed
2.5 out of 5 Points:
• Sets explicit, though
high, calorie limits for
most food groups, e.g.,
300 for energy bars,
400 for milk-based
foods, grains, nuts and
seed mixes or bars, 600
for milk-based
beverages, and 1,000
for mixed entrees.
• Some reference to
serving sizes, e.g.,
175mL for milk-based
foods, 250 mL for
milk-based beverages.
ALBERTA
(DRAFT):×
14.5/20
GRADE: B
Sale of “choose sometimes”
and “choose least often”
foods with weak controls
undermines stricter criteria;
e.g., dozens of foods listed
under “minimally
nutritious” foods (allowed
weekly) are high in fat,
sodium and sugar. To its
credit, the draft policy aims
to apply to all schools,
childcare facilities,
recreation centres, etc.
3.5 out of 5 Points:
• Good criteria for saturated fat (no more
than 2g), trans fat (0g), and total fat (no
more than 35% of total calories from
fat). (However, some suggested foods
may not meet these criteria—e.g., some
cheeses—and send conflicting signals to
food service operators.
• Weak fat limits for some milk products
(e.g., 2% milk).
3.5 out of 5 Points:
• Good criteria for
sodium for single
foods (no more than
200 mg/packaged
portion), but no
distinction between
single foods and
entrées.
• But some suggested
foods may not meet
this threshold (e.g.,
mixed dishes, cheese)
and send conflicting
signals to food service
operators.
4 out of 5 Points:
• Good criteria for sugar (no more than
35% of total calories from sugar).
3.5 out of 5 Points:
• Serving sizes as per
Canada's Food Guide
(2007)
• Reference amount
serving sizes as per
nutrition labelling
regulations also listed.
• No calorie ranges
listed.
SASKATCHEWAN:Ŧ:
5.5/20
GRADE: F
Sale of “serve sometimes”
and “serve least often”
foods with weak controls
undermines stricter criteria.
1.5 out of 5 Points:
• Little clear guidance on fats for most
foods (although lean ground meat is
recommended) under meats and
alternatives; weak fat limits for milk
products where explicit criteria is
provided (e.g., permits 2% milk); and no
limits for sat/trans fat.
0.5 out of 5 Points:
• No limits for sodium
beyond a vague overall
directive to "limit salt."
3.5 out of 5 Points:
• Strong limits on sugar for cereal (8
g/serving) and fruit (unsweetened only).
• Soft drinks (regular and diet), slushies,
sports drinks, fruit flavoured crystal
drinks, candy and chocolate and other
sugary foods are under the "serve least"
category of foods, to be served no more
than twice in a four-week period.
• No explicit sugar limits for milk prods.
0 out of 5 Points:
• No calories or serving
sizes listed.
MANITOBA: 10.5/20
GRADE: D
Sale of “serve sometimes”
and “serve rarely” foods
with weak controls
undermines stricter criteria
for “serve most” foods.
2 out of 5 Points:
• No explicit limits for saturated or trans
fat for any foods (limits are for total fat);
mention is limited to choosing grain
products without trans fat; weak fat
limits for some milk products (e.g.,
allows 2% milk), but better limits for
other products, e.g., cheese (20% MF or
approx. 10 g fat per 50 g serving).
• Modest guidance for meats and
alternatives (lean or extra lean choices)
2 out of 5 Points:
• Broad limits for
sodium in all food
groups (less than 480
per serving), which is
too high per serving of
single foods, e.g., 1
slice of bread, 1 half-
cup of vegetable juice.
3.5 out of 5 Points:
• No sugar limits for vegetables and fruit.
• Strong sugar limits for grains (12 g) and
milk products (20 g).
• Discourages consumption of energy
drinks and soft drinks.
3 out of 5 Points:
• Serving sizes as per
Canada's Food Guide
(1992).
• No calorie ranges
listed.
