School Nutrition Programs Compliance Handbook
CHAPTER 10-FOOD SAFETY PROGRAM
All schools and RCCIs participating in the National School Lunch Program (NSLP) and the School Breakfast Program (NSLP) must have a written food safety program based on Hazard Analysis Critical Control Points (HACCP) principles. OKDHS School Nutrition Programs (SNP) has developed a sample plan based on HACCP principles that can be modified to meet the requirements of the local food safety requirements. School Food Authorities (SFA) can request the prototype plan from the OKDHS SNP.
Section 302 of the Act amends section 9(h)(5) of the Richard B. Russell National School Lunch Act (42 U.S.C. 1758(h)(5)) by requiring that the school food safety program based on Hazard Analysis and Critical Control Point (HACCP) principles be applied to any facility or part of a facility in which food is stored, prepared or served for the purposes of the NSLP, SBP or other USDA Food and Nutrition Service (FNS) programs. The school food safety program, required since 2004, addresses food safety in all aspects of school meal preparation, ranging from procurement through service.
Purpose of a School Food Safety Program
The purpose of a school food safety program is to ensure the delivery of safe foods to children in the school meals programs by controlling hazards that may occur or be introduced into foods anywhere along the flow of the food from receiving to service (food flow). This plan is designed to help control food safety hazards that might arise during all aspects of food service (receiving, storing, preparing, cooking, cooling, reheating, holding, assembling, packaging, transporting and serving).
There are two types of hazards:
1) Ones specific to the preparation of the food, such as improper cooking for the specific type of food (beef, chicken, eggs, etc.) and
2) Nonspecific ones that affect all foods, such as poor personal hygiene. Schools should identify Critical Control Points (CCPs) and implement measures to control the occurrence or introduction of specific hazards. Developing and implementing SOPs will control nonspecific hazards.
A school food safety program should: control both specific and nonspecific hazards and consist of SOPs and a written plan for applying the basic HACCP principles. School Food Authorities (SFA) may request the USDA Guidance for SFAs: Developing a School Food Safety Program Based on Process Approach to HACCP Principles to help SFAs develop an overall school food safety program using the HACCP principles. To request this guidance email AFS.School.Nutrition.Programs@okdhs.org.
HACCP
Hazard Analysis and Critical Control Point (HACCP) is a systematic approach to construct a food safety program designed to reduce the risk of foodborne hazards by focusing on each step of the food preparation process from receiving to service. USDA requires SFAs to use the Process Approach to HACCP because it gives schools the flexibility to create a food safety program specific to the local food service operation. The Food and Drug Administration (FDA) originally developed the Process Approach for retail food establishments. The Process Approach groups food preparation into three broad categories based on how many times each menu item moves through the temperature danger zone. The SNP guidance material provides a modified version of the Process Approach to make it practical for your school food service operation.
Serving safe food is a critical responsibility for school food service and a key aspect of a healthy school environment.
When properly implemented, HACCP-based food safety programs will help you ensure the safety of the school meals served to children in your school nutrition program.
Food Process Approach
A HACCP requirement is the process approach for preparing foods. These categories are:
- Process #1: No Cook, food items meant to be kept cold from preparation through service.
- Process #2: Same Day Service, food items meant to be prepared hot and served hot the same day.
- Process #3: Complex Food Preparation, food items meant to be prepared hot and served cooled or possibly reheated. You will need to put each menu item (recipe) into one of the three categories and then keep it hot (or cold) while it is being stored, prepared, transported, held, and served.
If there is a failure in sanitation or temperature control, be sure to have a means of correcting the problem and verifying that the corrective steps resolved the problem. After the food safety program is implemented, staff should review process at least once a month to ensure it is effective. Each year, the site should review the entire program to incorporate any changes, such as new menu items, new equipment, changes in staff, and remodeling.
