Regulation EFAB Student Food Allergies Regulation EFAB Related Entries: Responsible Office: Las Cruces Public Schools EFAB, IHB, JBB, JLCD Associate Superintendent for Operations STUDENT FOOD ALLERGIES I. PURPOSE This regulation sets forth the procedures that support the health and well-being of students and staff at school or school-sponsored events who have food intolerances and food allergies, especially those that may be life threatening. It is divided into management of milk intolerance, non-life threatening, and life-threatening food allergies. This regulation also establishes a set of protocols that address preventative measures to reduce exposure to food allergens in school facilities and schoolsponsored activities, professional development, coordination of services, and emergency response procedures. This regulation supports the current LCPS Human Resources Department process for addressing staff food allergies with the development of an individual plan for the employee. II. OVERVIEW This regulation identifies comprehensive protocols to address the needs of students and staff with food allergies by: A. Increasing awareness and communication throughout the school community regarding food allergies, including education and training for all school personnel concerning life-threatening food allergies; B. Establishing preventative measures to reduce exposure to food allergens; C. Developing education programs for 1) students and their families on food allergen avoidance strategies; and 2) classmates/schoolmates on the avoidance of endangering, isolating, stigmatizing, or harassing students with lifethreatening food allergies. Reference to specific students can only be made with prior written parental consent. D. Developing an individualized healthcare plan for a student that is developmentally appropriate; E. Establishing emergency procedures for allergic reactions in the school setting and ensuring development and compliance with all emergency action plans for students. EFAB-R • Page 1 of 14 Regulation EFAB Student Food Allergies III. DEFINITIONS A. Milk intolerance is an adverse food-induced reaction that does not involve the immune system. It is not the same thing as a true food allergy that always involves the immune system. A person with milk intolerance lacks an enzyme that is needed to digest milk sugar, called lactose. When the person drinks milk products, symptoms such as gas, bloating, and abdominal pain may occur. B. A food allergy is an adverse reaction to a food or food component that involves the body’s immune system. Usually a protein in a food, the allergen is perceived by the body as foreign, and the body produces specific antibodies to it called Immunoglobulin E (IgE). The next time the food is eaten by the allergic person, his or her IgE triggers the release of histamines and other chemicals that cause the inflammatory response. C. Symptoms of a food allergy vary and range from mild to severe to life threatening. Symptoms may affect different body systems and include one or more of the following: 1) skin: seen as hives, rashes, or eczema; 2) the gastrointestinal tract: vomiting, abdominal cramps, and diarrhea; 3) the respiratory system: a tingling sensation in the mouth, swelling of the tongue and the throat, and difficulty breathing; and 4) the cardiovascular system: a drop in blood pressure, loss of consciousness, shock. D. Anaphylaxis is a potentially life-threatening medical condition in allergic individuals after exposure to their specific allergens. Anaphylaxis refers to a collection of symptoms affecting multiple systems in the body. The most dangerous symptoms include breathing difficulties and a drop in blood pressure or shock that are potentially fatal. An anaphylactic response may occur within minutes of the exposure, although onset may occur one (1) to two (2) hours after contact. E. Epinephrine is the drug used to treat an anaphylactic reaction. It works to reverse the symptoms and helps to prevent their progression. It is available by prescription in self-injecting devices such as EpiPen or Twinject. F. Food Plan pertains to a plan that identifies how the Las Cruces Public Schools Nutrition Services Department will modify meals provided by the school in order to meet a student’s special dietary needs, including needs identified in an individualized health care plan. G. An Individualized Health Care Plan (IHCP) is the plan of nursing care written for any student with a medical diagnosis whose health care needs affect or have the potential to affect the student’s safe and optimal school attendance and academic performance. It includes direct nursing care in the office; any special or emergency procedures in the classroom or cafeteria, including a food plan as cited in item F. above; emergency provisions for field trips; and emergency EFAB-R • Page 2 of 14 Regulation EFAB Student Food Allergies evacuations. The plan covers all the time the student is on campus or school travel, or participates in extracurricular