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Hello. Welcome to my webinar Essential Documents for Food Safety and Crediting. My name is Chad Maize and I serve as a Lead Nutrition Program Analyst for DESE Food & Nutrition Services. Today we will discuss essential documents used for identifying the contribution of a food product toward meal pattern requirements for the child nutrition programs such as - Child Nutrition Labels, also known as CN Labels - Watermarked Child Nutrition Labels - Product Formulation Statements - As well as other documents that can be used for crediting purposes We will also discuss important documents related to food safety such as temperature records, and the HACCP Plan and the role these kitchen documents play in confirming the safe production and service of food in your child nutrition program. We will also briefly cover what will be observed and expected during your Administrative Review concerning menu documentation and food safety. To begin with, why is documentation such as Child Nutrition Labels, Product Formulation Statements and product labels important? These documents provide a way for food manufacturers to communicate with school program operators about how their products may contribute to the meal pattern requirements for meals served under the Department of Agriculture's Child Nutrition programs. The first two documents we will discuss will be Child Nutrition Labels and Watermarked Child Nutrition Labels. The USDA, Child Nutrition Labeling Program provides food manufacturers the option to include a standardized food crediting statement on their product label. Here you see an example of a Child Nutrition Label for Briar Street Market Turkey Franks, toward the center of the label, circled in red, is what is called the CN Logo, which we will discuss in further detail in a moment. So, who runs the program? The Child Nutrition Program is run by USDA Food & Nutrition Services directly with commercial food processing firms and in cooperation with the following agencies: The Food Safety Inspection Service, the Agricultural Marketing Service, and the National Marine Fisheries Service. How does the Child Nutrition Program work? The program requires an evaluation of a product's formulation by USDA Food & Nutrition Services to determine its contribution toward the meal pattern requirements. So, once approved, USDA allows manufacturers to state this contribution on their product labels. The CN Label will stand as a warranty during an administrative review by ensuring the product component calculations are correct as they have been approved by USDA. What products are eligible for Child Nutrition Labels? Main dish products which contribute to the Meat/Meat Alternate component of the meal pattern requirements. Some examples include: beef patties, cheese and meat pizzas, egg rolls, bean burritos, and breaded fish portions. So, in other words, it is required to have a Meat or Meat Alternate component within the product in order for a manufacturer to have a CN Label created and approved by USDA. You will not see a CN Label for a product that only contains grains unless it includes the Meat/ Meat Alternate component in combination with the grain, such as a cheese pizza, in order to have a CN Label created for that product. So, are LEAs required to purchase from manufacturers that are able to provide CN Labeled products? The answer to that is No, it is not a federal requirement to purchase only from manufacturers that provide CN labeled products as purchasing decisions are left at the local level. Now we will discuss the different elements required to be included within a Child Nutrition Label. The first element is the CN logo. You will see at the bottom right hand side of this slide an example of a CN Logo, the CN logo contains a distinct border with the letters CN at each side of the border. Also required within the CN logo is the Meal Pattern Contribution Statement, in this example the meal pattern contribution statement is This 2.31oz fully cooked Beef Patty with Textured Soy Flour provides 2.00 oz equivalent meat/meat alternate for the Child Nutrition Meal Pattern Requirements. Following the Contribution statement is the next required element, the USDA/FNS authorization statement, which reads Use of this logo and statement authorized by the Food and Nutrition Service, USDA. Directly following the authorization statement should be the month and year the label statement was approved by USDA. And at the upper right hand corner of the CN logo should be the 6 digit product identification number assigned to that product by USDA Food and Nutrition Services. Also required to be featured within a Child Nutrition Label is the Product Name, inspection logo, the ingredient statement, the manufacturer address line and the net weight. Here we see an example of a complete Child Nutrition Label containing all the required elements. Toward the middle, again you see the required CN Logo with its distinct border, containing the meal contribution statement, the USDA authorization statement as well as the month & year it was approved by USDA. At the top right the logo is the 6-digit product identification