USDA Food Safety Requirements
• Effective July 1, 2005• USDA Interim Rule
published June 15, 2005• Final rules to formalize food
safety requirements published on August 8, 2008 form comments
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USDA Food Safety Requirements
Public Law 108-2651. Request two annual food
safety inspections for each preparation/serving site participating in NSLP and/or SBP
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USDA Food Safety Requirements
Public Law 108-265
2. Public Notification• Post copy of most recent
safety inspections at each preparation/serving site
• Provide copy upon request
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USDA Food Safety Requirements
Public Law 108-2653. State/Federal Audits to Assure Compliance
• DPI must report # of inspections to USDA• Info is obtained from Schedule A of on-line
contract• “Meals not served” is response if there is no
meals service at school listed on Schedule A
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USDA Food Safety Requirements
4. Implement Food Safety Program based on Hazard Analysis Critical Control Point (HACCP) principles
• Schools participating in the NSLP and/or SBP
• Guidance issued on June 10, 2005
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USDA Food Safety Requirements
Schools with HACCP based food safety program in place may retain their current program if it includes all the HACCP principles listed in USDA guidance
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Who were effected by regs?
School agencies participating in USDA’s NSLP and/or SBP 926 school agencies (districts & private
schools)Approximately 2,400 buildings
DPI’s School Nutrition TeamDHFS’s Division of Public Health and
agents School Nutrition Association (SNA) of WI
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Wisconsin’s Compliance Plan
Developed by representatives from:
• DPI’s School Nutrition Team• Department of Health/Agents
who conduct food safety insepctions
• SNA of WI9
• 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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Final Rule
• 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
• 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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Reauthorization 2010HHFKA/ Public Law111-296
USDA Guidance - June 2005
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School Food Safety School Food Safety Program Based onProgram Based onProcess Approach Process Approach to HACCP Principlesto HACCP Principles
Purpose of School Food Safety Program
Ensure the delivery of safe foods to children in school meal programs by controlling hazards that may occur or be introduced into foods anywhere along the flow of food from receiving to service – USDA Guidance
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What is Hazard Analysis Critical Control Point
(HACCP)?
A scientific and rational approach to food safety which:• analyzes potential hazards• determines the critical control
points in a food process• develops monitoring procedures to
determine if the hazards identified are effectively controlled
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Why is HACCP the “Gold Standard” in food service?
• Foodborne illness outbreaks are major financial and public relations cost to the food service industry
• Children are vulnerable• Visual inspections of food product
cannot detect pathogens• Documented HACCP controls can
prevent foodborne illness from occurring
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Seven Principles of HACCP
1. Conduct a hazard analysis2. Identify critical control points3. Establish critical control point
monitoring4. Establish corrective action5. Establish verification procedures6. Establish record keeping
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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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Differences Between Traditional and Process
Approach
Plan for Each Production/Serving Site
• Documents menu items in appropriate HACCP process category
• Identifies critical control points and control measures
• Includes monitoring responsibilities and forms to be used
• Establishes and documents appropriate corrective actions taken
• Includes records to show plan is operational
• Ongoing review and plan revisions needed
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Nine Steps for Plan Development
1. Describe each preparation/serving site2. Categorize menu items as process 1, 2, or 33. Identify critical control measures and limits4. Develop and /or adapt prototype Standard
Operating Procedures (SOPS) specific to site5. Establish monitoring procedures6. Establish corrective actions7. Choose appropriate monitoring records8. Provide training9. Review and revise food safety program period
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Step 1: Site Description
• Separate plan specific to site• Include equipment inventory• Floor plan is not needed for process
approach• Description for the individual site plan
should reflect what is done at preparation/serving location
• Same set ups may have same plan• Obtain assistance from those who
prepare and serve
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Step 2: Categorization Process
• Start with school menus (lunch & breakfast)• Include a la carte items and other items
served as part of Afterschool Snack Program, Fresh Fruit and Vegetable Program (if applicable)
• Complete chart to indicate the category• Minimize lists by grouping like items– Canned fruit– Dairy products– Purchased bread products– Fully cooked chicken products
• Some items to list separately:– Fresh melon and strawberries– “Casseroles” with various ingredients &
cooling processes21
Process Approach to HACCP
• Categorize all items including: – Potentially Hazardous Foods (PHF):
■ Egg ■ Meat ■ Dairy ■ Heated Vegetables/Fruits
–Non-Potentially Hazardous Foods:■ aw of 0.85 ■ pH of 4.6 ■
Hermetically or less or less sealed
• Place * by PHF (T/TC) such as melons & strawberries
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Process Approach to HACCP Group items according to number of
times the food goes through the “danger zone” (41°F. and 135°F.)
