STATE OF LOUISIANA
FOOD DISTRIBUTION PROGRAM
PROCEDURAL HANDBOOK
NATIONAL SCHOOL LUNCH PROGRAM
LOUISIANA DEPARTMENT OF AGRICULTURE & FORESTRY
NOVEMBER 2010
TABLE OF CONTENTS
I.
INTRODUCTION ..................................................................................................................... 1
II.
REFERENCE MATERIALS ..................................................................................................... 2
III.
ELIGIBILITY/AGREEMENTS ................................................................................................ 3
IV.
AVAILABLE COMMODITIES ................................................................................................. 4
V.
ALLOCATIONS AND ORDERING .......................................................................................... 5
VI.
USE AND SALE OF USDA COMMODITIES .......................................................................... 7
VII.
RECEIVING COMMODITIES ................................................................................................. 8
VIII.
STORAGE AND CARE OF COMMODITIES ......................................................................... 11
IX.
INVENTORY RECORDS ........................................................................................................ 15
X.
PROCESSING ......................................................................................................................... 16
XI.
TRAINING .............................................................................................................................. 22
XII.
THE SCHOOL ROLE IN A DISASTER ................................................................................. 23
XIII.
FOOD ALERT/RECALL SYSTEM ......................................................................................... 25
XIV.
COMPLAINT SYSTEM........................................................................................................... 33
XV.
REDISTRIBUTION OF DONATED FOODS ......................................................................... 33
XVI.
RECORD RETENTION REQUIREMENT ............................................................................ 33
XVII.
REVIEWS................................................................................................................................ 34
XVIII. PROGRAM TERMINATION ................................................................................................. 34
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I. INTRODUCTION
The United States Department of Agriculture's (USDA) Food Distribution Program (FDP) is a
multi-purpose program designed to improve the nutritional quality of the diets of people who participate in
the program. In addition, it supports agriculture through price support and surplus removal programs.
The foods are made available to the Louisiana Department of Agriculture and Forestry (LDAF) for
distribution to eligible outlets such as school food authorities (SFAs).
The purpose of this handbook is to provide guidance and explain to SFAs the operation of the FDP.
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II. REFERENCE MATERIALS
A. USDA REGULATIONS AND INSTRUCTIONS
The FDP is authorized by the U.S. Congress through several pieces of legislation. The primary pieces of
legislation which enable the various commodities to be provided are:
---Section 32 of the Agricultural Act of 1935, which authorized the purchase and distribution of
perishable commodities in order to remove surpluses and stabilize farm prices;
---Section 6 of the National School Lunch Act of 1946, which mandates a per-meal commodity assistance
rate for schools participating in the National School Lunch Program (NSLP); and
---Section 416 of the Agricultural Act of 1949, which authorizes the purchase and distribution of
commodities for the purpose of supporting farm prices.
Regulation and instructions are issued by USDA based upon the enabling legislation. Copies of pertinent
regulations (e.g., Code of Federal Regulations (CFR) 210, 250, 252, etc.) are available at
www.fns.usda.gov/fdd. In addition to regulations, formal instructions and policy memoranda are issued
to provide more detailed guidance in dealing with specific areas of the program.
B. USDA FACT SHEETS AND STANDARDIZED RECIPIES
1. Fact Sheets on individual commodity items are available on the internet at www.fns.usda.gov/fdd.
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III. ELIGIBILITY/AGREEMENTS
According to Federal Regulations, a school is defined as an educational unit of high school grade or below
operating under public or nonprofit private ownership. The term "high school" grade or below includes
classes of primary or higher grade or when they are recognized as part of the educational system in the
State, regardless of whether such pre-primary classes are conducted in a school having classes of primary
or higher grade. Additionally, schools must be in compliance with civil rights requirements. SFAs that
are eligible to participate are those SFAs that have obtained approval for the NSLP through the Louisiana
Department of Education, Division of Nutrition Assistance.
Prior to approval to participate in the FDP, the SFA must sign an agreement with the LDAF which
identifies the responsibilities of SFAs receiving donated foods. The agreement includes accountability,
storage, use or disposition of donated foods, and penalties for misuse of donated foods. Once approved,
agreements are permanent unless terminated as provided in the agreement.
SFAs are required to
provide, by amendment, on a timely basis, changes of pertinent information regarding program
administration, including any changes in site locations or authorized representatives.
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IV. AVAILABLE COMMODITIES
Schools are eligible for a certain dollar level of commodity assistance based on the number of lunches
served multiplied by the mandated rate of assistance. This is referred to as planned assistance level
(PAL). Commodities that are offered to SFAs against the dollar amount of their PAL are considered
entitlement foods.