number. Also, you see the required product name, the ingredient statement, the net weight, as well as the Inspected by USDA logo and lastly the name and address of the manufacturer. Now we are going to discuss Watermarked Child Nutrition Labels. These are used when the CN Logo and contribution statement are used on product information other than the actual product carton and is presented as a separate document. The Watermarked Child Nutrition Label was originally created by USDA for marketing purposes only to provide manufacturers an example for schools participating in the child nutrition programs and was not originally meant to be used as valid crediting documentation. Here is an example of a watermarked Child Nutrition label. You'll see that it appears to be just like a standard Child Nutrition Label, containing all the required elements of a CN Label, however, you'll see toward the center I have circled in red the watermark which reads Sample Copy Not for Documenting Federal Meal Requirements. So, as I stated before, Watermarked Child Nutrition Labels were not originally meant to be used as valid crediting documentation. And ideally the CN label from the actual product carton should be used to document meal requirements. However, on March 11th, 2015, USDA released a memo stating that Watermarked Child Nutrition Labels can be used to document federal meal requirements, but only with additional documentation, which I will explain next. So, in the event that the original CN label from the product packaging, or a photocopy or photograph of that label cannot be obtained, program operators may provide a Watermarked Child Nutrition Label as long as they ALSO provide the Bill of Lading or Invoice and that the product information listed on the Bill of Lading or Invoice matches the product information on the provided Watermarked CN Label. Next I will discuss Product Formulation Statements. If a product does not have a Child Nutrition Label, a signed Product Formulation Statement may be used for food component crediting and documenting purposes. A Product Formulation Statement, or PFS, is obtained via a request to the product manufacturer. An appropriate Product Formulation Statement will provide specific information about the product, and show how the food credits toward the child nutrition pattern, citing child nutrition program resources and/or regulations. Here I'm going to walk you through the different required elements that should be included on a Product Formulation Statement. The first thing is it should always be on an official company letterhead. You'll see with this example, the Kellogg's company logo featured at the top left. The next element that should be included in a Product Formulation Statement is it should be signed by a company representative. A Product Formulation Statement also must include the product name, product code number and serving or portion size. When receiving a Product Formulation Statement from the manufacturer, it is important to make sure the creditable ingredients listed on the Product Formulation statement match or have a similar description as the ingredients listed on the product label of the product you have in your kitchen. In this example, you see a label for a Nutri-Grain bar where 1 bar equals 44 grams. Hypothetically speaking, if this was the label for the Nutri-Grain bar you are using onsite, but the Product Formulation Statement you received from the manufacturer states 1 bar equals 34 grams, rather than 44 grams, then that should throw up a red flag and you should contact the manufacturer to obtain a new product formulation statement that matches the product you have onsite. A Product Formulation Statement should demonstrate how creditable ingredients contribute toward the meal pattern requirements. It should also provide information on how the manufacturer calculated the crediting. You should always double-check the manufacturer's calculations for accuracy. Also keep in mind the total creditable amount should never be rounded up and should always be rounded down. For example, a 2.15 oz. beef patty should not credit more than 2.00 oz. meat/meat alternate. Lastly, the crediting amount should never exceed the total serving size of the product. So if the serving size is 2.00 ounces and the Product Formulation Statement is showing it credits for 2.25 ounces, then that discrepancy should throw up a red flag and you should contact the manufacturer for a new Product Formulation Statement. Now we will discuss additional documentation and resources that can be used for crediting purposes. Any of the processed commodities you receive via ordering from the USDA Food Packet prior to each school year, you will be able to find nutrition and crediting information for the different products on the DESE website. I have provided a link here for your convenience. If you go to this link you will see all the participating vendors. For school year 2019-20 we have 31 participating vendors. If a Child Nutrition Label or Product Formulation Statement is available for these products you should be able to obtain copies of those labels at this particular location. For USDA Commodity Foods, sometimes referred to as