# Presentation: 529909

## 
Child Nutrition and WIC Reauthorization Act of 2004
Public Law 108-265

Part 3

Presentation originally delivered at the 
State Directors’ Meeting
Kansas City, MO
September 28-29, 2004

Updated Nov 10, 2004

USDA, FNS

**Child Nutrition and WIC Reauthorization Act of 2004**
**Public Law 108-265**
***Part 3***
**Presentation originally delivered at the **
**State Directors’ Meeting**
**Kansas City, MO**
***September 28-29, 2004***
***Updated Nov 10, 2004***
***USDA, FNS***

## Duration of Eligibility for Free or Reduced Price Meals:  Sec. 106

**Eligibility for free/ reduced price school meals remains valid for 1 year for most students**
**Eligibility in effect upon approval for the current school year and ending on a date during the next  school year determined by USDA**** **

**Notes:**
Section 106.  Duration of Eligibility for Free or Reduced Price Meals
Prior to Reauthorization:   No provisions.  
Note:  Current policies direct that, when a family’s income changes by $50 per month or $600 per year or household size decreases, the family must report the change, and the local school food authority is to adjust their status.

Section 106:  [Section 9(b)(9)(C) of the NSLA]
This section effectively directs that eligibility for free or reduced-price school meals remains valid for 1 school year for most students.
 Correctly determined eligibility would remain in effect beginning with approval for the current school year and ending on a date during the subsequent school year determined by USDA.  

FNS policy:
Continues temporary approvals for $0 income households.
Households may report changes and SFA must act on any change that increases benefits.

## Duration of Eligibility for Free or Reduced Price Meals (cont.)  

**Documentation for verification**
**At any point in time between the month prior to application and the time documentation is required**

**Notes:**
From Senate Colloquy
Households are now permitted to provide documentation for any point from the month prior to application and the time the income documentation is provided.

## Duration of Eligibility for Free or Reduced Price Meals (cont.)  

**An exception:****for cases****where****verification****activities****indicate****ineligibility.**
**Effective July 1, 2004.**
**Implementation memo issued.**

**Notes:**
An exception is included for cases where verification activities indicate ineligibility.
FNS is developing an interim final regulation that will include household applications as well as year long duration.

## Runaways, Homeless, andMigrant Youth:  Sec. 107

**Extends categorical eligibility for free meals to youth who are:**
**Homeless**
**Runaway**
**Migrants**

**Notes:**
Section 107.  Runaway, Homeless, and Migrant Youth
Categorical (automatic) eligibility
Prior to Reauthorization:   By administrative guidance, homeless children generally are automatically eligible for free school meals.  There are no explicit eligibility provisions for runaway youth or migrant children.  Also by administrative guidance, school officials may, for purposes of granting eligibility for free school meals, accept documentation that children are homeless from the local educational liaison for the homeless or directors of homeless shelters where the children reside.
[Section 9(b)(12)(A)(iv)-(vi) of the NSLA ]
Homeless, as defined under the McKinney-Vento Homeless Assistance Act.
Runaways, as defined under the Runaway and Homeless Youth Act.
Migrants – as defined by the Elementary and Secondary Education Act.
For purposes of granting automatic eligibility to homeless children, runaway youth, and migrant children, this section also requires documentation that they are homeless, served by a runaway youth program, or a migrant child.

## Runaways, Homeless, andMigrant Youth (cont.)

**Documentation**
**Often documentation is through Homeless Liaison**
**Issued implementation memos**
**Effective July 1, 2004**

**Notes:**
Section 107 
FNS has already issued 3 memos providing background and guidance on how schools obtain documentation.

## Certification by Local Educational Agencies: Sec. 108

**Certification by Local Educational Agencies (LEAs)**
**Defines LEA as that in the Elementary and Secondary Education Act of 1965**
**Changes school food authority to LEA for purposes of:**
**Certification**
**Verification**
**Effective upon enactment**

**Notes:**
	Section 108.  Certification by Local Educational Agencies
Prior to Reauthorization:   By regulation and practice, local “school food authorities” certify and verify eligibility for free and reduced price school meals.
Section 108:  [Section 9(b)(11) of the NSLA]
This section – and other amendments relating to certifying and verifying eligibility for free and reduced price school meals – stipulates that “local educational agencies” are effectively responsible for certification and verification activities.  
“Local educational agencies” are defined in the Elementary and Secondary Education Act, or, in the case of private nonprofit schools, an appropriate entity determined by USDA.
FNS will implement this change as part of other related regulations on verification.

