School Meal Programs: Changes to Federal Agencies' Procedures Could Reduce Risk of School Children Consuming Recalled Food

Highlights

Over the past few years, several food recalls, such as for beef and peanut products, have affected schools. It is especially important that recalls affecting schools be carried out efficiently and effectively because young children have a higher risk of complications from food-borne illnesses. GAO was asked to determine how federal agencies (1) notified states and schools about food recalls, (2) advised states and schools about disposal and reimbursement of recalled food, and (3) ensured that recalls were being carried out effectively. To do this, GAO reviewed and analyzed relevant documents and interviewed federal and state officials, as well as officials from 23 school districts that had experience with at least one of four recent cases involving the safety of food in the school lunch program.

Recommendations

Recommendations for Executive Action

Agency Affected	Recommendation	Status
Department of Health and Human Services	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS and that the Secretary of HHS should direct FDA to jointly establish a time frame for completing a memorandum of understanding on how FNS and FDA will communicate during FDA investigations and recalls that may involve USDA commodities for the school meal programs, which should specifically address how FDA will include FNS in its prerecall deliberations.	Closed – Implemented The USDA's Agricultural Marketing Service, Farm Service Agency, and Food and Nutrition Service entered into a Memorandum of Understanding with the HHS' Food and Drug Administration effective September 29, 2011. The purpose of the Memorandum is to establish a framework for the Parties to communicate and cooperate in the timely and full exchange of information to optimize controls essential to mitigate the potential for the distribution or use of USDA foods which may be unsafe.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS and that the Secretary of HHS should direct FDA to jointly establish a time frame for completing a memorandum of understanding on how FNS and FDA will communicate during FDA investigations and recalls that may involve USDA commodities for the school meal programs, which should specifically address how FDA will include FNS in its prerecall deliberations.	Closed – Implemented The U.S. Department of Agriculture's Agricultural Marketing Service, Farm Service Agency, and Food and Nutrition Service entered into a Memorandum of Understanding with the Food and Drug Administration effective September 29, 2011. The purpose of the Memorandum is to establish a framework for the Parties to communicate and cooperate in the timely and full exchange of information to optimize controls essential to minimizing the potential for the distribution or use of USDA Foods which may be unsafe.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS to develop guidelines, in consultations with the Agriculrural Marketing Service (AMS) and the Farm Service Agency (FSA), to be used for determining whether or not to institute an administrative hold on suspect commodities for school meal programs.	Closed – Implemented The Food and Nutrition Service has established agreements with the Agricultural Marketing Service and the Farm Service Agency for assessing and determining appropriate action on commodity complaints pertaining to food safety issues.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS to work with states to explore ways for states to speed notification to schools.	Closed – Implemented The Food and Nutrition Service reported that it now provides a service, the USDA Foods State Emergency Notification System (SENS), to states. The service allows states to send alert messages to schools during a recall or other food emergency affecting USDA foods.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS to improve the timeliness and completeness of direct communication between FNS and schools about holds and recalls, such as through the commodity alert system.	Closed – Implemented USDA reported that the Food and Nutrition has promoted the Commodity Alert System to schools on its website, in newsletters, and at conferences. The Commodity Alert System is highlighted in publications, such as the "Inventory and Management Tracking Guide:" and the "Responding to a Food Recall" manual.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS to take the lead among USDA agencies to establish a time frame in which it will improve the USDA commodity hold and recall procedures to address the role of processors and determine distributors' involvement with processed products, which may contain recalled ingredients, to facilitate providing more timely and complete information to schools.	Closed – Implemented USDA issued a manual, "Responding to a Food Recall: Procedures for Recalls of USDA Foods," which addresses the role of distributors and processors during a food recall.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS to revise its procedures to provide states with more specific instructions for schools on how to dispose of recalled commodities and obtain timely reimbursement.	Closed – Implemented USDA issued a manual, "Responding to a Food Recall: Procedures for Recalls of USDA Foods," which addresses the disposal of recalled commodities and reimbursement.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture should direct FNS to institute a systematic quality check procedure to ensure that FNS holds on foods and products used by schools are carried out effectively.	Closed – Implemented The Food and Nutrition Service (FNS) reporting system provides a quality check for commodities on which FNS has placed a hold.
Department of Agriculture	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of Agriculture direct FSIS to revise its procedures to ensure that schools are included in effectiveness checks.	Closed – Implemented The USDA Food Safety and Inspection Service, Directive 8080.1, Recall of Meat and Poultry Products was revised. The Directive provides for effectiveness checks at schools.
Department of Health and Human Services	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of HHS should direct FDA to revise the Recall Audit Check Report form to include a consignee prompt for schools.	Closed – Implemented FDA reported that this was completed and the FDA form now has a box for type of consignee as "school."
Department of Health and Human Services	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of HHS should direct FDA to revise FDA procedures to ensure schools are included in audit checks, either by drawing a separate schools-only sample or providing a selection preference for schools.	Closed – Implemented FDA revised its Regulatory Procedures Manual for recalls to include instructions to ensure that consignees who received recalled products that were purchased for use in a domestic nutrition assistance program (e.g. National School Lunch Program) are included in audit checks.
Department of Health and Human Services	To better ensure the safety of foods provided to children through the school meal programs, and to make improvements in three areas related to recalls affecting schools: interagency coordination; notification and instructions to states and schools; and monitoring effectiveness, the Secretary of HHS should direct FDA to revise FDA procedures to ensure analysis of its audit checks is documented, and any problems with recalls or audit checks affecting consignees involved with schools identified and acted upon.	Closed – Implemented FDA updated its Regulatory Procedures Manual section on recall procedures for evaluating audit checks and ensuring that appropriate and timely follow-up action is taken for issues affecting school lunch programs. FDA reports it is also working on an enhancement of its FDA Recall Enterprise System that will incorporate an audit check function that is expected to provide for better documenting and tracking of recall audit checks.

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Agriculture and Food

ChildrenElementary school studentsElementary schoolsFood contaminationFood inspectionFood programs for childrenFood safetyHealth policyMeat inspectionProduct recallsPublic healthPublic schoolsRisk managementSafety standardsSchool health servicesSchoolsSecondary school studentsSecondary schoolsStudents