×
Note: Alberta's draft guidelines, released in July 2007, will undergo online stakeholder consultation until October 31, 2007.
Ŧ
Note: a number of different versions of the Saskatchewan guidelines are in circulation. The version used for this review is the four-page document that appears on the Saskatchewan
Learning website (see Appendix 2).

27. 18
PROVINCE FAT SODIUM SUGARS CALORIES/
SERVING SIZES
ONTARIO: 9/20
GRADE: F
The Ontario government’s
nutrition criteria cover only
food services provided by
community volunteers and
vending machines.
Accordingly, 1 demerit is
assigned for each nutrient
criterion since the narrow
application of these standards
leave significant portions of
the school nutrition
environment without any
nutrition standards.
2 out of 5 Points:
• Strong fat and/or saturated/trans
fat limits for most grains and
“other” foods.
• Limited guidance on fats for
vegetables, fruits, meat and
alternatives; weak limits on fats
for some milk and alternatives
(e.g., allows 2% milk) but better
limits for others (e.g., 20% MF
for cheese).
2 out of 5 Points:
• Limited guidance on sodium
for grains and none for milk
products and alternatives.
• Broad limits on sodium for
vegetables, meat and
alternatives (480 mg), which
is too high per serving of
single foods.
• Some typically high-sodium
foods are not recommended,
such as hotdogs, sausages,
bacon, and deep fried foods.
2 out of 5 Points:
• No sugar limits on milk products, or
alternatives, or any vending machine
foods and limited guidance for grains
(low-sugar cereals)
• Canned and dried fruit provided by
volunteers must not contain added
sugar.
• Some high-sugar foods are not
permitted in community feeding
programs (e.g., soft-drinks, ice-cream,
cookies, candy).
3 out of 5 Points:
• Serving sizes as per
Canada's Food Guide
(1992).
• No calorie ranges listed.
QUEBEC: 10/20
GRADE: D
While Quebec’s post-IOM
effort to rid schools of some of
the least nutritious foods
(especially soft drinks and
french fries) is praiseworthy,
its failure to specify nutrition
criteria deprives schools of
important guidance and could
lead to nutrient-poor
substitutes getting a foothold.
3 out of 5 Points:
• Guidance to avoid products
containing saturated or
hydrogenated fat, offer meat
with lower fat content, eliminate
fried foods, avoid desserts and
snacks with high fat content,
and use cooking methods
involving very little or no fat.
• But no specific limits for total
fat, saturated fat or trans fat.
0 out of 5 Points:
• Salt is hardly mentioned and
no limits for sodium are
proposed.
3 out of 5 Points:
• Emphasis on unsweetened fruit juices,
avoiding desserts and snacks with
high sugar content.
• Aims to eliminate carbonated soft
drinks high in sugar or sugar
substitutes, any drinks with added
sugar, and products with sugar or an
equivalent as the first ingredient.
• But no specific limits for sugar.
4 out of 5 Points:
• Recommendations are
based on Canada's Food
Guide (2007), which
includes serving sizes,
though these are not listed
in the guidelines.
• No calorie ranges listed.
NEW BRUNSWICK: 10.5/20
GRADE: D
Sale of “moderate nutrition”
and “minimum nutrition” with
weak controls undermines
stricter criteria for “maximum
nutrition” foods. This
weakness is mitigated by
elimination of “minimally
nutritious” foods by 2007.
2 out of 5 Points:
• Minimal or no guidance on fats
and no limits for saturated or
trans fats for grains, vegetables,
and fruit; weak fat limits for
some milk products (e.g.,
allowing 2%) and none for
others (e.g., hard cheese).
2 out of 5 Points:
• Few or no sodium limits for
grains, milk, meat, and
alternatives (only for
nuts/seeds); incomplete
criteria for vegetables and
fruits.
3 out of 5 Points:
• No sugar limits for milk and
alternatives and no explicit sugar
limits for vegetables and fruit (except
unsweetened cereals, fruit, and juice).
