School Meal Programs: More Systematic Development of Specifications Could Improve the Safety of Foods Purchased through USDA's Commodity Program
Published: 2011-05-03T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Through its commodity program, the U.S. Department of Agriculture (USDA) provides commodity foods at no cost to schools taking part in the national school meals programs. Commodities include raw ground beef, cheese, poultry, and fresh produce. Like federal food safety agencies, the commodity program has taken steps designed to reduce microbial contamination that can result in severe illness. GAO was asked to review (1) the extent to which the program's purchasing specifications related to microbial contamination differ from federal regulations, (2) the extent to which specifications for raw ground beef differ from those imposed by some other large purchasers, and (3) examples of schools' practices to help ensure that food is not contaminated. GAO compared the program's purchasing specifications to federal regulations for food sold commercially, gathered information from seven large purchasers of ground beef, and interviewed officials in 18 school districts in five states, selected in part because of their purchasing practices.
section_title: What GAO Found
paragraphs: For 7 of the approximately 180 commodity foods offered to schools, USDA's commodity program has established purchasing specifications with respect to microbial contamination that are more stringent than the federal regulations for the same foods in the commercial marketplace. For example, the commodity program will not purchase ground beef that tests positive for Salmonella bacteria, while federal regulations for commercially available ground beef tolerate the presence of a certain amount of Salmonella. Program officials told GAO that more-stringent specifications are needed for certain foods they purchase because they go to populations, such as very young children, at a higher risk for serious complications from foodborne illnesses. However, the program has not developed more-stringent specifications for some pathogens and foods that have been associated with foodborne illness, such as raw, whole chickens cut into eight pieces that the program provides to schools. Program officials told GAO they selected products for more-stringent specifications based on their views of the safety risk associated with different types of food; developed these specifications through informal consultation with a variety of groups; and did not document the process they used. The commodity program's purchasing specifications related to microbial contamination for raw ground beef at various processing stages are generally similar to those of some other large purchasers. The specifications used by both the commodity program and these large purchasers are more stringent than federal regulations. USDA's commodity program has several purchasing specifications related to microbial contamination for raw ground beef production, process oversight, and testing. For example, the program requires beef suppliers to take actions to reduce the level of pathogens at least twice while beef carcasses are processed. Some large purchasers of raw ground beef have purchasing specifications similar to the commodity program, although they differ in certain details. For example, of the seven large purchasers that GAO interviewed, five said they require their beef suppliers to take between two and seven actions to reduce pathogen levels on beef carcasses. While all school districts must follow certain food safety practices to participate in federally funded school meal programs, school districts that GAO interviewed have also implemented a number of additional food safety practices. Federal regulations require school districts to develop written food safety plans and to obtain food safety inspections of their schools, among other things. In addition, some of the school districts GAO interviewed have established purchasing specifications related to microbial contamination or food safety for food they purchase in the commercial marketplace, among other things. Nevertheless, few of the district officials GAO interviewed were aware that the commodity program's purchasing specifications for seven products are more stringent than federal regulatory requirements. Officials from half of the districts GAO interviewed said that greater knowledge of these differences would affect their future purchasing decisions by enabling them to make more informed choices.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that USDA strengthen its oversight of food purchased by its commodity program, by establishing a more systematic and transparent process to determine whether additional specifications should be developed related to microbial contamination. USDA generally agreed with GAO's recommendations and provided technical comments.

section_title: Letter
paragraphs: The National School Lunch and School Breakfast Programs are federally  assisted programs that provide low-cost or free meals to more than 30  million children each school day in over 100,000 schools nationwide.  Schools taking part in the programs receive cash subsidies and food  provided at no cost, known as “commodities,” from the U.S. Department of  Agriculture (USDA). In recent years, USDA’s commodity program has  purchased over $1 billion worth of about 180 commodities annually,  including raw ground beef, poultry, and mozzarella cheese, and offered  them to schools. In addition, under an agreement between USDA and the  Department of Defense (DOD), schools may choose to receive fresh  produce, such as apples, lettuce, and baby carrots, purchased by DOD for  the commodity program. All told, food provided at no cost by the  commodity program provides about 15 to 20 percent of the food served in  schools, while the remaining 80 to 85 percent is purchased directly by  schools in the commercial marketplace. Like the rest of the nation’s food  supply, the food served in schools is generally safe, although vulnerable to  microbial contamination that can result in illnesses, ranging from  relatively mild to life-threatening or even fatal conditions.
USDA and the Food and Drug Administration (FDA) both have federal  regulatory and oversight responsibilities to, among other things, help  ensure the food industry’s compliance with preventive measures designed  to reduce or eliminate foodborne, disease-causing organisms, known as  pathogens. Agencies within USDA regulate the production of meat,  poultry, and processed egg products, and FDA issues regulations to ensure  the safety of all other foods, including fruits, vegetables, milk, and whole- shell eggs. Virtually all food for sale in the commercial marketplace is  subject to federal regulation and oversight, including testing for pathogens  by federal inspectors and setting limits on the levels of pathogens  detectable in certain foods.