## Permanent Exclusion of Privatized Military Housing AllowancesSec. 109

**Sec 109 makes *****permanent***** the rule disregarding housing allowances for “privatized” housing.**
**Effective July 1, 2004.**

**Notes:**
Section 109.  Exclusion of Military Housing Allowances
Prior to Reauthorization:   In cases where military families live in “privatized” housing, their housing allowances are not counted as income when determining eligibility for free or reduced-price school meals.  This rule was to expire June 30, 2004.
Section 109:  [Section 9(b)(13) of he NSLA]
This section makes permanent the provision to disregard housing allowances for “privatized” housing.
This exclusion applies to all of the Child Nutrition programs.
This will not need a regulation change – just an update to the eligibility guidance.
Please note:  This disregard only applies to privatized housing allowances. “Privatized housing” refers to the Military Housing Privatization Initiative, a program operating at a number of military installations.  This initiative puts the operation of military owned housing under private contractors.  Under this privatization initiative, a housing allowance appears on the leave and earnings statement of service members living in privatized housing.  It is important to note that this income exclusion is only for service members living in housing covered under the Military Housing Privatization Initiative.  It is not an allowable exclusion for households living off-base in the general commercial/private real estate market. Housing allowances for off-base housing are still considered income for the Child Nutrition programs.

## Waiver of Requirement for Weighted Averages for Nutrient Analysis:  Sec. 110

**Extends current waiver through September 30, 2009.**
**Memo****issued.**

**Notes:**
Section 110.  Waiver of Requirement for Weighted Averages for Nutrient Analysis
Prior to Reauthorization:   School food authorities must use “weighted averages” for their nutrient analysis of their school meal programs.  Under this method, the nutrient content of school meals is measured (“weighted”) according to food items chosen by students.  Compliance with this requirement was waived until September 30, 2003.  FNS extended the waiver through administrative policy.

Section 110:   [Sec. 9(f)(5) of the NSLA]
This section re-instates the waiver of the requirement to use “weighted averages” for nutrient analysis – through September 30, 2009.

Note:  Final regulation should be published prior to December 31, 2004.

## Food Safety, Section 111

## Food Safety:  Sec. 111

**Prior to Reauthorization, schools required to have at least one food safety inspection per year **
**Inspection conducted by State or local agency responsible for such inspections**

**Notes:**
Section 111.  Food Safety
Prior to Reauthorization:  Schools participating in the school lunch and breakfast programs must, at least once during each school year, obtain a food safety inspection conducted by a State or local governmental agency responsible for food safety inspections.
[Sec. 9(h) of the NSLA]

## Food Safety (cont.)

**Effective July 1, 2005, schools must have at least 2 inspections per year**
**School must post most recent report and make available upon request**

**Notes:**
Sec 111 
This section increases the number of required food safety inspections to at least two a year and 
requires that reports on the most recent inspection be publicly posted and provided to the public upon request.  
Note:  This section explicitly allows State and local governments to adopt or enforce any requirement for more frequent inspections.  

## Food Safety (cont.)

**State to annually audit food safety inspections of schools and**
**   ****report results to USDA**
**FY 2006 through FY 2009**
**USDA required to annually audit State reports**

**Notes:**
Sec 111:
For FY 2006 through FY 2009, States must annually audit required school food safety inspections and submit the results to USDA.  
USDA is required to audit these State reports.
FNS is developing procedures to capture the required information with minimum burden on schools, SFAs and State agencies.

## Food Safety (cont.)

**Also requires that each SFA implement a school food safety program **
**Must comply with “HACCP” system established by USDA  **
**Effective July 1, 2005 **

**Notes:**
Sec. 111
Prior to Reauthorization:  No requirement.

Section 111 also adds a requirement that school food authorities implement a school food safety program for the preparation and service of meals that complies with any “hazard analysis and critical control point” (HACCP) system established by USDA.
USDA is working on guidance about the HACCP system requirements:
Includes discussions with FDA and the National Food Service Management Institute
FDA has developed “A Guide for the Voluntary Use of HACCP Principles for Operators of Food Service and Retail Establishments.”  This Guide was developed with input from a broad group of stakeholders including regional, State and local health department staff, and members of the Conference for Food Protection, which included industry and consumer groups.  The original Guide was issued in 1998, a revision is currently being issued.  
The FDA document gives guidance on developing a food safety management system using HACCP principles.
FDA has developed a companion guide for regulators (health department staff) and provides training to them on a regular basis.  
NFSMI has developed and implemented a HACCP training network to reach foodservice professionals.  Over the last two years 320 HACCP instructors from 48 states have gone through the train-the-trainer course.  HACCP training will continue to be offered by NFSMI. 
A conforming provision on food safety is found in section 125 that officially recognizes the expansion of the duties of NFSMI to include food safety, including food handling, hazard analysis and critical control point plan implementation, emergency readiness, responding to a food recall, and food biosecurity training.

