This is the second part of our two-part series about purveying local foods for your school. Here is the link to Part One: Food Safety Considerations when Procuring Local Foods for Your Cafeteria.
Currently, there is increasing interest from school districts to source local foods such as, meat, poultry, egg and dairy products. The USDA’s Farm to School Census data indicated that schools purchased nearly $790 million in local food from farmers, ranchers, fishermen, food processors, and manufacturers in the 2013-2014 school year, representing a 105% increase over the 2011-2012 school year. In addition, 47% of these districts plan to purchase even more local foods in future school years.
When it comes to school food procurement, “local” can be defined in many different ways, such as within a mile radius, county, state, or region. Also, the definition of “local” is not static, and it may change depending on the product, season, and special events. Purchasing local foods has many benefits, including shortening the transportation time from farms to students and stimulate more local economic activity.
So, who defines “local” within the context of school food procurement? According to the USDA, “…the school food authority making the purchase or the State agency making purchases on behalf of such school food authorities have the discretion to determine the local area to which the geographic preference option will be applied.” The USDA specifies local foods can be procured using the micro-purchase process, informal procurement, or formal procurement methods. Procurement levels are based on the estimated purchase value and applicable small purchase threshold. Micro-purchase is the simplest, allowing for a one-time purchase under $3,000 without soliciting quotes. Next is informal procurement, for purchases that fall below the lowest of the federal, state, and local thresholds (eg. Under $150,000) where price quotes from at least three bidders are required. Last is formal procurement, for purchases that are above the federal, state, and local thresholds (eg. Above $150,000). Public announcement of the quote solicitation is required, and implementation of competitive sealed bidding and competitive proposals are common practices. More information on the procurement options can be found at USDA Local Procurement Decision Tree.
Schools not only have to ensure rigorous purchasing methods, but they also have to know food products are of high quality and safety. Two federal regulatory agencies are responsible for regulating all the commercial supply of meat, poultry, eggs and dairy products served in Child Nutrition Programs (CNP).
- Food and Drug Administration (FDA):
FDA regulates products from animals not covered by the Federal Meat Inspection Act of 1906 (FMIA), the Poultry Products Inspection Act of 1957 (PPIA), and the Egg Products Inspection Act of 1970 (EPIA), such as game animals, shell eggs, and seafood. This authority is conferred by the Federal Food Drug and Cosmetic Act (FFDCA).
- U.S. Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS): FSIS regulates the commercial supply of meat, poultry, and egg products to ensure that it is safe, wholesome, and correctly labeled and packaged. FSIS draws its authority from the FMIA, PPIA, and EPIA.
Confusion surrounding local meat inspection requirements for schools remains a barrier for successful procurement. The USDA allows for meat procurement from non-USDA slaughter and inspected facilities, which operate through an agreement with FSIS, allowing for State-level inspection of meat and poultry. Two acceptable-existing State-level facilities are not applicable to all 50 States and territories. The two facilities are:
- State Meat and Poultry Inspection (MPI) Programs:
State MPI programs are currently operated through cooperative agreements with FSIS by twenty-seven states and must enforce requirements “at least equal to” federal inspection programs under FMIA and PPIA. This means that school districts can buy and serve meat from smaller slaughter and/or processing establishments participating in an MPI program within their state.
- Cooperative Interstate Shipment (CIS) Programs:
CIS programs allow facilities already participating in a State MPI program to ship products in interstate commerce. In those states, establishments participating in a state MPI program are considered as federally-inspected facilities. Therefore, CIS programs open up new markets for ranchers of meat and poultry and expand regional sourcing opportunities for school districts.
The above outlines the State-level inspection programs for CNP meat and poultry coming from acceptable non-USDA facilities. Below is a brief overview for meat, poultry, eggs, and dairy that CNPs must observe. Full requirements can be found at: Procuring Local Meat, Poultry, Game, and Eggs for Child Nutrition Programs.
Livestock slaughtered and meat or meat food products processed under inspection in a USDA, MPI or CIS facility may be served in CNPs. These facilities may be traditional brick- and mortar facilities or mobile slaughter units. Livestock and meat food products from amenable animals (meaning, species subject to the regulations found in the FMIA or the PPIA) inspected at State MPI facilities are only eligible for intrastate distribution. Animals slaughtered in and meat food products processed in CIS facilities, regardless of where the animal was raised, can be sold in interstate commerce.
Poultry sold for commercial consumption must be inspected at a USDA facility, a MPI program facility, or a CIS program facility in either a traditional brick and mortar plant or a mobile slaughter unit, unless exempted from inspection requirements (where various exemptions may apply). Unlike livestock, poultry exemptions do allow poultry slaughter and processing to occur without the requirement of Federal or State inspection, within the limitations described in 9 CFR 381.1. Poultry produced under a poultry exemption are restricted to intrastate commerce only, meaning CNP operators cannot serve poultry products from neighboring states that are exempt from inspection.
Egg and Egg Products
Shell eggs come under the jurisdiction of the FDA and have to meet FDA guidelines, whereas liquid, frozen and dried egg products are regulated by USDA FSIS. All liquid, frozen and dried egg products are required to be USDA inspected and must meet the regulatory requirements outlined in EPIA in order to be used in CNP, such as being pasteurized and found negative for Salmonella. Shell eggs are not required to be pasteurized to be used in CNP, however they are recommended to meet at least grade B standards. FDA requires egg producers with 50,000 or more laying hens to implement measures to prevent Salmonella Enteriditis (SE) from contamination under the Egg Safety Rule. It was worth mentioning that only whole eggs can be credited in CNP, while shell, liquid, frozen or dried eggs fall under FSIS inspection.
In the US, many dairy products have federal grades and standards defining the composition, manufacturing, and quality requirements, which can be found in the Code of Federal Regulations (CFR), Titles 7 (Agriculture) and 21 (Food and Drugs). The grades and standards for dairy products that undergo inspection by USDA are listed by category on the USDA Agriculture Marketing Service website. State and local regulatory agencies inspect and regulate dairy industry from farm production through the sale to consumers. The Public Health Service has no legal jurisdiction in the enforcement of milk sanitation standards except on interstate carriers and milk and milk products shipped in interstate commerce. The FDA’s primary function under the Federal/State Milk Safety Cooperative Program (IMS Grade A products) is to provide technical assistance to the states in the implementation and enforcement of their milk regulations.
In conclusion, procuring local foods for school meals requires that the right funding methods and regulators are involved. We hope that more school districts and schools continue to participate in buy local. For more information, please review the below references.
Zhenlei Xiao, PhD and Shauna C. Henley, PhD, University of Maryland Extension
Egg Products Inspection Act. USDA Food Safety and Inspection Service.
Egg Safety Final Rule. US Food & Drug Administration
Egg Safety Inspections. US Food & Drug Administration
Inspections, Compliance, Enforcement, and Criminal Investigations Dairy Product Manufacturers (4/95). US Food & Drug Administration
Niche Meat Processor Assistance Network Mobile Slaughter Units. USDA Food Safety and Inspection Service.
Procuring Local Foods. USDA Food and Nutrition Service
Procuring Local Meat, Poultry, Game, and Eggs for Child Nutrition Programs (October 22nd, 2015). USDA Food and Nutrition Service
The Farm to School Census. USDA Food and Nutrition Service
Understanding Poultry Exemptions. eXtension.org