Julie Shelton Consultant - School Nutrition Program Wisconsin Department of Public Instruction Summer

 Added requirement that school food authorities implement a food safety program at each food preparation & service facility participating in NSLP or the SBP  Implementation date was school year beginning July 1, 2005  Program must be based on HACCP system established by USDA Secretary of Agriculture 2

 Two memoranda issued by USDA  Guidance for School Food Authorities: Developing a School Food Safety Program Based on the Process Approach to HACCP Principles, June

 “Insurance policy” for protection of customers  Compliance with food code  Continuous improvement/food quality  Saves money & time  Consultative services of environmental health specialist  Documentation to address complaints, suspected food borne illness, & legal action  Bragging rights 4

Meet “review & revise periodically” involves:  Ongoing verification of plan to determine if it is operational  Periodic validating plan to determine if the plan controls the hazards 5

 Brief review of plan components  Final regulations specific to food safety plan (January 2010)  HHFK Act of 2010/Public Law  Considerations/Issues/Concerns  Your issues/questions  Hot topics ◦ Allergens ◦ Breakfast in the classroom ◦ Farm to School  Update on available resources 6

 Develop description of site/equipment inventory  Categorize menu items as process 1, 2, 3  Identify critical control points, control measures and critical limits for items in each process  Adapt existing/develop SOPs for operation  Specify corrective action procedures  Specify recordkeeping procedures & monitoring documentation  Determine prerequisite training programs & document training to verify employee participation  Review and revise plan periodically 7

 Effective January 14, 2010  Codifies the food safety plan requirements  Addresses recordkeeping requirement  Include food safety program as part of state agency administrative reviews  Extends food safety program requirement to school breakfast program 8

 Perform a hazard analysis  Decide on critical control points  Determine the critical limits  Establish procedures to monitor critical control points  Establish corrective actions  Establish verification procedures  Establish recordkeeping system 9

Written plan for each prep/serving site must include methods for documenting:  Menu items appropriately categorized  Critical control points and critical limits  Standard operating procedures to provide a food safety foundation  Monitoring  Corrective action procedures  Recordkeeping procedures  Program Review & revision at least annually 10

 Traditional HACCP focuses on recipes  For process approach: ◦ Menu items are grouped into a given food preparation process that have similar hazards ◦ Actions or activities used to prevent, eliminate or reduce hazards are similar 11

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Process 1 - no cook step Receive  Store  Prepare  Hold  Serve Process 2 - heat and serve same day Receive  Store  Prepare  Cook  Hold  Serve  Serve Process 3 - complex food preparation Receive  Store  Prepare  Cook  Cool  Reheat  Hot Hold  Serve (advance preparation or leftovers) Receive  Store  Prepare  Cook  Serve  Cool  Reheat  Hot Hold  Serve 13

◦ Develop composite list ◦ Determine if the menu item potentially hazardous (time/temperature control for food safety) and designate with “*” ◦ Follow specific control measures that apply to all potentially hazardous menu items in the category 14

 Process 1 ◦ Example: dairy products ◦ Example: bakery products  Process 2 ◦ Example: chicken patty ◦ Example: heated canned vegetables  Process 3 ◦ Example: Chili prepared in advance ◦ Example: Leftovers 15

16 2-inch Pan Walk-in Average was 7:20 hours 4-inchPan Walk-in Average was 11:33 hours 3 gallons Walk-in Average was 24:17 hours 3 gallons Chill Stick Average was 6:10 hours Cooling Chili from 135°F to 41°F Note Food Code Requirement: Cool from 135°F to 70°F in 2 hours and 70°F to 41°F in 4 hours

17 2-inch Pan Walk-in Average was 2:23 hours 4-inchPan Walk-in Average was 3:53 hours 3 gallons Walk-in Average was 8:00 hours 3 gallons Chill Stick Average was 2:10 hours Note Food Code Requirement: Cool from 135°F to 70°F in 2 hours Cooling Chili from 135°F to 70°F

18 2-inch Pan Walk-in Average was 4:57 hours 4-inchPan Walk-in Average was 7:40 hours 3 gallons Walk-in Average was 16:17 hours 3 gallons Chill Stick Average was 4:00 hours Note Food Code Requirement: Cool from 70°F to 41°F in 4 hours Cooling Chili from 70°F to 41°F