• Many sugary products are listed as
not recommended.
3.5 out of 5 Points:
• Serving sizes as per
Canada's Food Guide
(1992) listed within the
handbook that
accompanies the policy.
• No calorie ranges listed.
NOVA SCOTIA: 12/20
GRADE: C
Sale of “moderate nutrition”
and “minimum nutrition” with
weak controls undermines
stricter criteria for “maximum
nutrition” foods.
3.5 out of 5 Points:
• Strong limits on total, saturated
and trans fat per serving, i.e.,
3g of total fat and 2g of sat/trans
fat combined for grains,
vegetables and fruit; 5g total fat
and 4g sat/trans fat combined
for milk and alternatives; and 5g
total fat and 3g sat/ trans fat
combined for meats and
alternatives.
• But allows 2% milk.
2 out of 5 Points:
• Broad limits for sodium in
all food groups (less than
480 per serving), which are
too high per serving of single
foods, e.g., 125mL for 1 half
cup of vegetables, etc., and
high limits for entrées
(960mg).
3.5 out of 5 Points:
• Good limits for sugar in vegetables
and fruit (no added sugars) and milk
and alternatives (lower fat and
flavoured milk should contain ≤28g
total sugar per 250 mL).
• No artificial sweeteners for grains,
milk and alternatives, but no sugar
limits specified for grains.
3 out of 5 Points:
• Serving sizes as per
Canada's Food Guide
(1992), though these are
not listed in the policy.
• No calorie ranges listed.
PRINCE EDWARD ISLAND:
4.5/20
GRADE: F
Sale of “serve sometimes” and
“serve least often” with weak
controls undermines stricter
criteria for “serve most often”
foods.
1.5 out of 5 Points:
• Incomplete fat criteria for grains
and milk products.
• Weak fat limits for milk and
alternatives, e.g., allowing 2%
milk and cheese without fat
limits.
• No limits specified for
saturated/trans fat.
0.5 out of 5 Points:
• While the policy states that
foods sold or made available
at school will be "low in
salt," there are no explicit
sodium limits in any food
group except seeds and nuts
under meats and alternatives.
2.5 out of 5 Points:
• No sugar limits for milk and
alternatives.
• Unsweetened or low-sugar cereal
within the "choose most" category of
foods.
• Candy, chocolate, pop, sports drinks
sweetened fruit drinks, within "serve
least often" category (1-2 times per
month).
0 out of 5 Points:
• No calories or serving
sizes listed.
NEWFOUNDLAND AND
LABRADOR: 12/20
GRADE: C
Sale of “serve moderately”
foods with weak controls
undermines stricter criteria for
“serve most” foods. (Nutrient-
poor "moderately nutritious"
foods may comprise less than
50% of foods daily.)
2.5 out of 5 Points:
• Strong fat limits for grains (3 g).
• Very little guidance regarding
fat for vegetables and fruit
(except minimize deep-fried
french fries); weak fat limits for
some milk and alternatives (e.g.,
allowing 2% milk) but better for
others (e.g., 20% MF cheese);
no limits specified for trans fat
or saturated fats.
2 out of 5 Points:
• Broad limit of 480 mg of
sodium for all foods in
“serve most” category,
which is too high per serving
of single foods, e.g., 2 cheese
slices, etc.; a salt shaker icon
to identify potentially high-
salt foods (and if they may
be “served most”) may be
confusing; it does not appear
beside foods (e.g., bread,
cheese) often high in sodium.
4 out of 5 Points:
• Good sugar limits for milk and
alternatives (e.g., 14 g or less per 175
mL of yogurt, unsweetened milk).
• Good sugar limits for cereals
(6g/standard serving size)
• Only unsweetened fruit, juice and
fruit bars, etc. are permitted.
3.5 out of 5 Points:
• Serving sizes as per
Canada's Food Guide
(1992).
• No calorie ranges listed.

