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Food Safety Inspections in Service-Only Sites Participating in the School Meals Programs

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FNS Document #
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Policy Memos
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PDF Icon Policy Memo (79.76 KB)
DATE:August 3, 2011
POLICY MEMO:SP 45 - 2011
SUBJECT:Food Safety Inspections in Service-Only Sites Participating in the School Meals Programs
TO:Special Nutrition Programs
Regional Directors
All Regions
State Directors
Child Nutrition Programs
All States

The United States Government Accountability Office (GAO) issued a report (GAO-11-376) to the Ranking Member, Committee on Education and the Workforce, House of Representatives on the safety of food purchased by the Department of Agriculture (USDA) and served in the School Meal Programs. One of GAO’s recommendations is that the Food and Nutrition Service (FNS) issue more specific guidance to states and school districts regarding the applicability of the food safety inspections requirement in schools that do not prepare food, such as those that only serve pre-packaged meals or meals delivered from a central preparation location (referred to in this memorandum as service only sites). This memorandum serves that purpose.

As required by section 9(g) of the Richard B. Russell National School Lunch Act and Federal regulations at 7 CFR 210.13 and 7 CFR 220.7, all schools participating in the National School Lunch Program (NSLP) and School Breakfast Program (SBP) must obtain two food safety inspections from the state or local governmental agency responsible for food safety inspections. This inspection requirement applies to all food preparation-service sites and service-only sites and state agencies must report all sites in the annual report submitted to USDA. The scope of the food safety inspection may vary according to the type of food service operation and is determined by the agency responsible for inspections.

We are aware that the inspection agencies generally do not view schools as high-risk food service operations, and sometimes do not recognize service-only sites as food service establishments because they do not actually engage in meal preparation activities. However, this does not change the requirement for all institutions that meet the definition of “school” under the NSLP to obtain two inspections.

We are confident that compliance with the food safety inspection requirement will enable schools to strengthen the safety of all foods served through the NSLP and SBP. For more information about the report School Meal Programs: More Systematic Development of Specifications Could Improve the Safety of Foods Purchased through USDA's Commodity Program, please visit

State agencies should direct any questions concerning this memorandum to the appropriate FNS regional office (RO). ROs with questions should contact the Child Nutrition Division.

Cynthia Long
Child Nutrition Division

Page updated: January 10, 2024

The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.