activities. It describes what nursing services, along with any other related services or program modifications, are needed to meet the student’s health care needs. The plan also addresses all emergency provisions for the student, including contacting of parents/guardians and medical healthcare providers. H. A Section 504 Plan (CFR 104.1, 104.6 (a)) ensures that no qualified handicapped student shall, on the basis of disability, be excluded from participation in or be denied the benefits of, or otherwise be subjected to discrimination under any program or activity of the Las Cruces Public Schools. A student is considered disabled if he/she suffers from a physical or mental impairment that substantially limits one or more of his/her major life activities, such as learning, walking, seeing, hearing, breathing, working, and performing manual tasks. (LCPS Policy JBB). I. An Individualized Education Plan (IEP) describes the “individualized education program” that is written for each child with a disability, designed to meet the child’s unique needs. Each child who receives special education services must have an IEP. The IEP is a written statement that is developed, reviewed, and revised and includes statements about present levels of educational performance, measurable annual goals, special education, and related services and supplementary aids and services to be provided. (LCPS Policy IHB). J. Least Restrictive Environment (LRE) (CFR 300.130) requirements means that each public agency must ensure that to the maximum extent appropriate, students with disabilities, including students in public or private institutions or other care facilities, are educated with students who are non-disabled; and special classes, separate schooling, or other removal of students with disabilities from the regular educational environment occurs only if the nature or severity of the disability is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily. The spirit of this requirement is to ensure that students are not unnecessarily removed from the regular classroom or isolated from other non-disabled students of their age and developmental stage. K. School-Level Multidisciplinary Team may include, but is not limited to, students (if age appropriate), parents, teachers, counselors, LCPS Nutrition Services Department director or his/her designee, school principal or his/her designee, school nurse, extra-curricular advisors, custodian, coaches, and LCPS Transportation Department personnel. L. Life Threatening Allergy (LTA) refers to a student who is diagnosed with a Life-Threatening Allergy by a recognized medical authority. EFAB-R • Page 3 of 14 Regulation EFAB Student Food Allergies M. School Community includes all staff, students, parents, and other individuals who work or volunteer in a school. N. Recognized Medical Authority must be licensed in the United States. For students with disabilities, this is limited to licensed physicians. For other students, the recognized medical authority is any U.S. licensed medical provider. O. Student Assistance Team means the school-based group of people whose purpose is to provide additional support to students and teachers so the student receives the maximum benefit possible from his/her general education. The SAT’s mission is to approach and arrive at appropriate solutions to problems in the school environment through a cooperative team effort. IV. PROFESSIONAL DEVELOPMENT A. Professional development at the building level shall be provided annually to all staff and shall consider the following topics: 1. Preventative measures to reduce exposure to food allergens 2. Use of EpiPens 3. Signs and symptoms of allergic reactions 4. Appropriate response 5. Documentation of training participation V. B. Milk intolerance and allergic reactions to food vary among students and can range from mild to severe life-threatening anaphylactic reactions. Students may react to ingestion, touch, or inhaling the allergen. C. Every food allergy reaction has the possibility of developing into a lifethreatening and potentially fatal anaphylactic reaction. This can occur within seconds of exposure, or may be delayed to the next day after exposure to the allergen. D. Any food has the potential to cause an allergic reaction, although the most common are peanuts, tree nuts, milk, egg, soy, wheat, fish, and shellfish. E. Appropriate staff shall be trained on Emergency Response Preparation. It is recommended that a minimum of three (3) school staff be trained in cardiopulmonary resuscitation, in addition to the school nurse. PROCEDURES FOR MILK INTOLERANCE A. The parent of a student with milk intolerance must provide a letter every school year to the student’s school, stating the student’s milk intolerance and EFAB-R • Page 4 of 14 Regulation EFAB Student Food Allergies acceptable substitutions for the milk. For example, if the student is unable to drink milk, the note should specify what substitute beverage (i.e., soy milk, or lactaid) should be provided. VI. B. The note to