## Purchases of Locally Produced Foods: Sec. 112

**Encourages purchases of locally produced foods.**
**Currently unfunded.**
**If funded, $400,000 annually through FY 2009.**

**Notes:**
Section 112.  Purchases of Locally Produced Foods
Prior to Reauthorization:   Subject to the availability of appropriations, USDA is required to encourage institutions participating in the school lunch and school breakfast programs to purchase, in addition to other food purchases, locally produced foods – to the maximum extent practicable and appropriate.  USDA also is required to provide startup grants to not more than 200 institutions to defray the initial costs of equipment, materials, and storage facilities (and similar costs) incurred in carrying out this policy.  Annual appropriations of $400,000 are authorized through Fiscal Year 2007.
[Sec. 9(j) of the NSLA]
Section 112:  
This section extends the authorization of appropriations through Fiscal Year 2009.

## Special Assistance:Provisions 2 & 3: Sec. 113

**Adds district-wide claiming percentages for Provisions 2 and 3.**
**Effective upon enactment.**
**Issued implementation memorandum.**

**Notes:**
Section 113.  Special Assistance
Prior to Reauthorization:   Under “Provision 2" and “Provision 3,” schools with high proportions of children eligible for free and reduced-price school meals may elect to serve all meals free (i.e., avoid annual individual eligibility determinations and separate meal counting procedures for free and reduced-price meals), if they absorb the extra costs which result from not having revenue from students.  

Section 113:  [Sec. 11(a)(1) of the NSLA]
This section allows school districts to claim “Provision 2" or “Provision 3" status.
FNS will be revising current Provision 2/Provision 3 regulations and guidance to explain how to apply base years, claiming percentages, etc. on a district-wide basis, especially for those SFAs that would be adding schools to their established Provision 2/3 situations.

## Food and Nutrition Projects Integrated with Elementary School Curricula:  Sec. 114

**Deletes provisions for grants for food and nutrition projects integrated with elementary school curricula.**
**Effective upon enactment. **

**Notes:**
Section 114.  Food and Nutrition Projects Integrated with Elementary School Curricula
Prior to Reauthorization:   Subject to the availability of appropriations, USDA is required to award grants to a private nonprofit organization or educational institution in each of 3 States to create, operate, and demonstrate food and nutrition projects that are fully integrated with elementary school curricula.  The authorization of appropriations for these grants ($100,000 - $200,000 a year) expired at the end of fiscal year 2003.
[Sec. 12(m) of the NSLA]
Section 114:  
This section deletes provisions for grants for food and nutrition projects integrated with elementary school curricula.

## Procurement Training:  Sec. 115

**Requires USDA to provide technical assistance and training on procurement practices to States and schools. **
**Will include information:**
**To ensure compliance with “Buy American” requirements; **
**on procuring safe foods (including model specifications).**
**$1 million discretionary funding authorized for each fiscal year 2005-2009 – Not provided.**

**Notes:**
Section 115.  Procurement Training
Prior to Reauthorization:   No provisions.
Section 115:  [Section 12(m) of the NSLA]
Subject to the availability of appropriations, this section requires USDA to provide technical assistance and training to States, State agencies, schools, and school food authorities in the procurement of goods and services for child nutrition meal service programs – including 
(1) technical assistance and training to ensure compliance with “Buy American” requirements and 
(2) technical assistance and training on procuring safe foods (including model specifications).  
Annual appropriations are authorized at $1 million a year for each of fiscal years 2005 through 2009, to remain available until spent.