In addition, the commodity program, as the purchaser of the food that  USDA provides at no cost to schools, has established purchasing  specifications for each of the commodities it buys. Some of these  specifications are designed to prevent harmful pathogens and limit the  allowable level of certain bacteria that indicate poor sanitary handling or  preparation conditions in specific commodities. These specifications apply  to foods that are commonly provided to schools. Many of these same  foods have also been associated with foodborne illness, such as raw  ground beef. In addition, large purchasers of food, such as grocery store  and restaurant chains, may include in contracts with their suppliers  specifications designed to prevent, reduce, or eliminate microbial  contamination.
In light of the potential for microbial contamination of food served in  schools, you asked us to examine the standards and procedures that exist  to ensure the safety of food in school meal programs. Accordingly, our  objectives were to examine (1) the extent to which federal purchasing  specifications related to microbial contamination for food in the  commodity program differ from federal regulations for the same foods  available in the commercial marketplace; (2) the extent to which the  commodity program’s purchasing specifications related to microbial  contamination for raw ground beef differ from those imposed by some  large federal and private-sector purchasers; and (3) examples of standards  and practices that exist at the state and school district level to help ensure  that food procured by schools is safe.
To address these objectives, we obtained documentation of USDA’s  purchasing specifications related to microbial contamination for food in  the commodity program, discussed these specifications with federal  officials, as well as with knowledgeable groups and individuals—including  representatives of industry associations and consumer groups—and  compared the specifications with federal regulations for food sold in the  commercial marketplace. We also compared the commodity program’s  purchasing specifications for raw ground beef to information we gathered  on the raw ground beef specifications used by a nonprobability sample of  six large private-sector purchasers—including grocery store chains and  quick-service restaurants—and one large federal purchaser, and analyzed  the findings of a study of USDA’s specifications. In addition, we visited and  held telephone conferences with a nonprobability sample of officials in  five states and 18 school districts selected because of their size;  indications of a prior experience with foodborne illnesses; or other  factors, including use of a food service management company and  participation in a food-buying cooperative. The results from these states  and districts cannot be generalized to other states and districts. Appendix I  provides a more detailed description of our objectives, scope, and  methodology.
We conducted this performance audit from February 2010 to May 2011, in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Background
paragraphs: According to USDA, the National School Lunch Program and the National  School Breakfast Program share the goals of improving children’s  nutrition, increasing lower-income children’s access to nutritious meals,  and supporting the agricultural economy. USDA’s commodity program  contracts for the purchase of food for these programs with manufacturers  that it selects through a competitive bidding process. At the state level,  state education departments typically administer the meals programs and  forward the commodity selections of individual schools to USDA’s  commodity program, which purchases and distributes the food selected by  schools. In 2009, schools most commonly ordered chicken, mozzarella  cheese, potatoes, and ground beef items purchased by the commodity  program, in addition to fresh produce purchased for the commodity  program by DOD in conjunction with DOD’s large-scale efforts to supply  fresh produce to its troops. Overall, USDA provides about 15 to 20 percent  of the food served in school meals. Schools purchase the remainder  independently using their own procurement practices, either purchasing  foods directly from manufacturers or distributors or contracting with food  service management companies that procure the food for them.
Three agencies within USDA are primarily responsible for the planning,  purchase, allocation, and distribution of commodities to states and school  districts: the Food and Nutrition Service, the Agricultural Marketing  Service, and the Farm Service Agency (referred to collectively in this  report as USDA’s commodity program). In addition to administering the  National School Lunch Program and the National School Breakfast  Program, the Food and Nutrition Service has overall authority to  administer USDA’s commodity program and coordinate all commodity  orders submitted by states. The Agricultural Marketing Service purchases  meats, poultry, seafood, fruits, and vegetables; while the Farm Service  Agency purchases dairy products, grains, peanut products, and other  items.