Other foods that are offered to SFAs that are not offered against the PAL are
considered bonus commodities.
Commodities generally available include frozen meat and poultry; and canned and frozen fruits which are
known as “Group A” foods. Purchases for “Group A” foods are made on a seasonal basis. Vegetable oil,
various cheeses and grain items are known as “Group B” foods and are available on a year round basis.
The commodities that USDA donates may vary depending on what food products are available.
Bonus commodities may be offered from either Group A or Group B foods.
All of the commodities that USDA purchases must be certified by the USDA's inspection services to assure
they meet established specifications. Only high grades of meats, fruits, and vegetables are accepted.
Specifications for the quality of the commodities purchased are constantly updated. Recently revised
specifications have reduced the fat, sugar, and salt contents of foods purchased.
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V. ALLOCATIONS AND ORDERING
A. DETERMINATION OF STATE PAL
Each year USDA provides the LDAF a State Planned Assistance Level (PAL). This PAL is determined by
multiplying the number of reimbursable lunches served in the prior year by the current commodity
assistance rate.
The LDAF in turn allocates the state's PAL among all SFAs using the same methodology.
NOTE: Breakfast data is not included in this computation; however, commodities may be
used for this meal.
The LDAF is then expected to make available dollars/food to SFAs in an equitable (not necessarily exact)
manner. In addition to the basic proration of the PAL the LDAF is expected to consider inventory levels,
usage rates, storage capabilities, shipping restrictions, and ethnic and local preferences in the allocation of
commodities to each SFA. SFAs are expected to allocate to their schools in the same manner.
B. ORDERING COMMODITIES
SFAs must order only quantities of food that can be used and stored without waste and must have
adequate facilities for the amount of food requested or accepted. SFAs may refuse up to 100% of the
commodities offered to their program.
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Except in unusual circumstances, SFAs should not have more than a six-month supply of commodities on
hand at any time and must notify the LDAF promptly if supplies exceed this limit. (Calculate the number
of months of supply by using previous rates of use). Additionally, school commodity inventory levels
should be reduced toward the end of the school year. SFAs have until the 15th of the month to revise an
order for the next month by contacting their area LDAF Food Distribution Field Supervisor. Ordering
procedures for each category are explained as follows:
Most commodities are ordered on an annual basis. Ordering information (Estimated PAL, Commodity
Information, and Available Shipping Periods, etc.) is sent out in mid November and is usually due back in
the Food Distribution Office in early February.
An example of the ordering packet is included.
(Attachment 1)
School Districts have the ability to utilize their PAL in the way which best suits their individual needs.
This includes Group A and Group B commodities, Department of Defense (DOD) Fresh Produce Program
and the further processing program.
In addition, during the year special offers of limited commodities are offered through the use of email.
Therefore, it is vital that if you have any change in your email address that you notify our office.
C. Department of Defense Fresh Produce Program
This program allows SFA’s to utilize a portion of their PAL if they so choose to purchase fresh produce
from the Department of Defense (DOD) fresh produce vendors. For further information on this program
you may contact the Food Distribution Division.
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VI. USE AND SALE OF USDA COMMODITIES
Commodity foods are made available to schools to improve the quality of lunches served to children.
USDA and LDAF requires participating schools to use donated food in the preparation of required
foods items or side dishes of the reimbursable lunch. In addition, donated foods may be used in the
preparation of meals served in the School Breakfast Program.
The use of donated foods may also be used in the following school activities:
a.
Training students in home economics and the Nutrition Education and Training (NET)
Program.
b.
Extra Sales - Items sold in conjunction with the NSLP are to be individual serving items
intended to be consumed on the premises, and all proceeds shall benefit the school's
non-profit food service program.
c.
Workshops, demonstrations, and tests relating to the utilization of such donated food by the
SFA.
d.
Any school related functions where the primary beneficiaries of the food are the students
themselves. In cases where the use of USDA foods cannot be avoided, e.g., schools using
single inventory management, the SFA must ensure that the nonprofit school food service
account is reimbursed for the use of USDA foods in such activities, in addition to the
reimbursement for other resources utilized. Further, USDA prohibits SFAs from increasing
their orders for USDA commodities for the purpose of supporting school related functions
other than the NSLP and the School Breakfast Program (SBP).
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VII. RECEIVING COMMODITIES
There are two basic methods for SFAs to receive commodities. The first involves commodities being
delivered, free of charge, to the SFA once a month (August through April) by the LDAF.
The other
involves the SFA picking the commodities up at a LDAF warehouse.