## Summer Food Service Program Section 116

## Summer Food Service Program – Simplified Summer Food Program

**Sec 116(f) makes the Simplified Summer Food Program permanent (formerly 14-State Lugar  Pilot)**

**Notes:**
Section 116(f) amends sec. 18(f) of the NSLA to permanently establish the Simplified Summer Food Program.  This replaces the pilot project that was commonly known as the 14-State Lugar pilot project.  The Simplified Summer Food Program continues the pilot’s provisions, includes the 14 States that qualified under the pilot, expands the number of eligible States, and includes all sponsors in eligible States. The law also requires an evaluation report by April 30, 2007.

[The 14-State Lugar pilot project allowed public sponsors of summer food service programs (e.g. schools, local governments) to receive the maximum summer program reimbursement rates without regard to actual costs.  The project operated in 13 States and 1 commonwealth: Alaska, Arkansas, Idaho, Indiana, Iowa, Kansas, Kentucky, Nebraska, New Hampshire, North Dakota, Oklahoma, Puerto Rico, Texas, and Wyoming.  Authorization expired June 30, 2004.]

## Summer Food Service Program – Simplified Summer Food Program (cont.)

**Provides the maximum operating and administrative reimbursements          (meals X rates)**
**No cost comparisons**
**Reimbursements can pay for any allowable Program cost**

**Notes:**
Section 116
The provisions of the pilot project continue with the Simplified Summer Food Program, including:
 --  Sponsors in eligible States receive the maximum operating and administrative reimbursement levels--  i.e., meals are reimbursed at the operating and administrative rates set by the Department for each year.
 --  Reimbursement amounts are not subject to comparisons to actual costs.  
 --  Earned reimbursements can be combined and used to pay for any allowable Program cost (whether operating or administrative).

## Summer Food Service Program – Simplified Summer Food Program (cont.)

**Effective January 1, 2005:**
**Original 14 States continue: AK, AR, ID, IN, IA, KS, KY, NE, NH, ND, OK, PR, TX, WY**
**6 new States may begin: CO, LA, MI, MS, OH, & OR**
**Private non-profit sponsors in all 20 States are eligible**

**Notes:**
Section 116
 Effective January 1, 2005:
 -- The original 14 States continue– Alaska, Arkansas, Idaho, Indiana, Iowa, Kansas, Kentucky, Nebraska, New Hampshire, North Dakota, Oklahoma, Puerto Rico, Texas, and Wyoming. 
 -- Six new States that qualify under an updated formula in the law may begin.  These states are Colorado, Louisiana, Michigan, Mississippi, Ohio, and Oregon. 
-- Also, effective January 2005, all sponsors in the 20 States become eligible.  Under the pilot, private non-profit organizations were not eligible unless they were participating as sponsors of schools, residential camps, or the National Youth Sports Program. 
 -- FNS notified all eligible States by letter on July 1, 2004.

## Summer Food Service Program: Seamless Summer Option

**Section 116(a) added the Seamless Summer Option to the SFSP**
**Available only to School Food Authorities  **
**Similar to NSLP, but provides meals during the summer months**
**Effective upon enactment **

**Notes:**
Section 116.  Summer Food Service Program for Children

This section specifies in law provisions that closely track the current “seamless summer waiver” policy.  
Under this “seamless summer option,” school food authorities may administer summer or school vacation food service under the provisions of the NSLP.   
They receive National School Lunch Program and School Breakfast Program reimbursement at the free rate for meals and snacks.

## Seamless Overview: What is the seamless waiver?

**Combines features of the NSLP, SBP, and SFSP**
**Meals and snacks are reimbursed at NSLP and SBP free rates**
**Eliminates applications**
**Reduces SFSP administrative tasks**

**Notes:**
Section 116
Since the provision in the law is intended to closely track the seamless waiver, FNS wanted to briefly highlight basic information about the waiver.
 -- The seamless waiver as it was designed, combines features of the NSLP, SBP, and the SFSP.
 -- This provision enables the SFA to provide summer food service through the NSLP.
 -- All meals and snacks are reimbursed at the NSLP and SBP free rates.
 -- And it reduces administrative tasks associated with the SFSP.

## Seamless Overview:  What does the waiver accomplish?

**Purpose of the waiver is to encourage schools to feed more children in low-income areas during the summer and other times when school is not in session.**

**Notes:**
Section 116

## Seamless Overview:  What makes the waiver seamless?

**NSLP and SBP policy:**
**Meal patterns/menu selections**
**Counting and claiming procedures**
**Other administrative procedures**

**Notes:**
Section 116
Here are some of the seamless aspects of the waiver:
It follows NSLP and SBP in terms of meal pattern or menu selections, 
Counting and claiming procedures (uses the FNS-10), and 
Most other administrative procedures from the school programs.