 Improper cooling is #1 cause of food borne illness  Limit the items in process 3 to minimize the risks and efforts involved to proper cool  Invest appropriate equipment & devices 19

 Cooling study log for items (see prototype) ◦ Cooling rates vary from item to another so separate study is needed ◦ Use study to test/adapt procedures presently followed  Develop specific SOP outlining procedures for each item  Not necessary to monitor temperatures each time when study documents food items are properly cooled 20

 What will be monitored?  How will it be monitored?  Who will be responsible for monitoring? (designated position with back-up) ◦ directly associated ◦ trained and knowledgeable ◦ accessible to monitoring activity ◦ responsible ◦ Has authority to take corrective action 21

 Receiving - Logs or Invoices? Other?  Damaged/Discarded Product – Log or use invoices?  Refrigerator/Freezer Temperatures – Logs for each units? Record on daily production plan? Are recording devise for walk-ins with alarm?  Cooking Temperatures – Log or recorded on daily production plan?  Holding – How often must temperatures be taken? Ways to eliminate or minimize?  Calibration – How often? 22

 Provide training with sequential steps  Establish specific routines or times of day for monitoring activities  Provide appropriate forms  Provide appropriate & sufficient ◦ Thermometers ◦ Testing devises for dishmachine & chemical sanitizers 23

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 Records from the food safety program for a period of six months following a month’s temperature records with § (c).  Records from the most recent food safety inspections to demonstrate compliance with § (b). 25

State agency must examine records to confirm that each school food authority under its jurisdiction meets food safety requirements of §

Implementation of a food safety program at each of the food preparation and service facilities under its jurisdiction serving reimbursable breakfasts 27

Working relationship with vendor Vendor HACCP certification Allergen management Pest control Standardized recipe with detailed instructions Integrated controls (designated cutting boards, fully cooked products) First-in-first-out inventory system & date marking 28

Success of plan implementation is dependent on:  Facilities  Equipment  People 29

 Selected/designed to promote safe food preparation and handling practices  Attention given to correction of barriers to safe food preparation ◦ Faulty, outdated plumbing ◦ Air gaps & cross connections ◦ Delivery schedules for food deliveries & transported food based on mail delivery 30

 Appropriate thermometers/properly calibrated  Heating and holding equipment with accurate gauges  Sufficient cold storage facilities 31

 Knowledgeable  Understand his/her role  Committed  Overcome Obstacles ◦ Time commitment ◦ High employee turnover ◦ Communication barriers 32

 Basic food safety competencies  Specific competencies for Food Safety Plan: ◦ Thermometer usage and calibration ◦ Receiving procedures ◦ Storage temperatures ◦ Hot & cold holding temperatures ◦ Cleaning/sanitizing ◦ Cooking and documenting temperatures ◦ Cooling procedures ◦ Reheating procedures and temperatures ◦ Maintaining necessary logs 33

 On-going safety training  Review of food safety principles including SOP guidelines on annual basis  Documenting training  Holding site supervisors responsible for maintaining standards 34

 Employee Health Reporting Program  Procedure/Process  Signed Agreement with plan & copy provided to employee  Orientation for new employees, subs, and volunteers  Documentation of SOPs 35

 Posted Process 1, 2, 3 charts  Customized temperature charts  Laminated signs in kitchen  Standardized recipes with: ◦ Food safety procedures ◦ critical control points  Others 36

USDA Quantity Recipes Posted at: pe_index_alpha.html Use as: ◦ Source for recipes to standardize ◦ Guide for written recipe format:  Ingredients and detailed instructions  Contribution serving makes towards food based menu planning system  CCPs and food safety procedures 37

Attention to:  Simplicity  Specific to each food service operation  Involvement of employees in plan development, implementation, plan review  Support from administration 38

 Recognition that food safety is important issue throughout entire school agency  Develop food safety & food safety policy for school agency addressing: ◦ School food service program ◦ Food brought from home or other sources ◦ Food in the classroom ◦ Vending ◦ Concessions ◦ Use of facilities by outside groups ◦ Access to the school kitchen 39

 Involve key constituents on a team to develop food safety & security policy  Support food safety and food security training for school food service staff  Support food safety education for students 40

 Work with administration to develop strong school district food safety & security policy  Require food safety certification for all management & supervisor personnel  Provide continuing food safety education  Evaluation the school food service program to determine that all prerequisite programs are in place to support food safety & security programs  Purchase tools required/make readily available  Develop self-inspection programs  Stay informed about current food safety rules and inspection processes 41