28. 19
The Government of British Columbia recently pledged to eliminate both “not
recommended” and “choose least” foods by 2008 and revised its nutrient criteria within the
“choose most” and “choose sometimes” categories. While these revisions have introduced some
improvements to the guidelines such as some lower sodium limits, the fat limit was actually
increased from 5 g to 14.9 g for “choose most” vegetables, and from 10 g to 14.9 g for grains.
“Choose most” foods still include mixed entrées with up to 750 mg of sodium, which deliver
double the amount of sodium per serving recommended under the new IOM school nutrition
standards and deliver one-third of the maximum daily intake of sodium even for an adult.69
Recently released Statistics Canada data on sodium consumption show that Canadian
children, on average, ingest approximately twice the recommended amount of sodium (largely
from processed and commercially prepared foods).70
Lax sodium limits in school food policies
in BC and most other provinces are especially troubling because “in the cultures like North
America, the lifetime risk among adults of becoming hypertensive is 90% and evidence indicates
that reducing sodium intake (and increasing potassium intake) may blunt the age-related rise in
blood pressure.”71
Similarly, Newfoundland and Labrador requires only that 50% of food offerings on a
daily basis in this province’s schools comes from the “serve most” category of foods, but there is
no guarantee that children will choose these items more often than the “serve moderately” items
higher in salt, fat, and sugar, e.g., pretzels, ice cream, bacon, chicken wings, and other unhealthy
choices.72
69
According to the IOM, the maximum daily intake for sodium for children aged 4-8 is 1,900 mg, aged 9-13 is
2,200 mg, and aged 14-18 is 2,300 mg.
70
For children aged 4-8, the Upper Limit for sodium is 1,900 mg, but children, on average, ingest 2,677 mg of
sodium per day. Older children and youth have even higher consumption levels. See Statistics Canada. Sodium
consumption at all ages. April 10, 2007, http://www.statcan.ca/english/freepub/82-003-
XIE/2006004/articles/sodium/sodiumconsumption_e.pdf, Last accessed September 23, 2007.
71
See: US Institute of Medicine, Dietary Reference Intakes for Water, Potassium, Sodium, Chloride and Sulfate,
Washington, DC: IOM, 2005, p. 354.
72
Some items have some restrictions. For example, french fries or hash browns can only be served once a week
and both cannot be served during the same week.

29. 20
These foods are considered “moderately nutritious” under some provincial
standards.
In New Brunswick, this province’s policy aims to eliminate minimally nutritious foods
by September 2007, but permits so-called “moderately nutritious” foods to be served thereafter.
According to the New Brunswick government, “moderately nutritious” foods include items high
in salt (e.g., canned noodle or rice soups, baked ham, and salted nuts and seeds), foods high in
sugar (e.g., pre-sweetened whole-grain cereals, and fruit compote with sugar added), foods high
in saturated fat (e.g., ice cream), and combination foods high in both salt and fat (e.g., cheese
pizza). Under New Brunswick’s policy, these and other low-nutrition foods can be served twice
a week to students in school. Given that several unhealthy food options are available for sale in
any given week, this could undermine restrictions on the availability of individual foods;
conceivably students could consume nothing but unhealthy foods for the entire week by eating
each unhealthy food offered only once or twice a week. Compounding this problem is the fact
that there are few unambiguous nutrient limits for any of the foods listed under Appendix A of
the New Brunswick food criteria, except for some milk products.
Similarly, even though the Nova Scotia policy claims to have eliminated some foods of
minimal nutritional value, this province’s policy still allows schools to offer whole milk (3.25%
milk fat) and high-fat cheeses. Single servings of such foods supply 25% and 50%,
respectively, of the recommended daily limits for saturated fat even for an adult’s 2,000 calorie
diet. And, at just under 960 mg per serving, the upper limit for sodium for mixed entrées allows
individual foods to contain almost half the daily maximum intake of sodium, even for an adult.
