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at the state-level, therefore, we believe that child nutrition programs should be placed in one agency and urge you to assign administrative responsibility on the Federal level to the Department of Education for several reasons.

The Department of Agriculture's child feeding programs, including the school lunch and breakfast programs, are administered in each state by State Departments of Education. One purpose of the reorganization proposal being considered today is to demonstrate the Federal government's commitment to education through the creation of an effective and efficient system for delivering quality educational services to children, youth and adults. Parallel administration of education and education · related programs on the state and Federal levels will achieve this goal by fostering their coordination and standardizing their requirements.

In Iowa, we have found that school-based programs are more efficiently administered when the education community can identify with and respond to a single agency.

For example, when a child immunization law was enacted in Iowa its implementation was assigned to the State Health Agency. The law required that local school districts gather immunization records of school-age children and forward them to the State Health Agency. The State Education Agency necessarily became involved because of its long-standing experience of working with local school districts on the collection of information, and the interpretation of state mandates and

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policies. I use this example to illustrate the point that there need to be uniform procedures for education and educationrelated programs on both the Federal and state level. This coordination can best be achieved through the SEA at the state level and through a Department of Education at the Federal level.

This experience can be applied further to the Federal child nutrition programs. Distribution of nutritional meals

to children is an important part of the total school day and the potential value of these programs as educational tools is limitless. I believe that education involves more than the activities of the classroom.

Identification of school-based

nutrition programs with other education programs, therefore, will help to make them equal partners in the child's total educational environment.

Opponents of the transfer argue that commodity support would be replaced by cash subsidies. Presently, less than 20 percent of the total Federal contribution to these programs is in the form of commodity support. Members of the education community who support the new Department of Education believe that commodity distribution should remain in U.S.D.A. and should not be undercut. The solution to this problem, however, lies in the use of interagency agreements. In Iowa, for example, the State Education Agency administers the entire feeding program and has negotiated agreements with the social service agencies, day care facilities and others. This is a sound administrative

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principle and easily could be applied to child nutrition programs

on the Federal level.

Recently, a new nutrition education program was enacted which is directly related to other education programs in the Department of Education. The program involves Federal assistance for the dissemination of curricula and materials, and the development of teacher training standards. Several programs now administered by the U.S. Office of Education include nutrition education components as well. Transfer of the U.S.D.A. education program to the proposed Department of Education will foster their coordination and stimulate even more activity in the Office of Education programs. The potential of the nutrition education program is immeasurable.

I fear, however, that administering this program outside of the new Education Department will diffuse its educational thrust and many of its future benefits will remain untapped.

I

Again, I appreciate this opportunity to present not only my views but also those of the Council to this Committee. urge your favorable consideration of the transfer of Child Nutrition programs to the new Federal Department of Education.

Senator PERCY. Thank you very much, Dr. Benton. Ms. Ullrich? MS. ULLRICH. I would like to say, as executive director of the Society for Nutrition Education, I am involved with an organization of about 5,000 professional nutritionists. I might say we have had the pleasure of talking to you, Senator Percy, on many occasions with the Senate Select Committee on Nutrition and Human Needs. We are primarily interested in providing ways to help people to make informed food choices. So our focus is directly on the education and nutrition.

You have my prepared remarks, so I thought I would just spend my time highlighting my concerns and recommendations.

I might just says, first of all, I am addressing my remarks only to the nutrition education concerns related to the proposed jurisdiction of this program, which may be moved from the USDA to the proposed new Department of Education. I also am speaking only for myself because we have not had the time to poll our executive committee of the society, but I think that my reactions do reflect the concerns of our membership.

I believe that nutrition education most logically belongs in the Department of Education, whether at the Federal, State, or local level. But there must be strong support, financially, administratively, and operationally. The present Office of Education does not provide that kind of support. As a matter of fact, in the past we have tried to identify places in which a nutrition education program might be placed in the Office of Education and at the present time we have been unable to find a suitable section.

Nutrition education should be integrated into a total educational experience and should not be a specialized, crisis, short-term, pilot project kind of program such as the drug and alcohol abuse education programs are at the present time.

Nutrition education must start as early as possible, even before the formal schooling, as well as through the elementary and secondary grades and into higher education. The child who experiences such a continuous sequential program can be expected to be a healthier adult.

Any program of nutrition education in the schools must have coordination between the classroom education and the school cafeteria, as a learning laboratory.

The program on nutrition education as a part of the School Lunch Act, funded for the very first time this year, has been very slow in receiving the funds of $28 million and establishing regulations. However, we understand full appropriations for the program have been released. The program does provide the kind of coordination between the classroom education and the school cafeteria I have suggested.

It is for this reason I am really rather reluctant to endorse efforts to start a new program and a new Department unless there can be firm guarantees that the nutrition education program in its entirety, as outlined by law, would be moved into this new Department of Education.

There also needs to be guarantees of coordination between the Department of Education and USDA to assure the interaction between the food and nutrition research and technology expertise in the USDA as well as educational programs. There should also be assurances that the nutrition education is a part of the broad food and nutrition policies developed by USDA and other depart

ments.

Of course, there also needs to be this same kind of coordination between feeding programs and education at the States and local levels. This is one reason that it may be better to have the nutrition education program in the Department of Education.

But nutrition education must be a broad training and educational program. There have already been pilot projects and the need has already been demonstrated. So I am recommending that the level of funding that should be at the same level as the existing program to provide that the program can be continued.

It is essential that regardless of where the program ends up, that it be an innovative, integrated program, which will help children to cope with the kinds of food choices that they have to make in today's environment.

Senator PERCY. Thank you very much, Ms. Ullrich. [The prepared statement of Ms. Ullrich follows:]