Brown Box Products, that you receive through USDA Foods, the only required documentation is the USDA Food Fact Sheet or Product Information Sheet. Here is an example of a product information sheet for 85/15 Frozen Ground Beef. The USDA product information sheets are categorized by food type and can be found on USDA's website and I have provided the web address on this slide for your convenience. So, what if you have a grain product, but you are unable to obtain a Product Formulation Statement? In this scenario, you can use the product label on the grain product itself in conjunction with USDA's Exhibit A document in order to determine how that grain product will contribute toward the meal pattern. The first thing you will want to look at is the Nutritional Facts section on the product label in order to determine the serving size of the product. In this example you see that 1 tortilla is 62 grams. The next thing you will want to look at is the Ingredients section in order to determine whether or not the product is Whole Grain Rich. If the product is Whole Grain Rich, typically the first ingredient will be whole grain. On this example label you will see the first ingredient is Water. It is okay that water is the first ingredient, however, the very next ingredient listed must be whole grain in order for it to be considered Whole Grain Rich. Oat Fiber is not a whole grain. Therefore, this particular product would not be Whole Grain Rich. I'm now going to show you a quick example how to use the USDA Exhibit A document in conjunction with the product label in order to determine how many ounces of grain this product contributes toward the meal pattern. You will first want to look at your serving size. Again, you will see 1 tortilla is 62 grams. You will then reference the USDA Exhibit A document. Locate the particular product on the document. You will see within Group B, third from the bottom, for tortillas 1 ounce equivalent equals 28 grams or 1 ounce. You will then take the 62 grams from the product label and divide it by 28 grams from the Exhibit A which equals 2.214 ounces. As I stated before, you should always round down in this situation. Therefore, 2.214 ounces should be rounded down to 2.00 ounces. So this tortilla would credit as 2.00 ounce grain toward the meal pattern. You can find a copy of the Exhibit A document within the USDA Whole Grain Resource Booklet. I have provided a web address for the booklet on this slide for your convenience. The booklet not only contains the Exhibit A document, but also contains additional information to assist you with determining whether or not a product is whole grain rich. It is a very useful resource and I highly recommend printing the booklet and keeping a copy at each serving location. Since we are discussing the subject of whole grains, I wanted to remind you that USDA released a new final rule for school year 2019-20 which requires only half of the weekly grains in the school lunch and breakfast menu to be whole grain rich. Next we will discuss Performance Standard 2 and documents we will require during an administrative review of the child nutrition programs. One critical area of the administrative review is Performance Standard 2, which focuses on whether or not meals claimed for reimbursement meet meal pattern and nutritional quality requirements. Prior to the reviewer arriving onsite to conduct the administrative review, the reviewer will request from you a week's worth of menu documentation. The documentation you will be required to send is menus, production records, standardized recipes as well as other supporting documentation such as Child Nutrition Labels and Product Formulations Statements. These records include all information necessary to support reimbursable meals and additional requirements. So, during the administrative review, for a Meat/Meat Alternate product please provide the reviewer with a Child Nutrition Label or a signed Product Formulation Statement. If the product is a whole raw product such as whole chicken breast or 85/15 ground beef you may send us documentation referencing the USDA Food Buying Guide. If the product is a USDA commodity food, a USDA Product Information Sheet will also be sufficient documentation to send to the reviewer. For a grain product you can either send a signed Product Formulation Statement or you can send us a photograph or photocopy of the product label itself. When doing so, you must make sure to include the Nutritional Facts section of the product label so we can determine the serving size and you must also include the ingredients section of the product label so we are able to determine whether or not the product is whole grain rich. If you need to send multiple pictures of the product label in order to include all the required sections that is completely fine. Please make sure all documentation is legible before sending it the reviewer. For a combination product, for example a cheese pizza, which contains both Meat Alternate component as well as the grain component, you must provide the reviewer with a Child Nutrition Label or a signed Product Formulation Statement. In the next few slides we will test our knowledge by going