Virtually all food for sale in the United States must comply with federal  food safety laws and regulations. Federal efforts for ensuring food safety  include focusing on preventing or reducing contamination by bacterial  pathogens such as E. coli O157:H7, a toxin-producing strain of the  intestinal bacterium E. coli; Salmonella; and Campylobacter; and  monitoring levels of other bacteria, such as generic E. coli and fecal  coliforms, which indicate the extent to which food was produced under  sanitary conditions. USDA, through its Food Safety and Inspection Service  (referred to throughout this report as USDA’s meat and poultry regulatory  program), is responsible for ensuring the safety of meat, poultry, and  processed egg products, and FDA is responsible for ensuring the safety of  virtually all other food products, including grains, nuts, and produce. GAO  has reported that federal oversight of food safety remains fragmented in  several areas, and that this fragmentation has caused inconsistent  oversight, ineffective coordination, and inefficient use of resources.  Existing statutes give these agencies different regulatory and enforcement  authorities. For example, food products under USDA’s jurisdiction must  generally be inspected and approved as meeting federal standards before  being sold to the public. Under current law, thousands of regulatory  inspectors of meat and poultry are to maintain continuous inspection at  slaughter facilities and examine all slaughtered meat and poultry  carcasses. They also visit other meat- and poultry-processing facilities at  least once each operating day. FDA is responsible for ensuring that all  foods it regulates are safe, wholesome, and properly labeled. To carry out  its responsibilities, FDA has authority to, among other things, conduct  examinations and investigations and inspect food facilities. But unlike  foods regulated by USDA, food products under FDA’s jurisdiction may be  marketed without FDA’s prior approval. For fresh cut fruits and  vegetables, FDA has issued guidance, which food manufacturers may  voluntarily use to minimize microbial contamination. FDA has also  established regulations that serve as the minimum sanitary and processing  requirements and may take enforcement actions against firms that do not  comply with these requirements. Under the FDA Food Safety  Modernization Act, the agency is required to promulgate regulations for  produce safety that would establish science-based minimum standards for  the safe production and harvesting of certain raw fruits and vegetables for  which FDA determines such standards could minimize the risk of serious  adverse health consequences or death.
While food may be contaminated by many different bacteria, viruses,  parasites, toxins, and chemicals, this report focuses on disease-causing, or  pathogenic, bacteria. Contamination may take place during any of the  many steps in growing, processing, storing, and preparing foods. Some  potentially life-threatening pathogens live in soil, water, or the intestinal  tracts of healthy birds, domestic animals, and wildlife. As a result, produce  may become contaminated if irrigated with tainted water, and the  carcasses of livestock and poultry may become contaminated during  slaughter if they come into contact with small amounts of intestinal  contents. Foods that mingle the products of many individual animals— such as bulk raw milk, pooled raw eggs, or raw ground beef—are  particularly susceptible, because a pathogen from any one of the animals  may contaminate the entire batch. A single hamburger, for example, may  contain meat from hundreds of animals. Pathogens can also be introduced  later in the process—such as after cooking, but before packaging—or by  unsanitary conditions—including contact with infected food handlers or  contact with contaminated equipment or surfaces. Still, pathogens are  generally destroyed when foods are properly cooked. In addition, the  presence of pathogens can be greatly reduced by subjecting food to  ionizing radiation, known as food irradiation. On the basis of extensive  scientific studies and the opinions of experts, we reported in 2000 that the  benefits of food irradiation outweigh the risks.
According to the Centers for Disease Control and Prevention (CDC),  foodborne disease is a major cause of illness and death in the United  States. CDC routinely gathers information from local and state health  departments and laboratories and reports information about a range of  foodborne illnesses and the foods with which they are associated. In 2011,  CDC estimated that approximately 48 million people become sick, 128,000  are hospitalized, and 3,000 die each year from foodborne diseases. CDC  attributed about 90 percent of the illnesses, hospitalizations, and deaths  having a known cause to eight pathogens, including four bacteria— Salmonella, Campylobacter, E. coli O157:H7, and Listeria  monocytogenes—that are included in USDA’s regulatory oversight of meat  and poultry and in the purchasing specifications of USDA’s commodity  program (see table 1). The four other pathogens are norovirus,  Clostridium perfringens, and Staphylococcus aureus—which are most  often spread by improper food handling or contamination by infected food  handlers—and Toxoplasma gondii, a parasite commonly found in people  and the environment that typically does not result in illness. The  commodity program requires testing for Staphylococcus aureus as an  indicator of poor sanitary handling or preparation conditions in raw  ground beef, diced cooked chicken, and baby carrots.
Information reported to CDC shows hundreds of instances of foodborne  outbreaks affecting children in schools during a recent 10-year period. An  outbreak occurs when two or more similar illnesses result from the  consumption of a common food. According to CDC documents, many  clusters of illnesses are not investigated or reported to CDC because of,  among other reasons, competing priorities at state and local health  agencies, and because only a small proportion of all foodborne illnesses  reported each year are identified as associated with outbreaks.  Nevertheless, based on CDC’s outbreak data for the 10 years from 1999  through 2008 (the most recent year for which data are available), we  identified 478 foodborne outbreaks, affecting at least 10,770 children, that  were associated with schools. Although these outbreaks were associated  with foods prepared or consumed at schools, they do not all relate to food  served as part of school meal programs. For example, the implicated food  may have been prepared at home and consumed at school as part of an  event. Nevertheless, the number of outbreaks associated with schools  represents about 4 percent of the approximately 12,000 foodborne  outbreaks reported to CDC during that period by state and local public  health agencies. As with foodborne disease outbreaks generally, most  outbreaks associated with schools could not be attributed to a single  contaminated ingredient, and many outbreaks’ association with a  pathogen could not be confirmed by a laboratory. We found that  Salmonella was among the most common bacterial pathogens identified as  causing outbreaks associated with schools. Moreover, when outbreaks  associated with schools could be linked to a specific food, they were most  commonly associated with contaminated ingredients such as poultry,  fruits, grain and bean products, dairy, beef, leafy vegetables, and pork.