While Alberta’s draft guidelines have good criteria for fats, sodium, and added sugars
under the “choose most often” group of foods, the “choose least often” group of foods includes
dozens of options high in fat, sodium, and added sugar, including potato chips, soft drinks,
chocolate bars, candy, ice cream, cakes, cookies, deep fried foods, donuts, pastries, and whipped
cream.
Some provincial guidelines are ambiguous concerning how frequently
low-nutrition foods can be served.
However, one part of Alberta’s guidelines indicates that those foods should be limited to
“one to two servings a week,” while another states that “these foods [plural, emphasis added]

30. 21
could be consumed once a week.” The draft guidelines are, like other provincial standards,
ambiguous concerning exactly how frequently these so-called “choose least often” foods can be
served. Given the sheer number of such foods listed in the policy, it is conceivable that students
could consume many foods high in fat, sodium, and added sugar at school even if schools served
each nutrient-poor food only once per week.
Public policy should ensure that all school food offerings are healthy and not rely on the
nutritional savvy and good judgment of minors to pick the health-enhancing choice over the
health-eroding one. Nutrition criteria must be relatively strict across the board and, if non-
nutritious treats are permitted, one such food should be available only on a very limited basis
(e.g., once a month or less) and offered alongside healthy fare.
• Lack of specific guidance to food service and vending machine operators concerning
nutrient limits for permitted foods
Although most provincial school nutrition criteria provide lists of foods under the
categories of maximum, moderate, and minimally nutritious foods, several provide very little
precise nutrition criteria to aid food service operators in determining which foods are sufficiently
nutritious to feed to children. For example, in Saskatchewan’s nutrition criteria, the only
explicit nutrient limits concern fibre and sugar for cereals, milk fat for some dairy products, and
levels of real fruit or vegetable content in juices and fruit leather or bars. Similarly, the
province’s of Saskatchewan, Quebec, New Brunswick and Prince Edward Island set few, poor,
or no criteria for key nutrients such as sodium.
• Wide variations and inconsistencies among provincial food policies
While food groupings are roughly similar across provinces—likely due to the influence
of Canada’s Food Guide (1992)—the placement of various foods within specific food categories
is subject to considerable variation across jurisdictions. For example, in Manitoba, fortified soy
and rice beverages are placed under the “serve most often” category for milk products, however,
in British Columbia, some flavored soy drinks are placed under the “choose sometimes”
category. And in Newfoundland and Labrador, pepperoni sticks are listed under the “serve
moderately” category for meats and alternatives, while in Manitoba this food item is listed under
the “serve rarely.”
There is also a lack of consistency in the approach to limiting substandard food choices.
For example, British Columbia defines food availability by percentages of available choices (i.e.,
50% or more for “choose most” foods, 40-50% for “choose sometimes” foods, and less than 10%
for “choose least foods”; this will change to 50% for “choose most” foods and up to 50%
“choose moderately” foods by 2008). The Newfoundland and Labrador policy also stipulates
that more than 50% of food offered on a daily basis must come from its “serve most” category of
foods. But most provincial policies that define food availability do so in temporal terms, i.e.,
maximum nutritional value (serve most often), moderate nutritional value (serve sometimes,

31. 22
which can vary between a few times a week to a few times per month), or minimal nutritional
(serve rarely, meaning a few times a month or else not defined at all).
These practices contrast with the single set of nutrition standards recommended by the
IOM. While it is important to ensure that provincial policies meet local and regional needs, there
is no indication that discrepancies in provincial nutrition criteria for school foods reflect
geographically varying dietary needs or food supplies. Indeed, in the region of Canada with the
most unique nutrition and food system challenges—the northern territories—there are no school
food nutrition standards whatsoever.
The most serious variation among provincial school nutrition criteria is whether such
criteria apply to all foods offered within schools, and the two most disappointingly narrow
examples involve policies in Ontario and Manitoba.