the cafeteria manager and shared with the LCPS Nutrition Services Department Director, teacher(s) and the school nurse. No meeting with the parent is required to modify the diet for milk intolerance. C. The parent/student will inform coaches and sponsors of the student’s milk intolerance and drinks to avoid. D. The checklist for milk intolerance shall be completed and kept on file at the school and by the Nutrition Services Department (Form EFAB-E1). PROCEDURES FOR NON LIFE-THREATENING ALLERGIES A. When a parent of a student with a non life-threatening food allergy notifies the school, the parent must provide medical documentation annually. This update must include information concerning the student’s allergy, the foods that need to be avoided, and the appropriate treatment for reactions. Such statement shall, in the case of a student with disabilities, be signed by a physician, or, in the case of a student without disabilities, by a recognized medical authority. In addition, the parent shall provide a history of past allergic reactions, including triggers and warning signs. It is the parent/guardian’s responsibility to immediately update the school about any changes to the student’s condition or to treatment for reactions. B. The school nurse shall organize a meeting of the school-level multidisciplinary team to develop a plan specifying how the school will accommodate the student’s food allergies. The result can be a food plan or an individualized health care plan. If the student has an IEP, the plan can be documented on the IEP if the meeting corresponds with the annual IEP planning meeting, but it is not required. C. With parental consent, an informational sheet will be developed that includes the parental consent, the child’s photo, name of classroom teacher (elementary), and allergen(s). This information sheet shall be provided to the Nutrition Services Department, with copies kept in the substitute teacher folder and the school nurse substitute folder; and it shall be posted in the school kitchen area. D. The Nutrition Services Department shall provide comparable substitutions for the foods that need to be avoided for all documented food allergies as determined by the Plan. EFAB-R • Page 5 of 14 Regulation EFAB Student Food Allergies E. The checklist for Non Life-Threatening Food Allergies for each student with an identified food allergy shall be completed and kept on file by the Nutrition Services Department and the school nurse (Form EFAB-E2). F. The plan needs to be reviewed annually with the parent/school nurse and may be done in the spring of the year. If there are no changes, only new medical documentation and communication (review of checklist) with the new classroom teacher(s) is required in the fall. If the student is changing buildings, a new check list and a group meeting is needed. VII. PROCEDURES FOR LIFE-THREATENING FOOD ALLERGIES A. When a parent of a student with a life-threatening food allergy notifies the school, the parent must provide medical documentation. A recognized medical authority must provide a written update annually. This update must include information concerning the student’s allergy, the foods that need to be avoided, and the appropriate treatment for reactions. Such statement shall, in the case of a student with disabilities, be signed by a physician, or, in the case of a student without disabilities, by a recognized medical authority. In addition, the parent shall provide a history of past allergic reactions, including triggers and warning signs. It is the parent/guardian’s responsibility to immediately update the school about any changes to the student’s condition or to treatment for reactions. B. Upon notice by the parent, the Student Assistance Team (SAT) will meet to determine appropriate interventions. The team may also include the Associate Superintendent for Operations or his/her designee, and representatives from the LCPS Communications Department and the LCPS Health Services Department, as appropriate. C. The multidisciplinary team/student assistance team shall develop an Individualized Health Care Plan (IHCP) or 504 plan that includes an Emergency Action Plan (EAP) for students with Life-Threatening Allergies. The IHCP shall address each of the following: 1. Type of allergies designated by recognized medical authority; 2. School meal program, including dining area accommodations; 3. Cooking and classroom activities, including classroom rewards and parties; 4. Parent/guardian’s signed consent to administer all medications; 5. Description of student’s past allergic reactions, including triggers and warning signs: 6. Parent/guardian’s interest in participating in the training/orientation in the student’s classroom; 7. Notice that parents have been encouraged to provide their child with a medical alert identification; EFAB-R • Page 6 of 14 Regulation EFAB Student Food Allergies 8. After-school snacks if the child attends a school administered program; 9. If a child attends an after-school program on school property that is not administered by LCPS, the parent assumes the responsibility to notify the after-school provider of the student’s allergies and preventative measures to be taken; 10. Designation of staff responsible for administering medications and necessary training for administering the medications; 11. Bus transportation (to and from school routes), including health care plan, to deal with medications and emergencies; 12. Special care for field/activity trips, including bus and lunch coolers; lockdown/shelter in place. 