The Child Nutrition and WIC
Reauthorization Act of 2004
requires each school food
authority (SFA) to implement a
school food safety program based
on HACCP (Hazard Analysis and
Critical Control Point)
principles. The School Nutrition
Association (SNA) has assembled
information and resources to
assist SFAs. SNA also offers
educational and training
opportunities appropriate for
school nutrition operations.
Details of the Law: Sec
111 of CN and WIC Reauth Act of
04
‘‘(5) SCHOOL FOOD SAFETY
PROGRAM.-Each school food
authority shall implement a
school food safety program, in
the preparation and service of
each meal served to children,
that complies with any hazard
analysis and critical control
point system established by the
Secretary.’’.
Key Points
USDA’s guidance and other
communications clarify aspects
of the law. Key points include:
- The law addresses the
entire school food safety
program. The HACCP-based
approach relates to
documented details of the
school food safety program.
- Programs may comply with
any HACCP system recognized
by USDA. SFAs that currently
implement traditional HACCP
will not be required to
change provided minimum
required elements are met.
- SFAs that do not
currently have HACCP plans
are encouraged to develop
programs based on the
process approach to HACCP.
- State agencies that
administer the child
nutrition programs will
review for compliance during
the state coordinated review
effort (CRE).
- SFAs are required
develop and implement school
food safety programs during
SY 2005-2006.
There are some elements that
FNS has outlined for a SFA’s
school food safety program to
include in order to comply, at a
minimum, with the requirement.
These are explained in FNS’s
guidance document. The minimum
required elements are:
- Documented SOPs
(Standard Operating
Procedures)
- A written plan for applying
HACCP principles at each
site within the SFA that
prepares and/or serves food
that includes methods for:
- Documenting menu
items into appropriate
categories (Process 1,
2, or 3) according to
the process-based
approach to HACCP
- Documenting Critical
Control Points during
food production
- Monitoring
- Establishing and
documenting corrective
actions
- Recordkeeping
- Periodically
reviewing and revising
the overall food safety
program