In Ontario, aside from the province's vending machine policy (which only applies to
elementary schools) provincial school nutrition criteria as outlined within the document Student
Nutrition Program: Nutrition Guidelines only apply to community volunteer-driven school
feeding programs, but, conspicuously, not foods for sale in Ontario schools.73
This is an
enormous loophole that essentially means foods sold in school cafeterias, canteens, tucks shops,
etc. are not even claimed to be held to any nutrition standards.
In Manitoba, the School Nutrition Handbook provides detailed nutrient criteria to assist
schools in the development of their own policies. However, the only requirement is that all
schools must develop a policy by the end of the 2007/2008 school year; there is no requirement
that schools follow any of the Handbook’s nutrient limits for fats, sodium, added sugars, calories,
and serving sizes.74
That said, considering there is very little published data about the actual
nutritional merit of foods sold in schools throughout Canada, it is possible that even provincial
government standards purporting to apply relatively strict nutrition criteria to all foods are, in
reality, largely ignored by schools—especially without additional funding for implementation
(see recommendation #3).
Inconsistencies among provincial nutrition criteria for school foods perhaps reflect the
difficulties in formulating such standards prior to the publication of the April 2007 IOM nutrition
standards for school foods. These inconsistencies further underscore the importance of
revisiting these criteria. There should be a greater degree of consistency among provincial
policies to ensure that Canadian school children are provided healthy and nutritious foods
regardless of where they live.
73
Personal communication with staff within both the Department of Education and the Ministry of Children and
Youth Services, September 7, 10, and 11.
74
Personal communication with Department of Education staff, September 11, 2007.

32. 23
• Complete absence of school food standards in Canada's north
Canada's three northern territories have yet to adopt any nutrition criteria for schools.
The lack of standards for those jurisdictions consigns children who reside there to the luck of the
draw.
Given the significantly higher rate of diet-related illness among Aboriginal people and
the high cost of food in the north, stringent nutritional standards and adequate public funding are
urgently needed to ensure that children have access to nutritious and affordable food. The
primacy of the federal government’s role in healthcare and public health in the territories and in
First Nations communities underscores the need for federal leadership.
• Lack of publicly available information concerning compliance
Given the relative newness of provincial school nutrition policies, it is not surprising that
no formal evaluations have been completed (or at least published) for some of them. However,
given the alarming rise in the rate of childhood obesity in Canada and the capacity of our public
schools to establish and promote healthy eating among Canada's young people, public
accountability for adherence to provincial standards is critical. There is no point in having
school nutrition policies—even weak ones—if schools are not following them, and there is no
way to know if schools are following them unless provincial governments conduct surveys on a
regular basis (e.g., once a year) with meaningful benchmarks. Such evaluations should include:
assessing compliance with explicit school nutrition standards; the extent to which school food
offerings meet science-based nutrient standards (e.g., those set out in the 2007 IOM standards)
and help ensure children consume the minimum number of servings of healthy foods like whole
grains, fruits, and vegetables (as set out in the 2007 update of Canada's Food Guide); barriers
inhibiting schools from meeting such objectives; and enabling factors that have helped schools
meet such standards.
VII. Conclusion and Recommendations
Canada is experiencing an epidemic of childhood obesity and a crushing burden of diet-
related diseases across the life-span, which already exact a high price in health and economic
costs that will rise for years to come unless health, education, and food policy-makers act now.
Schools are ideal venues to help ensure future generations get a healthy start in life. While some
provincial nutrition standards for foods sold at schools are useful first steps in helping to improve
school foods, these standards fall far short of the April 2007 IOM recommendations for school
foods, and federal and provincial governments devote precious little financial resources to
subsidize the consumption of nutritious foods like fruits and vegetables.
To improve Canadian standards for foods sold in schools, we recommend that all
governments and school authorities:

33. 24
1. Develop and support the implementation of comprehensive school nutrition policies that
contain nutrition standards for all foods distributed in school and reflect Canada's Food
Guide (2007) as well as the US Institute of Medicine’s Nutrition Standards for Foods in
Schools (2007).