## Seamless Overview:  What makes the waiver seamless?

**SFSP policy:**
**Types of sites**
**Use of area eligibility**
**Free meals to all 18 and under**
**Number and types of meals allowed**
**Times of operation**

**Notes:**
Section 116
This provision is like the SFSP in terms of:
Location and types of sites,
Use of area eligibility to qualify sites,
Free meals to all children ages 18 and under, 
The number and types of meals that are allowed, and 
The times of operation.

## Seamless Overview

**Uniquely seamless:**
**Reimbursement at NSLP/SBP free rates**
**SFAs monitor sites within 3 weeks of start-up**
**States must visit seamless site in CRE review of the SFA**

**Notes:**
Section 116
Finally, the waiver has some features that are unique to the seamless waiver:
Reimbursement at NSLP/SBP free rates, required monitoring visit by SFAs to each new site within 3 weeks of start-up, and State agency oversight which includes a visit to a seamless site during the CRE review of a SFA.

## Seamless Overview:  How did the waiver get started?

**FY 01, Five school districts were approved in CA and FL**
**FY 02, waiver expanded nationwide**
**FY 03, States authorized to approve**
**FY 04, FNS extended waiver**

**Notes:**
Section 116
The Seamless Waiver began with a request from the Alisal Union Elementary School District in California.  Also, California program advocates encouraged approval of the waiver.  So, in FY 01 the first waivers were approved for 5 SFAs – 2 in California and 3 in Florida.
In FY 02, the waiver was expanded nationwide.  
FNS ROs approved over 500 SFAs for participation In FY 03, FNS reduced reporting requirements and authorized States to approve waivers.

## Seamless Overview:  Where does FNS go from here?

**States retain approval authority **
**FNS will issue guidance in winter 2005**
**Interim rule will be published**

**Notes:**
Section 116
States retain approval authority and can continue to permit SFAs to operate under previously approved procedures. 

FNS will issue guidance for FY 2005.

FNS to publish an interim final regulation that will implement the provisions for a seamless option. 

## Summer Food Service Program – Rural Transportation Grants

**Sec 116(d) establishes a limited rural transportation grant pilot**
**No more than 5 States and no more than 60 institutions **
**$2 million in FY 2005 and $1 million in each of FY’s 2006 and 2007 **

**Notes:**
Summer food service rural transportation grants 
Prior to Reauthorization:   No provisions.
Section 116:   [Section 13(a)(10) of the NSLA]
This section requires USDA to provide grants to increase participation in congregate feeding sites under the Summer Food Service Program through innovative approaches to limited transportation in rural areas.  
The grants would be provided through not more than 5 State agencies to not more than 60 eligible service institutions – selected by USDA.  
Eligible service institutions would be allowed to conduct a program for 3 successive fiscal years, and mandatory funding is provided ($2 million for Fiscal Year 2005, and $1 million a year for Fiscal Years 2006 and 2007, available until spent).  

## Summer Food Service Program – Rural Transportation Grants (cont.)

**Interim report on the grants due to Congress on January 1, 2007**
**Final report due to Congress on January 1, 2008**

**Notes:**
Section 116
Also required are an interim report and a final report (due by January 1, 2008).

## Summer Food Service Program: Pennsylvania Rural Eligibility Pilot

**Sec 116(c) permits rural areas in Pennsylvania to determine site eligibility based upon 40% free and reduced price instead of 50%**
**Effective for calendar years 2005 and 2006 only**

**Notes:**
Rural Area Eligibility for Summer Food Service
Prior to Reauthorization:   No provisions. 
Note:  Under section 13(a)(1) of the NSLA, summer food service programs in “areas in which poor economic conditions exist” operate as “open-site” programs in which all participating children are served free meals.  “Areas in which poor economic conditions exist” are defined as those in which more than 50% of the children are eligible for free or reduced-price school meals.
Section 116:   [Section 13(a)(9) of the NSLA]
This section stipulates that, in rural areas of Pennsylvania, the threshold for “open-site” programs will be 40% – for calendar years 2005 and 2006.

