Food Safety Inspections in Non-Traditional School Settings

We have been asked to clarify how the food safety inspection requirement is to be carried out by program operators on military bases, Indian reservations and Residential Child Care Institutions (RCCIs). Questions have risen because some of these program operators are not within the jurisdiction of a state/local public health agency responsible for food safety inspections, only serve vended meals, or prepare and serve family-style meals.

All institutions participating in the National School Lunch Program (NSLP) or School Breakfast Program are required to obtain two food safety inspections per school year. Program operators in non-traditional settings are expected to do their best to fulfill their responsibility:

• Department of Defense (DoD) schools, whether in the United States or overseas, must request two food safety inspections from the military personnel in charge of the food safety function for the base, for example the military health agency.
• Non-DoD schools located on domestic military bases must request the inspections from the state/local public health agency responsible for inspections.
• Schools operated by the Bureau of Indian Affairs (BIA) must obtain two food safety inspections from the Indian Health Service (IHS). The IHS inspections fulfill the NSLP requirement and BIA schools do not have to request a state/local public health agency to conduct the inspections.
• RCCIs must obtain two food safety inspections from their state/local public health agency even if they only offer vended meals or if residents prepare and serve their own meals. The state/local public health agency has discretion to determine the extent of the food safety inspections. If the RCCI is part of another institution (e.g., a hospital), the inspections obtained by the larger facility count towards the NSLP requirement if the RCCI food preparation and/or service area is included in the regular inspection.

We ask the state Agencies (SAs) to continue working with the state and local public health agencies and school food authorities to promote compliance with the food safety inspection requirement. SAs may discuss unusual situations with the regional offices.

STANLEY C. GARNETT
Director
Child Nutrition Division