The first method has always been done as a service to the SFA since there is no regulatory requirement for
commodity delivery. The SFA should send a written request for commodity delivery to the LDAF.
(Delivery is restricted to those SFAs receiving commodities in truckload quantities).
Once approval for delivery has been granted, the SFA will be contacted by the LDAF commodity driver
each month to schedule a delivery time. The driver will contact the SFA at least 24 hours in advance of
actual delivery.
If for some reason the SFA subsequently cannot accept delivery at the scheduled time, an alternate time
will be arranged whenever possible. However, if for any reason delivery is not made within the current
month, it is then the responsibility of the SFA to pick up the commodity order and pay for any subsequent
storage charges.
The second method is for SFAs to make their own delivery arrangements. The SFA must contact their
LDAF warehouse to schedule an appointment for commodity pickup at least 24 hours in advance.
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The SFA must present the Order Acknowledgement (original is preferred, but a copy will suffice) to the
LDAF warehouse at the time of pickup or commodities will not be released. The SFA must pick up
commodities in a vehicle that ensures the commodities are transported at required temperatures. The
SFA must also ensure that all personnel involved in commodity pickup, with the exception of the driver or
the person in charge, remain outside of the warehouse. As with the first method, if the commodity order
is not picked up within the current month, the SFA is responsible for any subsequent storage charges.
Irrespective of the system by which commodities are received, there are general procedures which should
be followed:
A.
SFAs must verify that the product and quantity received is the same as that identified on the
Order Acknowledgement (ATTACHMENT 2) and/or Pick Ticket (ATTACHMENT 3).
B.
SFAs must verify that the product is in good condition - not damaged, spoiled, or infested.
SFAs' signature is required upon receipt of product for verification of Statement A and B.
SFAs are encouraged to check the temperature of delivered commodities and indicate on the Pick
Ticket if the temperature appears to exceed the following maximums:
Item
Freezer
Cooler
Dry Storage
Temperature
10 °F
40 °F
70 °F
If any food is found to be out of condition it must be segregated from the good food.
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C.
The Pick Ticket is to be signed and dated by a representative of the SFA and the delivery
person. Note any exceptions with the count or condition of the commodities at time of receipt on the
Pick Ticket. If exceptions are noted, return one copy of the Pick Ticket to the Distributing Agency
within five (5) days of receipt of the commodities.
D.
Follow local policy regarding the inspection and destruction of any damaged, spoiled, or
infested product. (Note-product of this nature is not to be returned to the LDAF warehouse).
E.
Mark and date commodities when received at each storage location (using month, day and
year) to allow easy identification and proper stock rotation.
F.
Notify the LDAF immediately of any significant problems.
G.
Obtain reliable thermometers for dry storage areas, coolers and freezers.
H.
Commodities in torn sacks, broken cartons, etc. should be repackaged and stored in a separate
room until used or disposed of.
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VIII. STORAGE AND CARE OF COMMODITIES
A SFA is responsible for taking prudent and reasonable care of USDA commodities after taking possession
of them. Possession includes transfers within a warehouse from the state account to the account of the
SFA. Adequate personnel for handling, accounting, preparation and use must be provided.
A. STORAGE
1.
Food should not be placed directly against walls or on the floor, but should be stored on
pallets, shelves, dollies, etc. Hot water heaters and other heat producing conditions should not
exist in the dry storage area where commodities are stored.
2.
Separate food items and non-food items.
3.
Have an adequate storage area that is clean and utilize other good housekeeping practices as
required by USDA and the state sanitation code.
4.
Thawed items should never be refrozen.
5.
Commodities must be stored in the original shipping containers. Bagged items which are
opened must be stored in clean containers with tightly fitted lids.
6.
All USDA foods should be stored at proper temperatures as specified on the packaging,
warehouse industry standards, fact sheets, specifications and/or LDAF guidance.
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B. COOLER/FREEZER CHECKS
SFAs must check coolers/freezers at least every other day even during vacation and holiday periods. The
only allowable exception is if a recipient agency is not able to make cooler/freezer checks on weekends, in
which case checks should be made late Friday afternoon and early Monday morning.
Automated alarm systems may be used if they produce documentation showing each time the acceptable
range is exceeded. The acceptable range for freezers shall be zero degrees Fahrenheit or below, and the
cooler standard range shall be 35 to 45 degrees Fahrenheit. Temperature logs produced by automated
alarm systems must show the date and temperature range of the refrigeration unit monitored.
