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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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