FOOD SAFETY REQUIREMENTS FOR SCHOOLS SCHOOL AND COMMUNITY NUTRITION May 2016

OBJECTIVES Participants will understand: Requirements related to food safety Expectations for implementation

REQUIREMENTS Health Department Inspections Food Safety Plans Training

USDA FOOD SAFETY REQUIREMENTS 2004 Child Nutrition and WIC Reauthorization Act (Implemented in 2005) 1. Established the requirement for schools to have a food safety plan based on HACCP principles. 2. Established the requirement for schools to obtain 2 health department inspections each year.

USDA FOOD SAFETY REQUIREMENTS 2004 Child Nutrition and WIC Reauthorization Act (Implemented in 2005) 3. Required that inspections are posted in a visible location to participants and available to the public upon request. 4. Established the requirement for SFAs to report annually to the SA the number of health inspections conducted at each site.

USDA REQUIREMENTS CONT. SP Responsibility to Request Food Safety Inspections September 19, Established the requirement for SFAs to request inspections when 2 inspections were not conducted at a school site. 2. Requires that the SFAs efforts to request the inspections is adequately documented.

USDA REQUIREMENTS CONT – United States Government Accountability Office 1. USDA issued more specific guidance regarding the applicability of the food safety inspection requirement for school sites that do not prepare food (service only). This is required for all sites regardless if the health department considers service only sites a “foodservice establishment or not”.

USDA REQUIREMENTS CONT Healthy Hunger Free Kids Act (Implemented in 2013) Expanded the Food Safety Plan requirements. Anywhere food is prepared, served or stored. Applicable to breakfast, lunch, special milk, the Fresh Fruit and Vegetable Program, afterschool snacks, Seamless Summer Option, Child and Adult Food Program and the Summer Food Service Program.

USDA REQUIREMENTS CONT Healthy Hunger Free Kids Act (Implemented in 2013) Professional Standards Established Food Safety Training requirement for new Child Nutrition Directors.

STATE REQUIREMENTS Level 1 Certification Training Level 1 certification required for all employees who work in school food service within the first 40 days of hire. Includes 4 hours of training related to food safety.

STATE AGENCY MONITORING SCN reviews SFAs compliance to both state and federal food safety requirements during the administrative review. SFAs annually report the number of health department inspections conducted at each of their sites.

HEALTH DEPARTMENT INSPECTIONS Each school site is required to obtain 2 health department inspections each program year. If 2 inspections have not been conducted, the SFA is required to request the inspections from the appropriate agency.

NONTRADITIONAL SCHOOL SETTINGS Domestic or Overseas Department of Defense (DOD) Schools – Request inspections from the personnel in charge of the food safety functions for the base. Non Department of Defense Schools located on domestic military bases – Request inspections from the State or local government agency responsible for food safety inspections.

NONTRADITIONAL SCHOOL SETTINGS Residential Child Care Centers (RCCI’s) – Request from the State or local government agency responsible for food safety inspections. * Even if only offering vended meals.

HEALTH DEPARTMENT INSPECTIONS Post the most recent health department inspection in an area that is visible to participants. Behind or on the serving line At the beginning of the serving line Near entrance Communication Board

HEALTH DEPARTMENT INSPECTIONS Make available to the public upon request. Available to view Make a copy Take a picture

HEALTH DEPARTMENT INSPECTIONS SFAs annually report the number of inspections conducted at each site for the prior program year in the fall. Fall 2016 – SFA’s reported the number of inspections conducted in the 2015 – 2016 SY (July 1, 2015 to June 30, 2016).

FOOD SAFETY PLANS Each school site that participates in a child nutrition program must develop and implement a food safety plan based on HACCP principles.

FOOD SAFETY PLAN Each school must have a plan even if no meals are actually produced onsite. All areas within the school where food is prepared stored or served must be included in the plan. Other areas outside of a school where food is prepared, stored or served must have a plan.

FOOD SAFETY PLAN Number of schools (approved in CNIPS) ( -) Subtract site from total if no food is prepared, stored or served there (+) Add storage areas or warehouses that is not located in one of your sites = Total number of Food Safety Plans within the district

FOOD SAFETY PLAN – REQUIRED SECTIONS Each Food Safety Plan must have all of the required written elements: 1. Operational description 2. Menu items separated into a process approach with the CCPs identified. 3. Standard operating procedures 4. Summary charts or tables 5. Plan to review and revise

SCHOOL SPECIFIC PLAN The food safety plan should be: Relevant to the school in which it is implemented Used by the staff in carrying out their daily duties Considered useful by the school staff

OPERATIONAL DESCRIPTION The operational description is information that illustrates the operations of the child nutrition program.

MENU ITEMS CATEGORIZED BY PROCESS The “Process” in the process approach to HACCP. If this is not included in the written plan, than the plan is not based on HACCP principles as required in regulation.

MENU ITEMS CATEGORIZED BY PROCESS Process 1: No Cook Process 2: Same day service Process 3: Complex

STANDARD OPERATING PROCEDURES Written description on how the food safety hazards are handled in the school.

IDENTIFYING SOPS Operational description Process charts

STANDARD OPERATING PROCEDURES Title: The name of the SOP identifies a process or policy in place to address a potential food safety hazard in the flow of the food through the school. Instructions: Step by step written instructions the staff must follow to control the potential food safety hazard the SOP is written to address. Monitoring: A description of how the staff will monitor for the food safety hazard.

STANDARD OPERATING PROCEDURES Corrective action: A description of what the staff will do if monitoring indicates there is a potential problem. Verification: A description of how the manager is going to ensure that the staff is following the SOP. Record keeping: All monitoring, corrective actions and verification must have a record keeping mechanism identified when CCPs are involved. All SOPS should have some record keeping involved in one or more of those areas.

PROTOTYPE SOPs Prototype SOPs are wonderful!!! Don’t have to start from scratch Ensures that all elements are covered Saves time and money

PROTOTYPE SOPs Edit the prototype SOP line by line: Remove what is not relevant Add what is relevant but was not included Remove the “helpful statements”

STANDARD OPERATING PROCEDURES The step by step instructions should be written in a way in which the staff knows exactly what to do. SPECIFIC AND CLEAR

STANDARD OPERATING PROCEDURES Staff training: What the food safety plan is, where it is located and that they must follow it. The SOPs that are specific to their job duties.

SUMMARY TABLES The monitoring, corrective action, verification and record keeping identified in the SOPs must be summarized into a table or chart.

SUMMARY TABLES Creates a visual of your plan that is easily referenced by staff. Demonstrates that SOPs adequately address the food safety hazards that they are written to address.

SUMMARY OF RECORD KEEPING

SUMMARY OF MONITORING AND VERIFICATION

SUMMARY OF CORRECTIVE ACTION

REVIEW AND REVISE There must be a plan in place to review all of the sections in the food safety plan each year or sooner if needed in order to revise the plan with any updates or changes.

REVIEW Operational description – Newly implement breakfast in the classroom, participation in FFVP, etc. Process Charts – Menu changes

REVIEW SOPs – Applicable updates to the operational description or process charts, changes in procedures or record keeping. Summary tables – Any changes to SOPs will most likely require a change in the summary tables.

REVIEW The written plan to review and revise must include: Who will review the plan When the plan will be reviewed How it will be documented

Thank you!

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