Documentation is required each time the acceptable range is exceeded. SFAs that do not use automated
alarm systems must maintain temperature logs (ATTACHMENT 4 AND/OR 5) that show the exact
date and time of each check, the recorded temperature, and the signature and title of the person
conducting the check. (Initials and/or abbreviations are not acceptable).
C. INSECT AND RODENT CONTROL
SFAs must protect all USDA donated commodities from insect and rodent infestation, including
fumigation and extermination as required. It is recommended that pest control be performed once a
month at a minimum. If a commercial pest control firm is used, receipts should be on file and available
for review. If pest control is performed by SFA personnel, the Integrated Pest Management (IPM) plan
should be available for review. There must be no external openings in the structure of the buildings in
which foods are stored that would allow rodent and insect infestation. SFAs must not store donated foods
on floors or against walls of storage areas.
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D. STOCK ROTATION PROCEDURES
Federal policy requires that first-in/first-out (FIFO) procedures be followed. The packing date on the
cases should determine the order in which foods are used if available. (The reason for this is that food is
sometimes purchased and shipped by vendors who have packed the food the previous year and/or stored
it for a period of time.).
E. THEFT CONTROL
SFAs must supply secure locks on buildings in which donated commodities are stored and should lock
freezers/coolers and other storage areas separately.
F.
GUIDELINES FOR PROPER RECEIVING, HANDLING, AND STORAGE OF USDA
DONATED FOODS
1.
Mark and date commodities (using month, day and year) when received.
2.
Store new shipments of commodities in back of the older shipments to facilitate removal of old
stock first.
3.
Store food items on dollies, platforms, or skids off the floor, away from walls and no closer
than 15 to 18 inches to the ceiling or cross beams.
4.
Store identical and/or similar food items together.
5.
Store commodities that absorb odors away from those that give off odors.
6.
Apply good housekeeping practices daily to ensure orderliness and cleanliness in all areas of
the storeroom.
7.
Obtain reliable thermometers for dry storage areas, coolers and freezers.
8.
Keep dry storage areas well ventilated by either natural or mechanical devices to remove
moisture, which prevents mustiness and retards the rusting of metal containers.
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9.
Commodities must not be stored in a storeroom with un-insulated pipes, water heaters,
refrigeration condensing units, and other heat-producing devices.
10.
Store commodities subject to insect infestation in separate sections of the storeroom to
minimize the possibility of insect infestation spreading from one group of commodities to
another.
11.
Commodities in torn sacks, broken cartons, etc. should be repackaged and stored in a separate
room until used or disposed of.
12.
Do not store items such as paint, kerosene, gasoline, oils, napthaline, cleaning supplies
(including soap, wax, polishes, etc.), in the same area with commodities. A separate storage
room should be provided for such items.
G. ANNUAL REVIEW OF STORAGE FACILITIES
The SFA shall conduct an annual review of all storage facilities/sites (individual schools, pantries,
storerooms, warehouses, etc.) prior to June 30 of each year.
The Annual Storage Site Review
(ATTACHMETN 6) is to be used for this purpose, if deficiencies are found during the review, a copy of
the Annual Storage review and a corrective action plan shall be submitted to the State Distributing
Agency. DO NOT SUBMIT A COPY OF THE REVIEW TO THE STATE DISTRIBUTING AGENCY IF
THERE ARE NO DEFICIENCIES. A copy of the completed Annual Storage Review shall be kept on file at
each site and the SFA's office.
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IX. INVENTORY RECORDS
SFAs must maintain accurate and complete records of USDA commodities. Two types of inventories are
required. They are:
1)
Perpetual Inventory - A Perpetual Inventory Record (ATTACHMENT 7) reflects the amounts
of foods in stock for each item and the quantities of food moving into and out of storage over
given periods of time. A perpetual inventory must be kept at each site and central location. It
is recommended that items be withdrawn at the site by the smallest usable unit.
2)
Physical Inventory - A complete physical inventory of all foods on hand must be taken on the
last working day of the month.
Perpetual inventories must be reconciled with physical inventories monthly.
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X. PROCESSING
A. PURPOSE OF PROGRAM
The purpose of the USDA Donated Food Processing Program is to allow eligible SFAs to utilize approved
commercial food vendors to process or repackage certain USDA donated foods into approved end
products.
B. OVERVIEW OF PROCEDURES
A SFA must first determine what processed food products it would like to receive and which processors
are capable of producing that product using USDA commodities. If the company and product are not
already approved by the LDAF, the SFA must send a written request to have the processor approved for
participation in the donated food processing program. The request must also specify the end product(s)
including name and product code(s) for which approval is desired.
