Inspection Requirements for SFAs Vending Meals to Outside Entities

Last Modified: 09/12/2013

CND Guidance Brochure (pdf)

July 2003

School Food Authorities (SFAs) that sell meals to outside organizations may be subject to inspection under the Federal Meat Inspection Act/Poultry Products Inspection Act (FMIA/PPIA)

What are the Federal Meat Inspection Act and the Poultry Products Inspection Act (FMIA/PPIA)?

The FMIA and PPIA and the implementing regulations for these Acts establish inspection requirements for certain types of facilities, which prepare foods containing meat and poultry products.

We only prepare meals for our own schools – are we subject to these inspections?

Self preparation and central school kitchens that only prepare meals for students in schools which are operated by your SFA are exempt from these inspections under the restaurant/central kitchen exemptions of the FMIA/PPIA regulations.

Is inspection required if we only vend to other federally funded Child Nutrition Programs?

  • If the program receiving the vended meals is not operated by your SFA, you may be subject to these inspections.

  • If the program receiving the vended meals is operated by your SFA, you are not subject to these inspections (e.g., a child care center or after school program operated by the SFA).

Can I get a waiver or exemption?

Some types of vending operations may be exempt from this inspection requirement, including:

  • Catering operations – all vended meals are transported and served to individual consumers by SFA staff;

  • Operations which only vend closed face sandwiches;

  • Operations that only vend entrees that contain less than 2% cooked meat or poultry by volume.

We are inspected by our local health department – would we still need this inspection?

Inspection under the FMIA/PPIA is a separate process from local/State health inspections, although the inspection may be conducted in cooperation with local/State health authorities. Therefore, the inspection is still required.

Who conducts FMIA/PPIA inspections?

The Food Safety and Inspection Service (FSIS) is the USDA agency, which administers meat and poultry inspection under these Acts. In 28 States, the actual inspections are conducted by State agencies that operate under agreements with FSIS. In the remaining States, FSIS staff conduct the inspections.

What are the inspection requirements?

The exact requirements are specific to each vending operation. The facility will develop a compliance plan working with the inspectors. In general terms, an inspection plan must include development of: 

  • Sanitation Standard Operating Procedures (SSOPs);

  • A Hazard Analysis Critical Control Point plan (HACCP);

  • An evaluation of existing facilities to identify any changes needed (changes which are not related to an immediate health hazard usually can be phased in over a budget cycle);

  • A system of ingredient labeling for vended meals.

If we vend meals, what should we do?

See the item below for additional information. 

Additional Information:

The Food and Nutrition Service (FNS) is working with the Food Safety and Inspection Service (FSIS) and State Education agencies on implementation of meat and poultry inspection in vending SFAs. Your State agency may contact SFAs to determine if they have vending operations that are subject to these requirements. If you are currently vending meals, it is also possible that you may be contacted by FSIS or the State agency responsible for meat/poultry inspection in your State to determine if you are subject to these inspection requirements.  If you would like to have additional information on meat/poultry inspection requirements now, or if you are contacted by FSIS or your State meat/poultry inspection agency, please notify your NSLP State agency.