2. Support the establishment of a pan-Canadian school meals program that is based on
health-protecting nutrition standards and encourages healthy eating habits.75
3. Conduct regular surveillance of school food policies and guidelines, food offerings, and
student consumption measured against benchmarks.
The health of Canada's children is too important to fall sway to jurisdictional
parochialism. While responsibility for education has historically been primarily assumed by
provincial governments, the legislative and financial responsibility for nutrition, food safety,
health, public health, consumer protection, and child protection has long been exercised in
various ways by local, provincial and federal governments. School nutrition, which should
support our children's health, should be no different.
While we are cognizant of inter-jurisdictional political sensitivities, Canada's children
and youth are entitled to expect a decent standard of nutritious fare at school regardless of where
they live. The current patchwork (and, in some places, threadbare) quilt of nutrition standards
and the minuscule level of public subsidies for nutritious foods fall far short of that mark.
Governments must act quickly to ensure that schools make a positive contribution to the
nutritional well-being of children.
75
See note 1.

34. 25
Appendices

35. 26
Appendix 1:
Key Findings from Publicly Available Provincial School Nutrition Surveys
Province Author and Title of
Report
Key Findings
BC Ministry of Education
and Ministry of Health,
Government of British
Columbia. School Food
Sales and Policies
Provincial Report.
2005.
http://www.bced.gov.bc.c
a/health/sales_report.pdf,
last accessed September
23, 2007.
• Coated granola bars, pastries/cookies, and uncoated granola
bars accounted for the bulk of items available for sale in
school stores in British Columbia. Few school stores
offered “more healthy” beverage choices such as water, milk,
and 100 percent fruit drinks. (p. 4)
• The most common foods available in cafeterias were
pastries/cookies. Given that snack machines are also located
in middle and secondary schools, the concentration of “less
healthy” food choices was very high in these schools. (p. 5)
• The proportion of “more healthy” choices available in
beverage machines was low (ranging from 26 to 34%) in
elementary, middle, and secondary schools. (p. 8)
SK Dr. Shawna Berenbaum.
Nutrition in
Saskatchewan Schools:
Policy, Practice and
Needs. 2004.
http://ww1.heartandstrok
e.sk.ca/Images/English/S
K-Nutrition-Report-
April-2004.pdf, last
accessed September 23,
2007. (Prepared for the
Heart and Stroke
Foundation of
Saskatchewan.)
• Vending machines typically serve pop, chips/chocolate bars,
candy and juice. (p. 4)
• Canteens most often serve chips/chocolate bars, candy, pop,
milk, baked goods and ice cream items. (p. 4)
• Cafeterias typically serve hamburgers, hot dogs, French fries,
baked goods, juice, milk and pop. (p. 4)
MB Department of Health,
Government of
Manitoba. Manitoba
School Nutrition
Survey. 2006.
http://www.gov.mb.ca/he
althyschools/foodinschoo
ls/documents/survey.pdf
Last accessed September
23, 2007.
• The top ten foods sold in school cafeterias were chocolate
milk, sandwiches/wraps, cookies, pizza, french fries, soft
drinks, soup, 100% fruit juice, water and white milk. The
top ten foods sold in canteens and tuck shops were chocolate
milk, candy, pizza, chips, hot dogs, chocolate bars, soft
drinks, and ice-cream, 100 fruit juice and water. (p. 9)
• 49% of the schools surveyed sold products from restaurants:
31% from local pizza restaurants and 18% from fast food
chains. (p. 9)
• Very few schools sold fresh fruit or nuts in their canteens and
tuck shops. (p. 8)
• By far the most popular items sold in snack vending
machines were fried snacks (chips, cheesies, crackers) and
chocolate or yogurt-coated granola/breakfast/sports bars and
nuts bars. (p. 13)