A State Participation Agreement (SPA) is a written document approved by the LDAF which authorizes a
commercial food processor to convert USDA donated foods into more convenient forms. The agreement
sets forth the terms and conditions under which donated food will be provided to the processors and the
terms under which the processor will utilize donated food in the production of end products for eligible
SFAs. After the LDAF has approved an agreement with a processor, a SFA eligible for the donated food
may purchase the specific end product(s) approved under the agreement. The LDAF grants this authority
to SFAs in the Agreement for Distribution and Use of Donated Foods.
Commodities may be transferred to a processor in two ways. Backhauling occurs when the processor
picks up commodities that have been allocated to the SFA and is in the possession of the SFA either at the
SFA’s warehouse, school(s), or at another storage facility. The LDAF must be notified in writing prior to
the release of donated foods to the processor for backhauling. The amount, item, storage location, date of
release, and estimated return date must be included. SFA’s that are large enough to
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receive commodities in truckload quantities may make arrangements with the LDAF to divert donated
commodities to processors. Other SFA’s may participate in the diversion of commodities for processing
as members of a group or cooperative.
C. PROCUREMENT STANDARDS
When purchasing foods for use in food service programs, the SFA must comply with Federal, State and
local procurement standards. The primary purpose of these standards is to assure that open and free
competition exists to the maximum extent possible. When the LDAF or USDA enters into an agreement
with a company to process donated food(s), this does not remove responsibility of the SFA to comply with
the procurement standards. The processing agreement permits the company to receive donated foods to
process into end-products, but it does not establish the price which the SFA pays. The procurement
procedures used by the SFA should establish the price to be paid by the SFA for all foods, including those
end-products containing donated foods. The SFA, as purchaser, has the responsibility to evaluate prices
received and to determine the successful bidder.
Bids received for approved end-products containing donated foods which will be purchased under the
discount system should clearly state the full price (before deducting value of donated foods), the value of
donated foods and the net price.
As part of the procurement activity, the SFA should ensure that acquisition of an end-product containing
donated food is cost-effective. Determining cost effectiveness is a simple process but extremely important
in demonstrating good management and ensuring maximum benefits are obtained from the resources
expended. To determine if purchasing a particular end-product containing donated foods is cost-effective,
the SFA should perform the following steps:
1.
The value of donated food contained in the end-product should be added to the cash (net)
price to arrive at the total cost of the item.
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2.
Gross (without value of donated food) prices for the same and comparable products being sold
in the area should be obtained.
(Note:
Delivery charges and all other costs should be
included.) Consideration should also be given to including the SFA's cost to produce the same
item if the SFA actually has the capability for such production.
3.
The total cost of the item being considered should be compared with the cost data obtained.
4.
If the cost of the item (including the value of donated food) being considered is approximately
the same as others, then it could be considered cost-effective. However, if the total cost
(including the value of donated food) of the item being considered is significantly higher, then
it is not cost-effective.
D. END PRODUCT CERTIFICATION
It is the responsibility of each school system to decide the level of certification they will require:
CN label, product formulation statement, letter of guarantee, or none of these.
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E. END PRODUCTS AVAILABLE
The LDAF will provide to the SFAs at the beginning of the school year any relevant information
concerning processing agreements approved by both the LDAF and USDA.
F. VALUE OF DONATED FOOD
The value of donated food contained in a case of end-product is determined by multiplying the number of
pounds contained in each case of donated food by the established price per pound. This per-case amount
is identified on the End Product Data Schedule (EPDS) for each approved item and may be obtained from
the processor.
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G. VALUE PASS-THROUGH SYSTEMS
An agreement for processing of dated foods allows the SFA to purchase end products at a reduced price
because the value of the commodity is deducted from the gross purchase price. This is known as Value
Pass-Through Systems.
LDAF allows three types of systems to ensure that SFAs are provided the full value of donated foods
contained in approved end products. These systems are known as discount and fee-for-service.
Discount -- The SFA purchases an approved end product directly from the processor or from a distributor
and is billed at a net price. The net price is determined by reducing the agreed-upon full (gross) price by
an amount at least equal to the value of donated food contained in a case of approved end product.
The billing procedure may be handled in one of two ways. First, the invoice would show the full price, the
reduction for the value of donated food(s), and the net price. Alternatively, the invoice may show only the
net price if a bid or other written document is on file and clearly indicates that the net price is the full
price reduced by the proper value of donated food.
Refund (or Rebate) -- The SFA purchases an approved end product directly from the processor or a
distributor at the commercial/gross price of the end product.
Refunds that reflect the value of the
donated food contained in the end product shall be made to the SFA by the processor upon proof of
purchase.
The refund payments shall be initiated or paid as follows:
1.