section_title: Federal Purchasing Specifications for Seven Foods in the Commodity Program Are More Stringent Than Federal Regulations for Those Foods in the Commercial Marketplace
paragraphs: For seven of the foods it purchases, the commodity program’s  specifications related to microbial contamination are more stringent than  federal regulations for those foods in the commercial marketplace.  Nevertheless, the program’s more-stringent purchasing specifications may  not apply to all foods and pathogens of concern.
subsections: section_title: For Seven Foods, the Commodity Program’s Specifications Related to Microbial Contamination Are More Stringent Than Federal Regulations for Those Foods in the Commercial Marketplace
paragraphs: For 7 of the approximately 180 commodity foods offered to schools,  USDA’s commodity program has established purchasing specifications  with respect to microbial contamination that are more stringent than the  federal regulations for the same foods available in the commercial  marketplace. For example, the commodity program will not purchase raw  ground beef that tests positive for Salmonella. On the other hand, USDA  regulations for commercially available raw ground beef tolerate the  presence of a certain amount of Salmonella. Specifically, a facility meets  regulatory performance standards if, on the basis of USDA’s regulatory  inspections, 7.5 percent or less of raw ground beef samples the agency  collects test positive for Salmonella. In addition, while the commodity  program rejects all raw boneless or ground beef that tests positive for   E. coli O157:H7, USDA regulations allow such beef to enter commerce if it  is first cooked. Moreover, the commodity program, through its purchasing  specifications, rejects ground turkey and diced cooked chicken if  microbial testing reveals levels of certain bacteria, which indicate  deficiencies in sanitation during production of these foods, are above  established limits. Federal regulations, on the other hand, do not require  that these same foods destined for the commercial marketplace be tested  for these organisms. Table 2 lists the seven foods for which the commodity  program’s purchasing specifications related to microbial contamination  are more stringent than federal regulations.
Officials of USDA’s commodity program told us that more-stringent  standards are needed for certain foods in the commodity program because  commodity foods go to school-age children as well as populations, such as  very young children, who are considered at a higher risk than the general  population for serious complications from foodborne illnesses. For the  remainder of the 180 commodity foods, the purchasing program requires  that suppliers meet existing federal regulations for food in the commercial  marketplace. For example, all ready-to-eat meat and poultry must adhere  to federal regulatory limits for Listeria monocytogenes.
Commodity program officials told us they selected products for more- stringent specifications on the basis of their views of the safety risk  associated with different types of food. For example, in their view, raw  meat products that are ground present a higher risk than other meat  products because they include meat from the surface of carcasses that, if  contaminated, could spread contamination throughout a large volume of  finished raw ground product. Similarly, one contaminated egg could  spread contamination through a large batch of liquid eggs. Also, program  officials said that cooked diced chicken requires additional microbial  testing because it is handled after cooking and before packaging.
While officials of USDA’s commodity program told us they consult with a  variety of groups and individuals in developing purchasing specifications  related to microbial contamination, they did not document these informal  consultations. For example, commodity program officials said some  purchasing specifications, such as those for raw ground beef, were based  in part on consultations with industry representatives and other agencies  within USDA, while other purchasing specifications were based on  information that has been gathered over time through informal  consultation with internal and external food safety experts. Commodity  program officials also stated that they consult with USDA’s meat and  poultry regulatory program and food safety experts as they change  purchasing specifications. In addition, commodity program officials stated  that, each year, USDA’s meat and poultry regulatory program and one of  USDA’s research agencies review the purchasing specifications for some  of the meat, poultry, and liquid egg products to ensure that the  specifications meet minimum regulatory requirements. Nevertheless,  commodity program officials told us they did not maintain documentation  regarding the process by which they developed their purchasing  specifications for the seven products that have more-stringent  specifications related to microbial contamination. In addition, we have  previously reported that when agencies relied on informal coordination  mechanisms and relationships with individual officials to ensure effective  collaboration, the efforts may not continue once personnel move to their  next assignments.
section_title: The Commodity Program’s More-Stringent Purchasing Specifications Do Not Apply to All Foods and Pathogens of Concern
paragraphs: While USDA’s commodity program has more-stringent purchasing  specifications related to microbial contamination for seven products, it  has not developed more-stringent specifications for some commodities it  provides to schools that have been associated with foodborne illness and  outbreaks. For example, according to data collected by CDC, poultry is  among the most common foods associated with foodborne illnesses and  outbreaks and has been associated with bacterial pathogens such as  Salmonella, Campylobacter, and Clostridium perfringens. While most of  the poultry items the commodity program provides to schools are  precooked, the program does provide raw, whole chickens cut into eight  pieces to schools. Despite food safety concerns about this product,  however, the commodity program does not have more-stringent  purchasing specifications related to testing and sampling for microbial  contamination for it, as it does for other foods that present food safety  risks. Nevertheless, according to program officials, other specifications for  this product—such as holding it within certain temperatures and  processing it within 7 calendar days after slaughter—are designed to  control microbial contamination.