over different types of labels in order to determine whether or not each label would be acceptable documentation for crediting purposes. Looking at this label for Tenderloin Patties, would this be acceptable documentation for crediting meal components? The answer is, Yes, this is acceptable documentation IF you also provide a bill of lading or invoice. Since this is a Watermarked CN Label, it is required you include a bill of lading or invoice in order to use the Watermarked CN Label to validate crediting. Looking at this label for Turkey Breast, would this be acceptable documentation for crediting the meal component? The answer to that is No, this is an unacceptable label. If this had been a whole raw product, then you could have used the label in conjunction with the Food Buying Guide in order to determine the amount of Meat/Meat Alternate it would credit for toward the meal pattern. However, if you look at the ingredients list, you will see it is not a whole raw product as it contains multiple ingredients aside from turkey breast and therefore a Child Nutrition Label or signed Product Formulation Statement would be required. Looking at this label for Chicken Pattie Fritters, would this be acceptable documentation for crediting purposes? The answer is Yes, this is acceptable documentation as this is a complete Child Nutrition Label containing all the required elements of a Child Nutrition Label. You'll see it has the product name, ingredients list, USDA inspection logo, and the manufacturer name and address listed at the bottom. I've circled the CN Logo which contains the required contribution statement, USDA authorization statement, the date it was approved by USDA as well as the 6 digit product code. This particular label also includes the Whole Grain logo, which indicates this product also contains creditable grains. This next label is a product label for bread. Would this be acceptable documentation to use for crediting the grain contribution for this bread product? The answer is, Yes, this is acceptable. If you are unable to obtain a Product Formulation Statement for your grain product, you can use the label from the grain product in your kitchen in conjunction with the USDA Exhibit A document in order to determine the crediting amount. Next we will be discussing food safety and important records related to food safety such as Temperature Records or Logs, and the Food Safety/HACCP Plan. Throughout this discussion, please keep in mind the Nutrition Program Specialist that will be conducting your administrative review is not trained to be a food safety Health Inspector. DESE Food & Nutrition Services will be reviewing some basic areas of food safety while we are onsite during your review, however, we are not conducting a complete food safety health inspection. So, you should always consult your local Health Department if you have questions about specific requirements such as food safety temperatures as these may vary depending on the requirements set by your local Health Department. The food safety documents we will be reviewing while onsite are documents such Temperature Records and your HACCP Plan. These documents are designed to ensure the safe production and services of food at each serving site. So, why are Temperature Logs important? Temperature Logs are important as they help assure foods are received, stored, cooked and held at the right temperatures in order to minimize or deplete potential health risks. As noted here, sometimes a simple mistake can have grave consequences. There really is no such thing as a small food safety mistake as even the smallest oversights could potentially cause a serious illness. Therefore, it is important to be able to reference Temperature logs in order to be able to confirm that your temperatures were within the proper critical control points in the event someone does become ill or there is an outbreak at the school. Also, please keep in mind that USDA Food & Nutrition Services requires each school in every LEA to maintain temperature logs for a period of Six Months. You will want to review and document internal cooking temperatures to ensure foods reach proper internal temperatures during cooking. Please also keep in mind different foods require different minimum internal temperatures to ensure safety. Make sure to check the food code and if you are unsure please contact your local Health Department. It is also important to keep logs for cooking & reheating, cooling, holding and storing temperatures. If you wish to do so, you can choose to record your cooking and holding temperatures on your daily production records. For your convenience, DESE Food & Nutrition Services have listed multiple record log templates on the DESE FNS website. There you can find templates for such things as: Cooking and Reheating Temperature Log Time and Temperature for Holding Freezer Temperature Log Dry Storage Temperature Log AND many others! Another crucial document to have at each serving location within your LEA is a food safety or HAACP Plan. HACCP stands for Hazard Analysis Critical Control Points. This plan is an important resource as it is a go-to reference book that will assist you with controlling