The Child Nutrition and WIC Reauthorization Act of 2004 requires each school food authority (SFA) to implement a school food safety program based on HACCP (Hazard Analysis and Critical Control Point) principles. HACCP Based Standardized Operating Procedures can be found at the link below:


Details of the Law: Sec 111 of CN and WIC Reauth Act of 04
‘‘(5) SCHOOL FOOD SAFETY PROGRAM.-Each school food authority shall implement a school food safety program, in the preparation and service of each meal served to children, that complies with any hazard analysis and critical control point system established by the Secretary.’’

Key Points
USDA’s guidance and other communications clarify aspects of the law. Key points include:

    • The law addresses the entire school food safety program. The HACCP-based approach relates to documented details of the school food safety program.
    • Programs may comply with any HACCP system recognized by USDA. SFAs that currently implement traditional HACCP will not be required to change provided minimum required elements are met.
    • SFAs that do not currently have HACCP plans are encouraged to develop programs based on the process approach to HACCP.
    • State agencies that administer the child nutrition programs will review for compliance during the state coordinated review effort (CRE).
    • SFAs are required develop and implement school food safety programs during SY 2005-2006.

There are some elements that FNS has outlined for a SFA’s school food safety program to include in order to comply, at a minimum, with the requirement. These are explained in FNS’s guidance document. The minimum required elements are:

    • Documented SOPs (Standard Operating Procedures)
    • A written plan for applying HACCP principles at each site within the SFA that prepares and/or serves food that includes methods for:
      • Documenting menu items into appropriate categories (Process 1, 2, or 3) according to the process-based approach to HACCP
      • Documenting Critical Control Points during food production
      • Monitoring
      • Establishing and documenting corrective actions
      • Recordkeeping
      • Periodically reviewing and revising the overall food safety program