Julie SheltonConsultant - School Nutrition Program

Wisconsin Department of Public InstructionSummer 2011

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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

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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 2005

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“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

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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

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Brief review of plan components Final regulations specific to food safety plan

(January 2010) HHFK Act of 2010/Public Law 111-296 Considerations/Issues/Concerns Your issues/questions Hot topics

◦ Allergens◦ Breakfast in the classroom◦ Farm to School

Update on available resources

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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

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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

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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

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Written plan for each prep/serving sitemust 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

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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

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Process 1 - no cook stepReceive Store Prepare Hold Serve

Process 2 - heat and serve same dayReceive Store Prepare Cook Hold Serve

Serve

Process 3 - complex food preparationReceive Store Prepare Cook Cool Reheat

Hot Hold Serve (advance preparation or leftovers)

Receive Store Prepare Cook Serve Cool Reheat Hot Hold Serve

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◦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

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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

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2-inch Pan Walk-in

Average was 7:20 hours

4-inchPanWalk-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

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2-inch Pan Walk-in

Average was 2:23 hours

4-inchPanWalk-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

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2-inch Pan Walk-in

Average was 4:57 hours

4-inchPanWalk-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

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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

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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

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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?

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Provide training with sequential steps

Establish specific routines or times of day for monitoring activities

Provide appropriate formsProvide appropriate & sufficient

◦Thermometers◦Testing devises for dishmachine &

chemical sanitizers

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Records from the food safety program for a period of six months following a month’s temperature records with § 210.13 (c).

Records from the most recent food safety inspections to demonstrate compliance with § 210.13(b).

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State agency must examine records to confirm that each school food authority under its jurisdiction meets food safety requirements of §210.13.

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

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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

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Success of plan implementation

is dependent on:FacilitiesEquipmentPeople

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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

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Appropriate thermometers/properly calibrated

Heating and holding equipment with accurate gauges

Sufficient cold storage facilities

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Knowledgeable Understand his/her role Committed Overcome Obstacles

◦Time commitment ◦High employee turnover◦Communication barriers

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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

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On-going safety training Review of food safety principles including SOP guidelines on annual basis

Documenting training Holding site supervisors responsible for maintaining standards

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Employee Health Reporting Program

Procedure/Process Signed Agreement with plan & copy

provided to employeeOrientation for new employees, subs, and volunteers

Documentation of SOPs

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Posted Process 1, 2, 3 chartsCustomized temperature chartsLaminated signs in kitchenStandardized recipes with:

◦ Food safety procedures◦ critical control points

Others

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USDA Quantity RecipesPosted at:http://www.nfsmi.org/Information/school_recipe_index_alpha.htmlUse 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

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Attention to: Simplicity Specific to each food service operation

Involvement of employees in plan development, implementation, plan review

Support from administration

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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

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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

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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

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Required components Table of contents/Index Any food safety policy/kitchen use policy & forms Prerequisite programsAdditional SOPsUSDA guidance pertaining to food safetySigned employee health reporting agreementsBlank copy of each monitoring logsCompleted monitoring logs for six months/moreEmployee training recordsFood safety inspection reportsAnnual review/revision documentationOthers?

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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?

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Ongoing Verification◦ Conduct frequently (daily, weekly, monthly) by

designated employee for multi prep/serving site operations and/or part of 2nd 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 2nd inspection

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Monitoring is being done, per plan

Monitoring records are completed accurately at predetermined frequency

Planned corrective actions are taken

Thermometers are calibrated

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Observing employees Checking monitoring records Checking corrective action records Reviewing calibration records Checking accuracy of thermometers

Reviewing past inspection reports Reviewing training protocols & agendas

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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

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Completion of Checklist for Review ofFood 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”

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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

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Determine where deviations have occurred

Detect overall trends Take action

◦ Change procedures◦ Revise plan◦ Revise monitoring forms◦ Provide training and specific instructions◦ Reassign responsibilities

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Ongoing Verification◦ Conduct frequently (daily, weekly, monthly) by

designated employee for multi prep/serving site operations and/or part of 2nd 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 2nd inspection

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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

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Improve plan by identifying weaknesses

Eliminating unnecessary or ineffective controls

Determining if the plan needs to be modified

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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

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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

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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 2011-12 school year

USDA will develop “practical” guidance

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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

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Use second inspection to verify and validate food safety plan with environmental health specialist

Obtain input from employees

Remember:Remember: It is your plan!It is your plan!

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DPI School Nutrition Program’sFood Safety and Food Biosecurity webpage

at: http://fns.dpi.wi.gov/fns_foodsafety 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

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Basic Food Safety Training Iowa State University Extensionhttp://www.extension.iastate.edu/foodsafety/educators/ccp.cfm?articleID=62&parent=2 Training materials and videos Calendar with safety messages

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