potential hazards and should contain Standard Operating Procedures or SOPs as well a written plan for applying basic HACCP principles. In other words, recognizing hazards and putting control points in place to prevent them. Please make sure your HACCP Plan is reviewed periodically and tailored specifically for each school food service site within your LEA. Slide 48: Now we will discuss Standard Operating Procedures or SOPs. SOPs are step-by-step written instructions for routine food service tasks that affect the safety of food such as proper dishwashing procedures and proper cooking procedures. The Standard Operating Procedures should be included within your HACCP Plan. Some different types of SOPs would be: Handling Potentially Hazardous Foods Personal Hygiene Procedures for Reheating Food and Dating Procedures These are all different examples of SOPs for different Critical Control Points. Also, SOPs should include the following components: Critical Control Points and Critical Limits Monitoring Procedures Corrective Action Procedures Dating Procedures and Recordkeeping Procedures Keep in mind, if you don't already have an established HACCP Plan or you are creating a new plan, you don't necessarily have to create your own SOPs from scratch. In fact, the Institute of Child Nutrition, or ICN, have created Standard Operating Procedures that you can use for your own HACCP Plan. You will just want to make sure you tailor these SOPs to fit your serving site. For example, if one section of the instructions of an SOP instructs you to Follow manufacturer's instructions regarding the use and maintenance of equipment. In order to tailor this section to meet your site, you should include the different types of specific equipment you have onsite and the specific instructions provided by each manufacturer on how to properly use and maintain each piece of equipment. This is just one example of tailoring an SOP to fit your serving site. We'll now take a quick walk-through of a sample SOP. Your HACCP plan should contain Critical Control Points. A Critical Control Point is a step at which you will reduce, prevent or eliminate a potential hazard. This sample SOP is for the Critical Control Point for Cooling Potentially Hazardous Foods. So basically it is a Critical Control Point for preventing bacteria from growing. This is a standard format for an SOP where it will start out with a Purpose, Scope and Key Words. The next part of the SOP shows the Instructions Section. In this example it shows the instructions on how to properly cool food. Also within the Instructions Section of this sample SOP you will see it specifies the Critical Limits. So if you are within the times and temperatures listed within these instructions you will prevent your hazard, so in this case you will prevent bacteria from growing. Next you will see the Monitoring Procedures section specifying what type of equipment to use to measure internal temperatures as well as when and how to monitor the temperatures. Here you also see the Corrective Action Procedures section, which describes the actions you should take to correct any procedures defined within the SOP that are not being followed correctly. Lastly, you will see listed is the Recordkeeping Procedures, which in this case describes who is assigned to record the temperatures and when, how and where the temperatures will be recorded. Also, the SOP should be dated and signed when the SOP is implemented, reviewed and/or revised. Now we will discuss Dating Procedures and the First-in First-out method. Items should always be clearly dated as soon as they reach the kitchen and then after being cooked and saved for leftovers. You should also be following the First-in First out method, also known as FIFO. The FIFO method ensures the oldest unexpired item is used first. This not only helps prevent food hazards but also helps eliminate food waste. During the Administrative Review we will be looking at the following documents while onsite. We will be looking at temperature records for your freezer, refrigeration, ambient storage or dry storage area and your food temperature logs. Next, will make sure you have your most recent food safety inspection posted and visible in the cafeteria to all students and adults eating at your cafeteria. Also, USDA requires each serving site within an LEA to have at least two food safety inspections conducted each school year. If you did not have two food safety inspections at the time of the onsite review, we will check to see if you had two food safety inspections completed during the prior school year. If you did not have two food safety inspections during the prior school year, you must show documentation that you had contacted your Local Health Department to request the inspection. Lastly, we will be looking at your HACCP Plan while onsite to make sure it contains all the required elements and check to see if the HACCP Plan has been tailored to your specific site as well as make sure the plan appears to be up-to-date. If you have questions concerning the content of this webinar.... Please contact DESE Food & Nutrition Services at schoolfoods@dese.mo.gov or by calling 573-751-3526. Thank you.