In addition, USDA’s commodity program has more-stringent purchasing  specifications for one of the ready-to-eat meat and poultry products it  provides to schools—diced cooked chicken—but not for others. The  commodity program provides schools several ready-to-eat meat and  poultry products, including cubed ham and smoked turkey breasts. These  products, like all ready-to-eat meat and poultry products, must not test  positive for Listeria monocytogenes, in accordance with federal  regulatory requirements. The commodity program, in its purchasing  specifications, does not require testing for any additional pathogens or  other bacteria for these food products, as it does for the cooked diced  chicken it purchases. Program officials explained that they believe most of  the ready-to-eat meat and poultry products they purchase present less of a  contamination risk because they are placed in sterile sealed packages for  cooking and shipping, but others have raised concerns about these types  of products. For example, representatives of a large food distributor we  interviewed stated that ready-to-eat meat and poultry products are their  biggest food safety concern after raw meat and poultry. One food industry  safety expert told us he thought that all of the commodity program’s ready- to-eat meat products should have more-stringent specifications related to  microbial contamination. One large urban school district we interviewed  required its commercial suppliers to test all ready-to-eat meat and poultry  products for a variety of pathogens and other bacteria, including  Clostridium perfringens, Shigella, and Staphylococcus aureus, in  addition to Salmonella and Listeria monocytogenes. Finally, according to  active surveillance conducted by CDC, the incidence of Listeria  monocytogenes in 2009 was at its highest rate since 1999.
Similarly, USDA’s commodity program has more-stringent purchasing  specifications related to microbial contamination for some of the fresh  produce items it provides to schools but not others that have been  associated with foodborne illness and outbreaks. Currently, the  commodity program applies purchasing specifications related to microbial  contamination to minimally processed fresh produce items—sliced apples  and baby carrots—but not to other fresh produce items. However, these  two commodities are only offered on a trial basis to a limited number of  schools. Most of the fresh produce—including most of the minimally  processed items such as sliced apples and baby carrots—that schools  obtain through the commodity program is purchased by DOD. The  agreement between the commodity program and DOD does not require  DOD to use the same purchasing specifications related to microbial testing  that the commodity program uses for the produce it purchases. DOD  officials told us the agency relies on federal regulations to ensure food  safety but may occasionally test fresh produce items for microbial  contamination. In contrast, the commodity program requires its suppliers  to test for pathogens and other bacteria on an ongoing basis. Therefore,  baby carrots and sliced apples purchased by the commodity program  undergo more-stringent microbial testing than the baby carrots and sliced  apples purchased for schools by DOD. Because commodity program  specifications are more stringent than DOD specifications for these  products, the commodity program initiated conversations with DOD  officials in 2010 to explore having DOD use the more-stringent standards,  according to commodity program officials.
DOD purchases most of the other fresh produce distributed to schools in  the commodity program and relies on current federal regulations that do  not require microbial testing for produce in the commercial marketplace.  DOD officials told us they do not have any more-stringent purchasing  specifications related to microbial contamination for any of these produce  items. While the commodity program purchases and distributes to schools  a few fresh produce items—whole apples, oranges, pears, and potatoes— in addition to baby carrots and sliced apples, DOD purchases and  distributes to schools several times the amount of fresh and minimally  processed produce purchased by the commodity program and a wider  variety of produce items, including grapes, lettuce, celery, broccoli, and  spinach. In recent years, many foodborne disease outbreaks and illnesses  have been associated with fresh produce, including items like those that  DOD purchases for schools. For example, in 2006, bagged spinach  contaminated with E. coli O157:H7 sickened an estimated 238 people,  killed 5 people, and cost the industry an estimated $80 million in lost sales.  As a result, the company most closely linked to this outbreak now  routinely tests its spinach and other leafy greens for E. coli O157:H7. While  DOD did not purchase this contaminated bagged spinach item or  distribute it through the commodity program, according to DOD and  USDA officials, DOD does purchase other bagged spinach products and  provides them to schools. In addition, in the past year, chopped celery  contaminated with Listeria monocytogenes was linked to an outbreak in  one state that resulted in 5 deaths, and alfalfa sprouts contaminated with  Salmonella sickened an estimated 140 people in 26 states and the District  of Columbia. Officials we interviewed in a midsize urban school district  said they do not serve what they called “high-risk” raw produce items,  such as spinach and bean sprouts, because children are at a higher risk of  complications from foodborne illness.