13. The EAP will include photo, name, offending allergens, warning signs of reactions, and emergency management, including medications, and names of those trained to administer; and 14. Other information relevant to the individual. E. The multidisciplinary team, after reviewing all relevant medical data and careful consideration of the individual needs of the student with a life-threatening food allergy may consider further whether the school cafeteria should avoid serving peanuts or peanut products, or other allergens, not sell peanuts or peanut products in school-sanctioned stores or vending machines, or during schoolsponsored events. If requested, food labels that contain a listing of all ingredients shall be made available. F. As part of the Individualized Health Care Plan, the Superintendent may designate a school as “Food Allergen Friendly.” Should a school be designated as food allergen friendly, the school will display “nut-free” and allergen awareness signs at all public entrances and other public places. In such a case: 1. Faculty, staff, parents, students, and visitors shall be advised that they should not bring the allergens onto school property. 2. Food used in the classroom shall come from an approved list of safe foods. Food shall be packaged with an attached ingredient list. The student’s IHCP shall identify those foods to be avoided in the classroom. 3. EpiPen training shall be documented for each staff member, including nutrition services personnel, responsible for administering the EpiPen. 4. As a part of the food plan, Nutrition Services Department personnel shall be trained by Nutrition Services Department Administrators regarding food allergy, reading ingredient lists, and cross-contamination. EFAB-R • Page 7 of 14 Regulation EFAB Student Food Allergies VIII. GUIDELINES FOR ENTRY INTO SCHOOL FOR A STUDENT WITH A LIFE-THREATENING FOOD ALLERGY A. The school principal shall develop and implement a plan to ensure that all certified and non-certified staff, volunteers, monitors, security, and substitutes are fully informed of the contents of the IHCP, EAP and/or the 504 plan and receive appropriate training. The school principal shall ensure that a CPR trained employee is always present in the school when the student is in attendance. B. If appropriate, with written parental consent, other parents in the school community shall be informed of the food allergy. When necessary, a letter may be distributed from the principal, in consultation with the parent of the child with life-threatening food allergies, requesting cooperation for avoiding sending possible food allergens to school. C. Parents are encouraged to work with the Nutrition Services Department to preview food ingredient labels. D. Parents/guardians are responsible for providing all emergency medications as ordered by a recognized medical authority to be stored at school and required to safeguard the student. Parents/guardians bringing medications to school must follow instructions in the medication policy (LCPS Policy JLCD). E. Medications shall be appropriately stored in an easily accessible, secure location. Students are encouraged to carry their own epinephrine as soon as it is age and developmentally appropriate, with approval from the student’s physician, parent, and the school nurse. F. A “no eating” policy is enforced on all school district buses running to and from school routes, with exceptions made only to accommodate students with other health needs. Careful attention will be given to each case so students’ needs are met. (LCPS Parent and Student Transportation Handbook, Bus Regulations Governing Students, Regulation #11). G. The school nurse shall keep the student’s emergency action plan on file. Substitute nurses shall have access to all emergency medicines and care plans via the nurse substitute folder. A copy shall be given to the classroom teacher and care plans via the teacher substitute folder. The student may choose to carry a copy of the plan. H. The checklist for Life-Threatening Food Allergies for each student with an identified food allergy shall be completed and kept on file with the school nurse (Form EFAB-E3). _________________________________ Associate Superintendent for Operations June 29, 2011 __________________________ Date Approved EFAB-R • Page 8 of 14 Regulation EFAB Student Food Allergies History: revised 6.29.11 Legal Reference: USDA regulations 7 CFR Part 15b, CFR 300.130, CFR 104.1, 104.6 (a) Regulation EFAB-Appendix I STUDENT FOOD ALLERGIES APPENDIX I CONSIDERATIONS FOR THE DEVELOPMENT AND MANAGEMENT OF A PLAN FOR A STUDENT WITH A LIFETHREATENING FOOD ALLERGY A. CLASSROOMS 1. The classroom teacher shall have immediate and functioning communication with the school nurse by such means as an intercom, walkie-talkie, or cell phone. 