The SFA shall submit a refund application to the processor within 30 days from the end of the
month of date of delivery. SFA’s may submit refund applications to the processor on a quarterly
basis if the total refund due is $25 or less during the quarter.
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2. Within 30 days of the receipt of a refund application, the processor shall compute the amount and
issue payment of refund directly to the SFA. Processors may issue payment of refunds on a
quarterly basis if the total payment due to that SFA is $25 or less during the quarter.
Fee-for-Service -- The SFA pays a fee-for-service per pound or per case, which represents the processor’s
costs of ingredients (other than the donated food), labor, packaging overhead and other costs incurred in
the conversion of the donated food into specific end products.
The billing procedure will depend on whether or not a distributor is involved. If not, the processor will
bill the RA for the agreed upon fee-for-service plus delivery charge. If so, two options are allowed: 1) the
processor will bill the RA for the fee-for-service and the distributor will bill the RA for storage and
delivery of the end products; or 2) the processor will bill the RA for his portion and the distributor's
portion. The invoice must show the processing fee and the distributor's charges as separate, identifiable
charges.
The SFA must not pay a fee-for-service to the processor for any item in excess of the maximum identified
on the approved end product data schedule for that item.
H. RECORD KEEPING
SFAs must follow the same procedure for record keeping and handling processed foods as are used for
purchased foods.
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XI. TRAINING
SFAs should have a continuing training program for local staff on all program and regulatory areas.
Training should provide for consistent, standardized program interpretation and implementation as well
as help ensure that commodities are handled and utilized properly. Training can be conducted formally
through workshops, newsletters, etc., and informally through technical-assistance visits, phone calls, etc.
SFAs should base their training on needs assessments gathered from sources such as review findings,
self-monitoring evaluations, problem areas, program changes and new policies. All training should be
documented by, at a minimum, the agenda and a list of attendees (ATTACHMENT 8) may be used for
this purpose).
A. SUGGESTED TRAINING TOPICS
1.
Proper receiving and receipting of foods
2.
Labeling and dating
3.
Storage requirements
4.
Safe handling of foods
5.
Inventories
6.
Efficient utilization of commodities (e.g., recipes, menu development, taste tests)
7.
Record Keeping
8.
Commodity Fact Sheets
9.
Processing procedures
10.
Monitoring school operations
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XII. THE SCHOOL ROLE IN A DISASTER
Hurricanes, tornadoes, floods, chemical spills, and other disasters may generate a need for congregate
(mass) feeding. Irrespective of the type of disaster, the response from USDA, the LDAF and SFAs will
remain the same.
Any food donated by USDA can be used in disaster feeding. Recognizing the emergency and the need to
feed people, SFAs having USDA donated commodities must cooperate fully and make these foods
available to groups involved in disaster feeding activities.
In disaster situations, schools are authorized to release for congregate feeding activities any USDA
donated foods in schools, other recipient agencies or other storage locations under contract to them with
prior approval of the LDAF.
The American Red Cross is the primary disaster organization, but USDA, directly and through SFAs, will
provide foods to any recognized agency equipped to serve disaster victims. The Salvation Army, many
religious denominations, civic organizations, unions and others are able to provide food preparation for
congregate service. USDA has no foods specifically designated for disaster feeding and must depend on
foods in LDAF warehouses, and at the schools. USDA foods are not always available in quantity to fill all
needs, but they do provide a good supplement to those provided by the disaster agency.
In most cases the Red Cross or other disaster organizations will provide a trained shelter manager and, in
many cases, personnel to operate the kitchen and food service facility. If school food service personnel
help in the feeding operation, funds are available from local, state, federal, and disaster organizations to
pay for them.
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Accurate records must be kept by the school of all foods provided or used for disaster feeding purposes.
Signed receipts (Donated Food Commodity Redonation Statement, (ATTACHMENT 9) should be used
for all foods transferred to disaster feeding organizations. The SFA will be asked to provide verbal
information on foods used/transferred and numbers of people fed (if it is doing the feeding) on an
immediate basis. The Disaster Feeding Reporting Form (ATTACHMENT 10) must be completed and
submitted to the State Agency within 72 hours after termination of emergency feeding operations.
Prompt reporting will permit USDA to replace donated foods provided or used with the same or other
desirable foods at an early date.
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XIII. FOOD ALERT/RECALL SYSTEM
This policy establishes food alert/recall system procedures for communicating effectively and quickly with
all SFAs whenever there is an urgent concern about the safety, wholesomeness or condition of donated
foods.
A. SCHOOL FOOD AUTHORITY PROCEDURES:
Administrative Level
1.
