A sweeping change went into effect in July 2005 to improve the safety of food served in the National School Lunch Program (NSLP) and School Breakfast Program (SBP) in all school cafeterias nationwide.  It was the implementation of a law passed (the Child Nutrition and WIC Reauthorization Act of 2004) that required all school foodservice settings to have food safety plans based on HACCP (Hazard Analysis and Critical Control Point) principles, in addition to increasing the mandatory food safety inspections from once per year to twice.

This new food safety requirement has an enormous impact because it affects some 100,000 schools across the country.  Schools alone serve nearly 29 million lunches and 8 million breakfasts each day in the NSLP and SBP. Since the law required a HACCP-based program, one had to be found that would fit school foodservice, which is very similar to retail foodservice.  The Process Approach to HACCP, formulated by the Food and Drug Administration and vetted with members of the Conference for Food Protection, was adapted for use by schools and released as Guidance in June 2005.  Because school foodservice settings range from satellite kitchens that serve pre-cooked and heated foods to full-scale central kitchens, guidance had to be flexible enough to meet these varying needs.

The Process Approach to HACCP differs from traditional HACCP in that menu items can be grouped into similar processes, as the hazards are similar.  It breaks down food preparation into three basic processes determined by the number of times the food goes through the temperature danger zone (TDZ) (41 – 135 ˚F, according to the 2005 Food Code).  The three processes are as follows:

• Process 1:  Food preparation with No Cook Step (no trips through the TDZ).
• Process 2:  Preparation for Cook and Serve (one trip through TDZ).
• Process 3:  Preparation for Cook, Chill, and/or Reheat, and Serve (more than one trip through the TDZ).

The Process Approach works well in foodservice establishments with a variety of menu items and in varying types and sizes of facilities.  School foodservice outlets that already used traditional HACCP were not required to revise their plans to use the Process Approach.  In addition to using the Process Approach in the Guidance for schools, standard operating procedures were developed to assist with their overall plans.

Oversight of HACCP implementation is conducted by the state agency that administers the NSLP and SBP.

The food safety inspections must be conducted by a state or local government agency responsible for food safety regulations.  More frequent inspections may still be required by state or local governments.  In addition, schools must post, in a publicly visible location, a report on the most recent food safety inspection, and provide a copy of the food safety inspection report to the public upon request.  State agencies must report to USDA annually on the number of inspections conducted.

For further information, go to the USDA Food and Nutrition Service Web site and click on “food safety.”