2. Information shall be kept about students’ food allergies in the classroom; the teacher shall consider the food allergen when planning class projects, parties, holidays, celebrations, arts, crafts, science experiments, cooking, snacks, rewards, or other purposes. 3. For events that involve any food items being served in the classroom outside of school hours, desks and tables shall be washed with hot water and soap. 4. Students shall be informed of the dangers of food sharing or food trading in the classroom. 5. Recommendations for proper hand-washing techniques will be taught. B. SCHOOL FIELD TRIPS 1. The parent/guardian shall be responsible for determining the appropriateness of each field trip and consideration of safety on the field trip of the student with life-threatening allergies. 2. Teachers planning for field trips shall provide timely notification to the school nurse and parent/guardian (LCPS Policy IKB). 3. The parent, when signing a student permission form to participate in a field trip experience, may provide the name and phone number of the nearest hospital (and each hospital en-route). This information shall be part of the field trip chaperone’s emergency plan. 4. Medications including epinephrine auto-injector and a copy of the student’s EAP must accompany the student on the field trip. EFAB-R • Page 9 of 14 Regulation EFAB Student Food Allergies 5. A cell phone or other communication device must be available on the trip for emergency calls. 6. Parents of an LTA student shall be invited to accompany their child on school trips, in addition to the chaperone. 7. Field trips shall be chosen carefully; no student shall be excluded from a field trip due to risk of allergen exposure. C. SCHOOL BUS 1. Eating shall be prohibited on school buses. (LCPS Parent and Student Transportation Handbook, Bus Regulations Governing Students, Regulation #11). 2. School nurses shall train school bus drivers in risk-reduction procedures, recognition of allergic reaction, and implementation of bus emergency plan procedures. 3. School bus drivers shall be provided with the EAP of all students with LTAs. 4. The school bus shall have a cell phone or other means of communication for emergency calls. D. PHYSICAL EDUCATION AND RECESS 1. Teachers and staff responsible for physical education (P.E.) or recess shall be trained to recognize and respond to exercise-induced anaphylaxis, as well as anaphylaxis caused by other allergens. 2. Staff in the gymnasium, playground, and other sites used for recess shall have a walkie-talkie, cell phone, or similar communication device for emergency communication. 3. If, for safety reasons, medical alert identification (i.e., ID bracelet) needs to be removed during specific activities, the student shall be reminded to replace this identification immediately after the activity is completed. 4. A current epinephrine by auto-injector shall be readily accessible, and an adult staff member onsite shall be trained in its use. E. SCHOOL-SPONSORED AFTER SCHOOL ACTIVITIES 1. The school safety team shall post instructions for accessing Emergency Medical Systems - 911 (EMS) in all activity areas. 2. The adult staff member in charge shall be provided with the EAPs of all students who have life-threatening allergies. The EAP shall identify who is responsible for keeping epinephrine by auto injector during after school events. A current epinephrine by auto-injector shall be readily EFAB-R • Page 10 of 14 Regulation EFAB Student Food Allergies accessible, and an adult staff member onsite shall be officially trained in its use, for previously diagnosed students. 3. If, for safety reasons, medical alert identification, (i.e., ID bracelet) needs to be removed during specific activities, the student shall be reminded to replace this identification immediately after the activity is completed. F. NUTRITION SERVICES/CAFETERIA 1. Responsibilities of the Nutrition Services Department Director a. Be prepared to discuss menus (breakfast, lunch, and after-school snack); a la carte items; recipes; food products and ingredients; food handling practices; checking food labels for potential food allergens; cleaning and sanitation practices; and responsibility of various staff. b. Establish communications and training for all school Nutrition Services Department staff at the student’s school. c. Be prepared to make available food ingredient lists used in food production and service. d. Maintain food ingredients from each food served to a child with allergies for at least 24 hours following service in case the student has a reaction from a food eaten in the cafeteria. e. Maintain contact information for vendors and purveyors to access food content information. f. Understand the laws protecting students with food allergies as they relate to food services. 