Develop a standard operating procedure before receiving notification of a food alert/recall. The
standard operating procedure should include an itemized list of steps to be taken, persons
responsible for each step, and detailed procedures to be followed at each step.
For USDA
commodity foods, a responsible person needs to be appointed to coordinate food safety; typically,
this appointee is the food service district director. The name, title, email address, and phone and
fax numbers for this person should be provided to the State Distributing Agency.
2. Review the food alert/recall notification report when it is received. Determine the problem as
stated in the food alert/recall, review the specific directions in the communications and determine
actions that must be taken.
3. Communicate information about the food alert/recall to the sites ((schools, contract feeding sites,
central kitchens, etc.) as quickly as possible in a manner that assures the information has been
received and site managers/technicians understand their responsibilities. For USDA commodity
foods, the school district must immediately notify sites of the recall, identify the
location of the affected products, verify that the food items bear the product identification codes,
isolate the commodities to avoid accidental use, and take an accurate inventory by location.
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4. Collect health related information needed for public communications. The seriousness of the
health risk determines the classification of a recall. For information on a specific product contact
the State Agency or public health department. For Class I or Class II recalls document the
following information: whether any of the product was served, to which classes (groups of
students and other customers), the date(s) served, and any reports of possible health problems
related to the recalled product including physical symptoms of illness and any actions taken.
5.
Work closely with the school district’s public communications person. Notify
this person so that one person is prepared to handle public communications, including contact
with health agencies, local media, and parents.
6. Locate the product affected by the food alert/recall. Identify whether any of the
product was actually received in the school district and if so, identify the sites where the affected
product is located, and verify that the food product containers bear the product identification
code(s) listed in the recall notice.
7.
For each site, obtain an accurate inventory count of the product and the amount already used.
8. Verify inventory counts against records of foods received at the sites to assure that all food has
been removed from potential use.
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9. Obtain confirmation from each site that the product has been segregated from other food
products and secured so that it will not be used.
10. Take action to conform to the food alert/recall:
Step 1: Submit information to the manufacturer, distributor, or State agency describing the
quantity of the product in stock and the storage site. For USDA commodity foods, information
regarding the quantity of the product in stock and the storage site where the commodity is located
must be submitted to the State Distributing Agency within 10 calendar days of the recall to
expedite removal, replacement, and reimbursement.
Step 2: Determine if the food item is to be returned (to whom), or destroyed (by whom). If the
information on how the item is to be returned or destroyed has not been provided in the food
alert/recall notice, determine who in your school district is responsible for obtaining the
information. Address your questions through this person. The person responsible should be
designated in the standard operating procedure.
Step 3: Notify site personnel of the procedures, dates, etc. to be followed for collection or
destruction of the product affected by the food alert/recall.
Step 4: Product to be returned: Follow the written instructions in the recall notice for returning
the food product. For USDA commodity foods, in the majority of situations the product will be
collected by the distributor to be returned to the vendor. School districts will work with the State
Distributing Agency and the contracted warehouse/distributor to
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determine the appropriate method and time frame for collecting the product affected by the food
alert/recall. If the distributor delivers to a central location in the school district, it is the district’s
responsibility to consolidate the products from affected schools to a central location within the
district’s area of responsibility. The product should be consolidated for collection as soon as
possible but no later than 30 days after the date of the recall notice.
Step 5: Product to be destroyed on-site: Do not destroy any USDA commodity product
without official written notification from FSIS or FDA. Follow manufacturer’s or
distributor’s recall notification instructions for purchased food products. If the food
product is to be destroyed on-site, determine the procedures for on-site destruction of food
products, who should be present, and who must be notified of the process. Due to the potential of
health risk to humans or animals, some State public health departments require notifications of
all food products to be destroyed before any action is taken.
11. Consolidate documentation from all sites for inventory counts.
12. Determine reimbursable costs for commodity food items.
Contact the State agency or
manufacturers for information on reimbursement for recalled foods.
13. Submit necessary paperwork for reimbursement of food costs. For purchased foods, check with
the distributor for protocol on reimbursement. For USDA commodity foods, school districts and
independent schools will receive necessary paperwork from the State Distributing Agency at time
of recall.
14. Complete and maintain all necessary documentation related to the recall for three years plus the
current year.
15. Maintain copies of any communications received or sent in relation to the food recall for three
years plus the current year.
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16. Maintain files of information provided to the school district public communications contact
person; other media contact(s)
and the public; and adverse health reports and subsequent
actions for three years plus the current year.
School Site Level
1.