Recently recognized pathogens have been associated with a variety of  foods, including meat and fresh produce, that are not addressed either by  the commodity program’s purchasing specifications or by federal  regulations. Specifically, public health officials have shown that at least  six strains of E. coli other than E. coli O157:H7 produce the same  potentially deadly toxins and life-threatening illness. CDC has estimated  that these strains cause approximately 113,000 illnesses and 300  hospitalizations annually in the United States. Outbreaks associated with  these six strains of E. coli have involved lettuce, raw ground beef, and  berries, among other foods, according to CDC. For example, in 2010, two  students in New York state developed a disease with complications, such  as kidney failure and anemia, after consuming romaine lettuce  contaminated with one of these strains, which the school district  purchased commercially. Officials in this district told us that, as a result of  the outbreak, the district reduced the amount of lettuce it served and  stopped purchasing the particular bagged lettuce product associated with  the outbreak.
Although USDA’s commodity program has not developed any purchasing  specifications related to microbial contamination to address the risks from  these non-O157 strains of E. coli, federal regulatory agencies have  considered taking action to address them, and some food companies have  begun to test their products for these strains. In October 2007, USDA,  FDA, and CDC cosponsored a public meeting to consider the public health  significance of non-O157 E. coli in the U.S. food supply. As of February  2011, USDA’s meat and poultry regulatory program is considering  conducting routine testing for the presence of six non-O157 strains of   E. coli in certain raw beef products. In addition, some companies in the  food industry have developed their own tests and are currently using these  methods to determine whether the food they produce is contaminated  with strains of non-O157 E. coli. For example, we visited one produce  company that routinely tests its leafy greens for these strains. In addition,  USDA’s meat and poultry regulatory program has collaborated with  industry to develop tests that could rapidly detect six such strains in raw  ground beef. As of February 2011, officials for USDA’s meat and poultry  regulatory program said that the department had developed standardized  tests to detect all six strains.
section_title: The Commodity Program’s Specifications for Raw Ground Beef Are Generally Similar to Those of Some Other Large Purchasers
paragraphs: While virtually all food for sale in the commercial marketplace must meet  federal regulatory requirements, federal agencies and others may apply  more-stringent purchasing specifications in the contracts they use to  purchase food. USDA’s commodity program has several purchasing  specifications related to microbial contamination for raw ground beef  production, process oversight, and testing. Like the commodity program,  some other large purchasers of raw ground beef that we interviewed have  purchasing specifications in similar areas, although the specifications  differ in certain details. In response to a request from the commodity  program, the National Research Council found that the scientific basis for  the program’s purchasing specifications for raw ground beef, which were  revised in 2010, is unclear.
subsections: section_title: The Commodity Program Has Purchasing Specifications Related to Microbial Contamination for Raw Ground Beef Production, Process Oversight, and Testing
paragraphs: The purchasing specifications for raw ground beef set by USDA’s  commodity program in 2010, which are more stringent than federal  regulatory requirements for foods in the commercial marketplace, are  designed to prevent, reduce, or eliminate microbial contamination through  (1) steps taken when cattle are slaughtered, (2) oversight of the suppliers’  slaughter and grinding processes, and (3) microbial testing of the raw  ground beef at different points in the production process from slaughter  through grinding. The commodity program’s purchasing specifications  include the following:    Steps when cattle are slaughtered: The slaughter processes used by beef  suppliers must include at least two actions—known as antimicrobial  interventions—designed to reduce the level of pathogens on the beef  carcasses. One of these interventions must occur at a critical point in the  production process where such interventions are likely to effectively  reduce pathogen levels. For example, beef suppliers may use interventions  to control contamination of the carcass from the hide during skinning or  from the gastrointestinal tract during evisceration, or to control the  growth of pathogens when the carcass is chilled or when the finished  product is stored. Suppliers may use such interventions as organic acids,  hot water, or steam applied to the carcass; physical actions; or a  combination of interventions in sequence. For example, a slaughter facility  might combine a physical intervention, such as trimming away visible  contamination on the carcass with a knife, with other antimicrobial  interventions, such as spraying the carcass with very hot water, to improve  the microbial safety of the beef carcass after slaughter, skinning, and  evisceration. In addition, beef suppliers must validate—either through  existing agency guidance or studies they conduct—that the interventions   they use reduce the level of harmful pathogens on carcasses by at least  99.9 percent.