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 Required components  Table of contents/Index  Any food safety policy/kitchen use policy & forms  Prerequisite programs  Additional SOPs  USDA guidance pertaining to food safety  Signed employee health reporting agreements  Blank copy of each monitoring logs  Completed monitoring logs for six months/more  Employee training records  Food safety inspection reports  Annual review/revision documentation  Others? 43

 Ongoing Verification – Implementation of the food safety plan Is the plan being followed?  Periodic Validation – design of food safety plan Does the plan control the hazards? 44

 Ongoing Verification ◦ Conduct frequently (daily, weekly, monthly) by designated employee for multi prep/serving site operations and/or part of 2 nd food safety inspection  Periodic Validation ◦ Done less frequently, but at least annually, and is intended to confirm that the plan controls the hazards in operation and may be completed during 2 nd inspection 45

 Monitoring is being done, per plan  Monitoring records are completed accurately at predetermined frequency  Planned corrective actions are taken  Thermometers are calibrated 46

 Observing employees  Checking monitoring records  Checking corrective action records  Reviewing calibration records  Checking accuracy of thermometers  Reviewing past inspection reports  Reviewing training protocols & agendas 47

Includes: Observing employees Checking monitoring records Checking corrective action records Reviewing calibration records Checking accuracy of thermometers Reviewing past inspection reports Reviewing training protocols & agendas 48

Completion of Checklist for Review of Food Safety Plan (see prototype) ◦ Adapt prototype to fit site ◦ Adapt as the “look fors” for multi school sites and/or ◦ Person in charge acts as “inspector” ◦ Complete at least annually as part of routine monitoring of sites and on “as need basis” 49

 During observations: Determine if employees follow plan/Ask open ended questions to find out if employees understand what to do  For record review: May need to randomly choose a few days if responsible for multi- school sites  Focus on CCPs  Look for patterns 50

 Determine where deviations have occurred  Detect overall trends  Take action ◦ Change procedures ◦ Revise plan ◦ Revise monitoring forms ◦ Provide training and specific instructions ◦ Reassign responsibilities 51

 Ongoing Verification ◦ Conduct frequently (daily, weekly, monthly) by designated employee for multi prep/serving site operations and/or part of 2 nd food safety inspection  Periodic Validation ◦ Done less frequently, but at least annually, and is intended to confirm that the plan controls the hazards in operation and may be completed during 2 nd inspection 52

 New menu items or processes  New programs  New regulations – Food Code & USDA  Changes ins suppliers, customers, equipment or facilities  Changes needed in prerequisite programs or SOPs  Appropriateness of recordkeeping forms 53

 Improve plan by identifying weaknesses  Eliminating unnecessary or ineffective controls  Determining if the plan needs to be modified 54

 Complete periodically, at least annually  Maintain completed form with the food safety plan at each preparation or serving location  Include effective date for modified items and forms 55

 Strengthens existing food safety requirements for all FNS programs (NSLP, SBP, FFVP, SMP, plus Afterschool Snack & Supper Programs)  Food safety plan based on HACCP must be applied to any facility or part of facility where food is stored, prepared or served for FNS programs 56

 USDA anticipates minor updates for meal/milk service on school buses, in hallways, kiosks, classrooms, or other areas outside cafeteria  Effective ASAP/n o later than school year  USDA will develop “practical” guidance 57

 Meet HHFK Act of 2010 provision which requires review and update for all FNS programs  Consider making appropriate revision to DPI prototype SOPs/monitoring logs now listed on DPI website for: – Breakfast Served in Classroom – Milk/juice transported in coolers – Prototype transport sheets for lunch, breakfast, afterschool care snack 58

 Use second inspection to verify and validate food safety plan with environmental health specialist  Obtain input from employees Remember: It is your plan! 59

DPI School Nutrition Program’s Food Safety and Food Biosecurity webpage at:  Four USDA food safety requirement  Link to WI Food code & fact sheets  Prototype food safety plan(s) & resources  Food safety training resources & job aids ◦ including sources for free handwashing posters 60

Basic Food Safety Training Iowa State University Extension ducators/ccp.cfm?articleID=62&parent=2  Training materials and videos  Calendar with safety messages 61

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