Requirements for a School Food Safety Program
To meet the USDA standard requirements for implementing a food safety program,
Schools and RCCIs must include the following elements:
1. Documented Standard Operating Procedures (SOPs)
· SOPs serve as a basic food safety foundation and to control hazards not outlined specifically in the HACCP plan. SOPs outline the proper procedures for controlling and preventing critical hazards during the food flow process.
2. A written plan at each of the sites where food preparation is conducted, as well as for each site where meal service occurs for applying HACCP principles that include methods listed in table 1.
Table 1: HACCP Principles |
HACCP principles using the following methods:
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To assist schools in complying with these food safety requirements, OKDHS School Nutrition Programs (SNP) provides a guideline for developing an effective food safety plan, along with sample language for a policy. This guidance adopts language taken from the adapted from: U.S. Department of Agriculture, Food and Nutrition Service. (June 2005). Guidance for School Food Authorities: Developing a School Food Service Program Based on the Process Approach to HACCP Principles. This guidance is available on the USDA website at http://www.fns.usda.gov/sites/default/files/Food_Safety_HACCPGuidance.pdf, and upon request by email to OKDHS School Nutrition Programs (SNP).
FOOD SAFETY REVIEWS
Food safety programs must be reviewed to ensure that standard operating procedures for safe food handling are updated to include any facility or part of a facility where food is stored, prepared, or served, such as on school buses, in hallways, courtyards, kiosks, classrooms, or other locations outside the cafeteria. This requirement applies to the school breakfast or lunch meals, and Special Milk, the Fresh Fruit and Vegetable Program and afterschool snack or supper programs.
HEALTH INSPECTIONS
According to section 111 of the Child Nutrition and WIC Reauthorization Act of 2004 schools and RCCIs participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) are required to increase the number of food safety inspections from the one inspection currently required to two inspections per year. Section 111 also requires schools and RCCIs to post the most recent food safety inspection report in a place visible to the public. Schools and RCCIs must also release the report to the public upon request.
If a school or RCCI does not receive two inspections a year, it must contact the local health department and request a second inspection. Document all requests and follow-up attempts to get health inspections completed.
Each year, SFAs are required to submit a report to OKDHS School Nutrition Programs (SNP) listing the number of health inspections completed in the previous year. The form is required to be submitted to OKDHS SNP by September 1 of each school year.
Table 2, contains a summary of the requirements for health inspections
Table 2: Health Inspection Requirements |
The following are the health inspection requirements for each school year (July 1st through June 30th):
o Contact the local health department if a second inspection has not been received by about mid-March of the school year. This request can be made to the health department inspector when they come out to conduct the first inspection, a phone call with staff at the local health department, or email with the local health department. § If the local health department is unable or will not conduct two inspections, document the following: · The reason given by the heath department why the a second inspection will not be conducted. · Document the date of the contact and the name of the person the contact was with.
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Food Safety Resources
Table 3.1 contains resources available upon request from OKDHS School Nutrition Programs. To request one of the items in table 3.1 email AFS.School.Nutrition.Programs@okdhs.org.
Table 3.1: Food Safety Resources Available from OKDHS School Nutrition Programs |
· USDA Guidance for School Food Authorities: Developing a School Food Safety Program Based on the Process Approach to HACCP Principles. Available upon request by emailing AFS.School.Nutrition.Programs@okdhs.org. |
Table 3.2 Contains Food Safety resources available online.
Table X.2: Food Safety Available Online |
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USDA National School Lunch Program (NSLP) Food Safety Resource Website: |
Institute of Child Nutrition (ICN) Writing, Updating, and Revising a HACCP-Based Food Safety Plan Workshop webpage: · https://theicn.org/icn-resources-a-z/writing-a-haacp-based-food-safety-plan-for-schools/ |
USDA Guidance for School Food Authorities: Developing a School Food safety Program Based on the Process Approach to HACCP Principles: · http://www.fns.usda.gov/sites/default/files/Food_Safety_HACCPGuidance.pdf |
ICN Food Safety Resources website: |