## Guidance to PA to be issued Winter 2005
An evaluation of the project is due to Congress January 1, 2008
$400,000 mandatory funding provided for the evaluation 

**An evaluation of the project is due to Congress January 1, 2008**
**$400,000 mandatory funding provided for the evaluation **

**Summer Food Service Program: Pennsylvania Rural Eligibility Pilot ****(cont.)**

**Notes:**
Section 116 also requires USDA to conduct an evaluation of the lowered threshold.  
A report is due not later than January 1, 2008, and mandatory funding (a total of $400,000) is provided to carry out the evaluation, to be available until spent

## Commodity DistributionProgram: Sec. 117

**Makes permanent USDA’s authority to use section 32 and Commodity Credit Corp. funds to maintain****the annually  programmed level of commodity assistance.**

**Notes:**
Section 117.  Commodity Distribution Program
Prior to Reauthorization:   USDA is required to use “Section 32" and Commodity Credit Corporation funds to maintain the “annually programmed level of commodity assistance” for child nutrition and Older Americans Act programs (i.e., supplement appropriated funds in order to ensure that the covered programs receive the value of commodities they are “entitled” to receive).  This requirement was to expire June 30, 2004.

Section 117:  [Sec. 14(a) of the NSLA]
This section makes the requirement for USDA to use “Section 32" and Commodity Credit Corporation funds to maintain the “annually programmed level of commodity assistance” permanent. 

## Notice of Irradiated Food Products Section 118 

## Notice of Irradiated Food Products

**USDA to develop policies and procedures to ensure that:**
**Irradiated food products are made available only if requested by States and SFAs**
**Reimbursements (subsidies) to schools for these products are equal to those for non-irradiated products**

**Notes:**
Section 118.  Notice of Irradiated Food Products
Prior to Reauthorization:  No provisions, however the 2002 Farm Bill stated that USDA “shall not prohibit the use of any technology to improve food safety that has been approved by USDA of Agriculture or has been approved or is otherwise allowed by USDA of Health and Human Services” for use in various commodity purchase programs. This includes irradiation.
Section 118:  [Section 14(h) of the NSLA]
This section requires USDA to develop a policy and establish procedures for the purchase and distribution of irradiated food products for school meal programs.  
At a minimum, they must ensure that: 
– irradiated food products are made available only at the request of States and school food authorities;
– reimbursements (subsidies) to schools for these products are equal to those for products that are not irradiated.

Note:  Under current policy and under Reauthorization, USDA may offer schools irradiated food products, but schools are not required to request such products.  

## Notice of Irradiated Food Products (cont.) 

**Policy and procedures must also ensure that States and SFAs are provided factual information on the science and evidence regarding irradiation technology **

**Notes:**
Section 118.  Notice of Irradiated Food Products
Prior to Reauthorization: :  No provisions.  
Note:  Under current policy USDA may offer schools irradiated food products.  

Section 118:   States and school food authorities are provided factual information on the science and evidence regarding irradiation technology.

## Notice of Irradiated Food Products (cont.)

**Information provided to schools must include: **
**Notice that irradiation is not a substitute for safe food handling techniques **
**Other information to promote food safety  **

**Notes:**
Factual information provided by USDA must include:
notice that irradiation is not a substitute for safe food handling techniques, 
Other similar information determined by USDA to be necessary to promote food safety in the school meals programs

## Notice of Irradiated Food Products (cont.)

- USDA to provide model procedures to provide SFAs, parents and students:
- Factual information on the science and evidence on irradiation technology
- Other food safety information

## Notice of Irradiated Food Products (cont.)

**Procedures must also ensure that irradiated food products provided by USDA are appropriately labeled with symbol or other printed notice**
**Containers must have symbol/notice prominently displayed in clear and understandable format**

**Notes:**
Section 118.  Notice of Irradiated Food Products
Prior to Reauthorization: :  No provisions.  

Section 118:  
Policies and procedures must also address:
irradiated food products distributed by USDA are labeled with a symbol or other printed notice that: 
indicates that the product is irradiated.
is prominently displayed in a clear and understandable format on the container.

## Notice of Irradiated Food Products (cont.)

**Irradiated food products are not commingled in containers with non-irradiated foods**
**Schools that offer irradiated food products are encouraged to provide alternatives to irradiated foods **

**Notes:**
Policy and procedures must also ensure that:
irradiated food products are not commingled in containers with other foods products that are not irradiated and
schools that offer irradiated food products are encouraged to offer alternatives to those products in school meals.

## Notice of Irradiated Food Products (cont.)

**Requirements in Reauthorization similar to policy and procedures already in place**