Identify the food product affected by the food alert/recall immediately. Food alerts/recalls are for
specific foods from a named manufacturer or source. For example, if chicken nuggets with the
Product Code 26091 from XYZ manufacturer were part of the alert/recall, it does not mean
chicken nuggets from all manufacturers or even all chicken nuggets produced by the XYZ
manufacturer are part of the alert/recall. Each alert/recall is specific to a product code and a
specific production run. It is important to identify the product code, lot number, and pack date
listed in the alert/recall notice. Use the code and date to check any product in inventory. The
accurate way to identify the product is by reading the label. The best practice is to learn the
product label and maintain complete records of deliveries and invoices.
2. Determine if you have any of the food product on hand and take necessary actions to hold the
product to prevent its use until final action or removal can take place. Immediately physically
segregate the product, including open containers or leftover product. Segregate suspect open
containers that are unlabeled and do not contain product codes and any food items in current
production that may contain the food product affected by the food alert/recall. Mark the product
“DO NOT USE” and “DO NOT DISCARD.” Inform the entire staff not to use the marked product.
Document the quantity in inventory.
3. Determine if the food product has been used. Some ways to determine if the product has been
used include reviewing invoices, production records, inventory records, and menu records.
4. Account for all food product that was received. Add the count for the amount of product in
inventory and the amount already used; the sum should equal the total amount that was received.
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This step is necessary to make sure that all product involved in the alert/recall has been removed
from potential use.
5.
If the recalled product has been used, document the date(s) used and to whom it was served
(classes, not individuals).
6. If you have had any reports of health problems that could be related to consumption of the
product affected by the alert/recall, direct anyone affected to appropriate medical personnel or
the school nurse. Collect the information to submit to the school district central office including
persons’ names, reported symptoms of physical illness, and actions taken.
Only health
professionals should give medical advice.
7.
Submit to the district central office the following information:
a.
Inventory counts of the product affected by the alert/recall that was on hand at the time
of the alert/recall and counts or amounts of the product used before the alert/recall
notice was received.
b. How the product affected by the alert/recall was segregated from other food products and
secured to prevent further use.
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c.
Information on whether the product was served; if it was served, provide information on
to whom it was served and the date(s) served.
d. Reports of symptoms of adverse health problems and actions taken.
8. Follow instructions given by the central office for collection, return, or destruction of the recalled
food product.
9. Complete any necessary documentation for collection, return or destruction, and reimbursement.
10. Submit necessary documentation to the school district’s central office.
11. Maintain copies of documentation on file for three years plus the current year including:
a.
Copies of communications received and sent regarding the food alert/recall.
b. Documentation related to the food alert/recall that shows the required procedures were
followed including:
1.
How the product was secured to prevent use.
2.
Return of the product - to the distributor/manufacturer or to the central
office/warehouse.
3.
Destruction of the product on-site and accompanying written notification to do
so.
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4.
Records that show the date product was used and to whom it was served.
5. Reports from customers of symptoms of physical illness.
NOTE: All SFA’s are encouraged to utilize the USDA/FNS Commodity Alert System which delivers
instant notices of food issues from the USDA. This service is provided free of charge, can be individually
customized, and notices are broadcast to email.
To sign up for this free service please go to
envoyprofiles.com/usda-alerts and follow the instructions provided.
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XIV. COMPLAINT SYSTEM
Schools may use the Commodity Complaint Form (ATTACHMENT 11) to report to the LDAF any
problems with USDA commodities. The form should be fully completed by the SFA. The information will
be forwarded by the LDAF to USDA and the school will be furnished with results of the investigation of
the complaint if requested.
XV. REDISTRIBUTION OF DONATED FOODS
Commodities cannot be sold or exchanged.
XVI. RECORD RETENTION REQUIREMENT
All records pertaining to the FDP shall be retained by the SFA for a period of three years from the end of
the Federal fiscal year to which they pertain, provided that these records shall not be destroyed in any
case in which litigation with reference thereto is pending, or until the appropriate State and/or Federal
audits have been conducted.
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XVII. REVIEWS
Representatives of the LDAF, the Louisiana Department of Education, the USDA, the General Accounting
Office, the Food and Drug Administration, public health officials, and others may inspect the facilities
used for the storage and preparation of commodities. These representatives may also inspect and audit all
records and reports and review procedures pertaining to the commodity program.
XVIII. PROGRAM TERMINATION
If a SFA ceases participating in the Program, it must notify the LDAF and conduct an inventory of all
USDA donated commodities in its possession.
The LDAF will instruct the recipient agency on the
procedure for transferring the commodities. The costs of the transfer must be borne by the SFA.
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