Oversight of suppliers’ slaughter and grinding processes: Before  purchasing raw ground beef from a supplier, commodity program officials  visit the supplier’s facilities to evaluate, among other things, its quality  control programs, equipment, and documentation that the supplier’s  product complies with the program’s specifications. After purchases have  begun, commodity program officials periodically inspect the supplier’s  facilities, processes, and documentation at a frequency dictated by the size  of the purchases. For example, these inspections occur monthly for  suppliers with multiple, ongoing contracts, and they occur at least once  during each contract period for suppliers with intermittent contracts. If  deficiencies are discovered, these inspections may occur more often.  Finally, when raw ground beef is being produced, commodity program  officials must be present to monitor the supplier’s performance, verify  compliance with the program’s specifications, and obtain samples of raw  ground beef for microbial testing, among other things.
Microbial testing of raw ground beef at different points during  production: Beef suppliers must send samples of raw boneless beef before  and after it is ground to a laboratory, accredited by the commodity  program, where the samples are tested for the full range of microbes  detailed in the commodity program’s purchasing specifications. Under the  current specifications, samples must be taken from each 2,000-pound lot  of raw boneless beef to be ground and each 10,000-pound lot of finished  raw ground beef. Samples of finished raw ground beef are selected at 15- minute intervals during grinding. Suppliers may not distribute the raw  ground beef to schools until the test results are known. In the event that  test results reveal the presence of Salmonella or E. coli O157:H7, the  supplier must notify both the commodity program and USDA’s meat and  poultry regulatory program. The commodity program rejects raw ground  beef contaminated with these two pathogens. The commodity program  uses test results of other bacteria to help ensure that the raw ground beef  it distributes to schools is produced under sanitary conditions. If the levels  of these bacteria exceed certain thresholds, the commodity program  rejects the affected lot of raw boneless beef or ground beef. Suppliers that  fail to maintain sanitary conditions are barred from producing raw  boneless beef or ground beef for the commodity program until they take  corrective action to restore sanitary conditions.
section_title: Some Other Large Purchasers of Raw Ground Beef Have Similar, More- Stringent, Purchasing Specifications, Although Certain Details Differ
paragraphs: The seven large purchasers of raw ground beef we interviewed (six large  private-sector purchasers—including grocery store chains and quick- service restaurants—and one large federal purchaser) relied on  purchasing specifications related to microbial contamination for raw  ground beef production, process oversight, and testing that were the same  or substantially similar to those used by USDA’s commodity program, with  variation in such things as the number or placement of required  antimicrobial interventions designed to reduce microbial contamination.  The specifications used by these purchasers, like those used by the  commodity program, call for more-stringent testing for microbial  contamination than do federal regulations for the same foods in the  commercial marketplace. Officials at a meatpacking plant we visited said  that both the commodity program’s specifications and those of its large,  private-sector customers include high standards with only slight  differences. In addition, two large purchasers pointed out that  specifications may vary depending on the intended use of the raw ground  beef. For example, a quick-service restaurant chain that maintains strict  control over its cooking processes may have specifications that differ from  those of the commodity program and grocery store chains, which have no  control over how the raw ground beef they purchase is cooked. The  purchasing specifications shared by the seven purchasers we interviewed  are generally as follows:    Steps when cattle are slaughtered: All but two of the large purchasers told  us they require suppliers to apply interventions on beef carcasses to  reduce the level of pathogens and other bacteria, as the commodity  program does. These purchasing specifications are more stringent than  federal regulatory requirements. The specifications used by these  purchasers differ in terms of the number of interventions to apply, where  in the production process to apply the interventions, and the target level  for the reduction of pathogens.
Number of interventions: Although three of these purchasers, like the  commodity program, require two interventions, one required three, one  required seven, and another purchaser did not dictate the number of  interventions, as long as its suppliers achieved a given reduction in the  levels of pathogens.
Where to apply interventions: Some of these purchasers specify where  interventions should be applied. For example, like the commodity  program, one purchaser requires that at least one intervention be  applied at a critical point in the production process where such  interventions are likely to effectively reduce pathogen levels. Another  purchaser stipulates that both interventions it requires be applied at  such critical points.
Target levels for pathogen reduction: Specifications for the level of  pathogen reduction ranged from removing 99 percent of pathogens to  removing 99.9 percent. One purchaser did not specify a target for  reduction of pathogens but requires its boneless beef suppliers to  demonstrate that their processes will reduce E. coli O157:H7 to  nondetectable levels.
The purchaser that did not include additional measures to reduce the level  of pathogens and other bacteria on beef carcasses in its purchasing  specifications told us it relied on federal regulatory requirements that were  designed to ensure the safety of raw ground beef. This purchaser also said,  however, that some of its suppliers may apply interventions or other  measures that are more stringent than federal regulations as part of their  routine business practices.
Oversight of suppliers’ slaughter and grinding processes: All the  purchasers we interviewed use one or more of the following measures to  oversee the performance of their raw boneless beef and ground beef  suppliers: initial approval of suppliers, periodic inspections, and on-site  presence during grinding. But they differ in their specifications for who  must conduct the inspections and how frequently the inspections must  occur as follows:   Like the commodity program, most of the purchasers require initial  approval of potential suppliers and purchase raw boneless and ground  beef only from approved suppliers. For example, one purchaser said it  requires that both its suppliers and grinders certify that they can meet  its quality specifications before contracting with them.