• Process #1 – No Cook– Menu item is not in the danger zone
• Process#2 – Same Day Service– Menu item takes one trip through danger
zone• Process#3 – Complex Food Preparation– The menu item goes through both heating and
cooling, taking two or more trips through the danger zone.
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Process #1 – No Cook
Receiving → Store → Prepare → Hold → Serve
Sub Sandwich with Ready to Eat Ingredients
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Process #2 – Same Day Service
Receiving → Store → Prepare → Cook → Hold → Serve
• Menu items made from canned, packaged, frozen, raw ingredients that involve a cook step.– Heated canned or frozen vegetables– Pizza– Fully cooked chicken products
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Process# 3 – Complex Food
Receiving → Store → Prepare → Cook → Cool → Reheat → Hold → Serve
• Menu items with preparation steps which may require cooling and reheating prior to being served– Spaghetti Sauce– Turkey and Gravy– Hard boiled eggs– Heated Leftovers
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Step 3: Identify Critical Control Points &
MeasuresCritical Control Point (CCP) an operational
step in a food preparation process at which control can be applied and is essential to prevent or eliminate a hazard
Control Measures - any action or activity that can be used means taken to prevent , eliminate, or reduce hazards to an acceptable level (Refer to flow charts on p. 9-10 of prototype)
Critical Control Points
• Points in food preparation/processing where controlling a step is essential to assure food safety– Receiving– Cold Holding– Cooking–Hot Holding– Cooling– Reheating
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Critical Measures in Process Approach HACCP
• No Cook:– Cold holding or limiting time in the danger zone to
inhibit bacterial growth and toxin production (e.g., limiting time item is at room temperature and discarding items that reach limits.
• Same Day Service:– Cooking to destroy bacteria and other pathogens– Hot holding or limiting time in the danger zone to
prevent the growth of spore-forming bacteria.
• Complex Food Preparation:– Cooking to destroy bacteria and other pathogens– Cooling to prevent the outgrowth of spore-forming
bacteria– Hot and cold holding or limiting time in the danger
zone to inhibit bacterial growth and toxin formation– Reheating for hot holding, if applicable. 30
Critical Limits
The time and temperature ranges for food preparation and service (either hot or cold) that keeps food safe.
– Cold holding = 41°F (Maximum)–Hot Holding = 135°F (Minimum)– Cooking = Time + Temperature– Cooling– Reheating Previously Cooked
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General
Receive
Store
Prepare
Critical Measures & Limits Process 1
Example: Sub Sandwich with RTE Ingredients
Critical Measures & Limits Process 1
Example: Sub Sandwich with RTE Ingredients
COLD HOLDING
Critical Limit: Internal Temperature of 41°F
Check & Record Temperatures
SERVE
General
Receive
Store
Prepare
Critical Control Measures & Limits
Process 2Example: Fully Cooked Chicken Nuggets
Critical Limits – Process 2Example: Fully Cooked Chicken Nuggets
SERVE
Critical Limit: Hot hold at no less than 135°F.
Check & Record Temperatures
COOK/REHEAT FULLY COOKED PRODUCTS
Critical Limit: Internal Temperature of 135°F for 15 seconds
Check & Record Temperatures
General
Receive
Store
Prepare
Critical Control Measures & Limits for Process 2
Raw Beef for Spaghetti Served on Same Day
Critical Limits – Process 2Raw Ground Beef for Spaghetti Sauce – Served
Same Day
SERVE
Critical Limit: Hot hold at no less than 135°F.