2. In the Cafeteria a. The school nurse shall provide cafeteria monitors with training in EpiPen administration, and shall train them to take note of the situation surrounding a child with allergies and intervene quickly to help prevent trading of food or bullying. b. All students eating meals in the cafeteria should be encouraged to wash their hands before and after eating so that no traces of allergens will be left on their hands. c. After each meal service, all table and chairs shall be thoroughly washed with soap and warm water. This shall include the use of dedicated water on peanut-free tables to avoid cross contamination. 3. School Principals The school principal shall be prepared to discuss content of all school vending machines. EFAB-R • Page 11 of 14 Regulation EFAB Student Food Allergies Regulation EFAB-Appendix II STUDENT FOOD ALLERGIES APPENDIX II EMERGENCY A. Response to Emergencies Schools with an identified student who has a life-threatening allergy shall include in their emergency response plan a written plan outlining emergency procedures for managing life-threatening allergic reactions. This plan shall identify personnel who will: 1. Remain with the student. 2. Assess the emergency at hand. 3. Activate the emergency response team (building specific, systemwide). 4. Refer to the student’s EAP. 5. Notify school nurse. 6. Notify emergency medical services. 7. Administer the epinephrine. 8. Notify parent/guardians. 9. Notify school administration. 10. Notify student’s primary care provider and/or allergy specialist. 11. Attend to student’s classmates. 12. Manage crowd control. 13. Meet emergency medical responders at school entrance. 14. Direct emergency medical responders to site. 15. Accompany student to emergency care facility. 16. Assist student’s re-entry into school. B. Practice drills shall be conducted at least once per school year. The drill shall be conducted during the first month of the school year. C. Returning to School After a Reaction 1. Students who have experienced an allergic reaction at school need special consideration upon their return to school. The approach taken by the school shall be dependent upon the severity of the reaction, the student’s age, and whether classmates witnessed the allergic reaction. EFAB-R • Page 12 of 14 Regulation EFAB Student Food Allergies 2. A mild reaction may need little or no intervention other than speaking with the student and parents and re-examining the IHCP. 3. In the event that a student has a moderate to severe reaction, the following actions shall be taken: a. Obtain as much accurate information as possible about the allergic reaction. b. Identify those who were involved in the medical intervention and those who witnessed the event. c. Meet with staff to discuss the incident and dispel any rumors. Do not assign blame. d. Document the incident per LCPS protocol. Take appropriate action based on the evidence to prevent further occurrences. e. If an allergic reaction is thought to be from a food provided by the school district, request the assistance of the Nutrition Services Department Director to ascertain what potential food item was served/consumed after a review of food and/or labels. f. Review the EAP described in the IHCP. g. The student and parent(s) may meet with the nurse/staff who were involved in the allergic reaction to be reassured about the student’s safety, what happened, and what changes will be made to prevent another reaction. h. Amend the student’s EAP, Allergy Action Plan, and/or the school’s emergency response plan to address required revisions. i. The emergency team shall conduct an after-action review of the incident to determine the effectiveness of the emergency response plan and to determine what procedures, if any, need to be revised. The emergency plan shall be changed as appropriate. D. Special Considerations for the Student 1. Staff should be aware of the potential for anxiety, and the potential for further consultation with the student’s physician. If a student demonstrates anxiety about returning to school the school counselor may check, in with the student on a daily basis until his/her anxiety is alleviated. If a child has a prolonged response to an anaphylactic event, strategies should be reviewed, and clinical intervention may be recommended to the parent. 2. It is important to keep in mind that a student will continue to need to access help if another allergic reaction should occur; therefore, make sure a student feels comfortable enough to seek help, if needed. It is critical that students not withhold information out of embarrassment or because of intimidation. EFAB-R • Page 13 of 14 Regulation EFAB Student Food Allergies 3. A food allergy incident may result in stress for other students with food allergies. As such, other students with food allergies in the school system may be in particular need of support. EFAB-R • Page 14 of 14