Check & Record Temperatures
COOK/GROUND BEEF
Critical Limit: Internal Temperature of 165°F for 15 seconds
Check & Record Temperatures
General
Receive
Store
Prepare
Critical Control Measure & Limits - Process 3
Raw Ground Beef for Spaghetti Sauce – Served Next Day
Critical Limits – Process 3Raw Ground Beef for Spaghetti Sauce – Served Next
Day
COOK/GROUND BEEF
Critical Limit: Internal Temperature of 165°F for 15 seconds
Check & Record Temperatures
Critical Control Measures & Limits Process 3
Raw Ground Beef for Spaghetti Sauce – served next day
Critical Control Point: COOL
Critical Limit: Cool from 135 °F to 70°F within 2 hours and from 70°F to 41°F or lower within an additional 4 hours.
Check & Record Temperatures
Critical Limits – Process 3Raw Ground Beef in Spaghetti Sauce – Served Next
Day
Critical Control Point: REHEAT
Critical Limit: Heat to 165 °F for at least 15 seconds.
Check & Record Temperatures
Critical Control Limits & Measures - Process 3
Raw Ground Beef in Spaghetti Sauce - Next Day Service
Critical Limit: Hot hold at no less than 135°F.
Check & Record Temperatures SERVE
General
Receive
Store
Prepare
Critical Control Measure & Limits - Process 3Turkey Roast (Raw – Served Next Day
Critical Control Measures & Limits Process 3
Example: Turkey Roast (Raw) & Gravy
General
ReceiveStore
Prepare
COOK/Raw Turkey Roast
Critical Limit: Internal Temperature of 165°F for 15 seconds
Check & Record Temperatures
Critical Control Measures & Limits Process 3
Turkey Roast (raw) & gravy – served next day
Critical Control Point: COOL
Critical Limit: Cool from 135 °F to 70°F within 2 hours and from 70°F to 41°F or lower within an additional 4 hours.
Check & Record Temperatures
Critical Limits - Process 3Example: Turkey Roasts (raw) & Gravy
Critical Control Point: REHEAT
Critical Limit: Heat to 165 °F for at least 15 seconds.
Check & Record Temperatures
Critical Control Measures & Limits
Process 3 Example: Turkey Roasts (raw) & Gravy
Critical Limit: Hot hold at no less than 135°F.
Check & Record Temperatures SERVE
Critical Control Measures & Limits Process 3
Example: Fully Cooked Chicken Nuggets – Heated Leftover
General
Receive
Store
Prepare
Critical Limits – Process 2Example: Fully Cooked Chicken Nuggets – Heated
Leftover
SERVE
Critical Limit: Hot hold at no less than 135°F.
Check & Record Temperatures
COOK/REHEAT FULLY COOKED PRODUCTS
Critical Limit: Internal Temperature of 135°F for 15 seconds
Check & Record Temperatures
Critical Control Measures & Limits Process 3
Example: Fully Cooked Chicken Nuggets – Heated Leftover
Critical Control Point: COOL
Critical Limit: Cool from 135 °F to 70°F within 2 hours and from 70°F to 41°F or lower within an additional 4 hours.
Check & Record Temperatures
Critical Limits – Process 3Example: Fully Cooked Chicken Nuggets - Heated
Leftovers
Critical Control Point: REHEAT
Critical Limit: Heat to 165 °F for at least 15 seconds.
Check & Record Temperatures
Critical Control Measures & Limits
Process 3 Example: Fully Cooked Chicken Nuggets - Heated
LeftoversCritical Limit: Hot hold at no
less than 135°F.
Check & Record Temperatures SERVE
Step 4: Develop/Adapt SOPs
SOPs are written instructions for a food service task that reduce food safety hazards. Usually written to include:–Who?–What?–When?–Where?– How?–Why?
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Components of USDA’s SOPs
• Purpose (What)• Scope (Who does this apply to)• Keywords (New terms)• Instructions (How, Where and When)• Monitoring (Why)• Corrective Action (What to do if
there is a problem)• Record Keeping
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SOPs Developed by DPI School Nutrition Team for Prototype
• Adaptation of USDA’s & Iowa State University SOPs
• Include WI Dept. of Health Services Food Code Fact Sheets
• Minimized number of SOPs by grouping items - examples:– No bare hand contact with glove use–Manual and Machine dishwashing
• Monitor for critical control points Only
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What SOPs Do You Need?
• Address critical control measures for process 1, 2 & 3 potentially hazardous foods in your operation
• Provide food safety foundation
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Step 5: Establish Monitoring Procedures
• Considerations:–What is monitored? – How will you monitor?–When and how often will you monitor?–Who will be responsible for monitoring?
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What is Monitored
Critical control measuresMost involve measurements involving temperature & time
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&&
Who Monitors
• Directly associated with the operation
• Trained and knowledgeable• Accessible to monitoring activity• Responsible• Specify position and back up
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Step 6: Establish Corrective Action
• Needed whenever a critical limit is not met
• Must be carried out immediately• Employees must know what is
expected and how to make right decision
• Determined for all CCPs• Include summary in each school plan
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Corrective Action
ExampleCooler not maintaining 41°F
temperature – Is cooler is working properly?– Is thermometer calibrated?– Report temperature reading to supervisor
if cooler is not working properly– Supervisor contacts service repair
person if thermometer is accurate
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Step 7: Maintain Records
• Food Safety Plan • Records to be kept
– Receiving logs (or make use of invoices)– Cold Holding Temperature logs– Monitoring (cooking, cooling, and reheating and
other Critical Control Points)– Corrective action– Calibration records– Training logs
• Documentation of activities provides proof that reasonable care was exercised in the event your school is implicated in a foodborne illness
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How long must records be kept?
• Any combination records that include production plans - 3 years plus current
• Monitoring records food safety inspections - 6 months
Recommendation: Keep monitoring records for school year to support food safety plan and keep two most current food safety inspection reports
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Step 8: Provide & Document Training
• Basic food safety • Specific to Process approach to HACCP & the food safety plan• Annual training schedule • Documentation of training shows
there is employee participation in plan
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Important Competencies
• Basic food safety knowledge• Employee health reporting
responsibilities• Proper handwashing/glove use• Thermometer usage and calibration• SOPs• Recordkeeping procedures
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Helpful Job Aids
• Signage and posters at strategic locations
• Written recipes and daily production plans that designating process category
• CCPs in written recipes• Monitoring logs that includes
temperature ranges for cold holding, hot holding, etc.
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Step 9: Review & Revise Food Safety Plan
• Review and revise food safety plan at least annually or as often as necessary to reflect any changes
• Changes may include:– New equipment– New menu items– Different vendors– New programs– Reports of illness– Comments on a health inspection report– Other factors or changes in procedures.
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Step 9: Review & Revise Food Safety Plan, cont.
• 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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Food Safety Plan ReviewFood Safety Inspection
• Determine if there is a completed plan for each site– Accurate Description– Menu items categorized by process type – SOP specific to food service operation &
followed– Employees understand and follow SOPs
• Select three SOP’s to determine if applicable and implemented
• Review monitoring records for three days selected at random since last inspection
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Food Safety Plan Review, cont.
• Are records maintained?– Review by choosing 3 random days in
current school year to verify all records kept.
– Check to see if:• Appropriate temperatures are monitored
and recorded. • Records appear accurate and consistent.
• Are corrective actions documented if a critical limit is not met?
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Food Safety Plan Review, cont.
Is there a Employee Food Safety Training Program in place?
Plans reviewed and updated annually and when there are changes?
Report will be left summarizing results of plan review.
If there is no plan available:Must display inspection report that states “no
plan”.Expect follow up – environmental specialist will
notify DPI.
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Overall ConsiderationsTimeSimplicity
Make changes in operation to make that possibleBatch cooking to minimize holdingPurchase /order fully cooked meat itemsLimit number of process 3 by eliminating cooling step
Specific to food service operationSupport and recognition from
administration & othersInvolvement & InputContinuous Improvement
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Successful Implementation Recommendations
Work with school administration to develop strong school agency wide food safety and security policy to cover:– School food service– Food brought from home – Vending – Field trips– Concessions– Use of facility by outside groups– Access to the school kitchen
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Successful Implementation
Recommendations1. Required food safety certification
for all management/supervisory personnel
2. Provide food safety education for all employee & students
3. Develop self inspection programs 4. Stay informed about current food
safety regulations
Where to direct questions?
Contacts/Resources:
• Julie Shelton(School Program Regulation Compliance)
• James Mack (WI Food Code & Contact info for DHFS or Agent, & Fee Schedule)
• Person who conducts food safety inspections
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