All of the purchasers told us they require periodic inspections of their  beef suppliers or grinders; most use both their own employees and  third parties to conduct these inspections. For example, one purchaser  uses its own employees and those of its grinders to inspect its suppliers  of boneless beef at least once annually. This purchaser also requires  both its raw boneless beef and its raw ground beef suppliers to undergo  at least one annual audit by a third party.
One purchaser had its own employees on site when its beef was being  ground—as the commodity program does—because all its raw ground  beef is produced either at a large company-owned facility or in its own  stores.
Microbial testing of raw ground beef at different points during  production: Most of the purchasers we interviewed told us they require  their suppliers to sample beef before and after it is ground, to test these  samples for pathogens, and to meet specified thresholds related to those  pathogens. Their specifications differed, however, in terms of how they  sampled raw boneless beef and ground beef and the microbial testing they  require as follows:   One purchaser said it requires that samples be gathered twice from  each 2,000-pound lot of boneless beef, once before it leaves the  meatpacking plant, and once when the lots arrive at the grinder.  Another purchaser, like the commodity program, required samples of  finished raw ground beef to be taken every 15 minutes during grinding,  and one required samples to be taken about every 9 minutes.
Like the commodity program, most of these purchasers require that  their suppliers retain control of the raw ground beef until the test  results are known. These purchasers reject raw boneless or ground  beef contaminated with E. coli O157:H7. One purchaser also requires  suppliers to test boneless beef for pathogens that indicate whether it  was produced under sanitary conditions. This purchaser said it used  the results of such tests, along with other information, to evaluate the  performance of its suppliers, as the commodity program does.
The one purchaser that had not developed specifications for the sampling  and testing of raw boneless or ground beef relied on federal regulatory  requirements, which include limits for E. coli O157:H7 and Salmonella.  While it lacked such specifications for its suppliers, this purchaser may  occasionally test its raw ground beef for microbial contamination.
section_title: The Scientific Basis for the Commodity Program’s Revised Purchasing Specifications for Raw Ground Beef Is Unclear
paragraphs: In 2010, an expert committee convened by the National Research Council  at the request of USDA’s commodity program found that the scientific  basis of the program’s 2010 revisions to its purchasing specifications for  raw ground beef is unclear. In its report, the committee noted that some  specifications were based on industry practices, but it could not determine  the scientific basis of the industry practices. Further, it noted that other  specifications appeared to have been based on information gathered  through informal, ad hoc expert consultation, a method the committee  deemed to be the least preferred form of evidence for developing  specifications. Nevertheless, the committee found that a lack of reported  outbreaks in recent years caused by either Salmonella or E. coli O157:H7  associated with raw ground beef purchased by the commodity program  strongly suggested that the program’s purchasing specifications have been  protective of public health. The committee did, however, recommend that  the commodity program develop a systematic, transparent, and auditable  system for modifying, reviewing, updating, and justifying science-based  purchasing specifications for raw ground beef.
The committee was also asked by USDA to compare the commodity  program’s purchasing specifications to those used by other large  purchasers of raw ground beef. Accordingly, the committee reviewed the  purchasing specifications for raw ground beef used by 24 large corporate  purchasers and found considerable variation with regard to acceptable  levels of microbes. Specifically, the committee found substantial  differences among the 24 purchasers in their criteria for bacteria that  indicate the extent to which production conditions are sanitary, such as  generic E. coli, as well as for Salmonella, Listeria monocytogenes, and   E. coli O157:H7. The committee attributed the variations, in part, to the  intended use of the raw ground beef. For example, specifications for raw  ground beef distributed in frozen form may need to differ from purchasing  specifications designed to improve the shelf life of fresh ground beef.  According to its report, because the committee lacked information on the  scientific basis for the corporate purchasing specifications, it could not  directly compare the commodity program’s specifications with those of  the corporate purchasers. The commodity program revised its purchasing  specifications for raw ground beef in 2010 in response to concerns  expressed in the media that the program’s existing specifications were not  as stringent as those of large-scale purchasers of raw ground beef in the  corporate sector, such as quick-service restaurants.
section_title: School Districts Have Adopted a Variety of Food Safety Practices to Help Ensure That Food Served in Schools Is Safe
paragraphs: While all school districts must follow certain food safety practices to  participate in federally funded school meal programs, school districts we  interviewed have also implemented a number of additional food safety  practices. For example, some of these school districts have established  purchasing specifications related to microbial contamination and have  limited the kinds of foods purchased because of food safety concerns  related to staff training and the adequacy of their facilities.
subsections: section_title: School Districts Must Follow Certain Food Safety Practices to Participate in Federally Funded School Meal Programs
paragraphs: To participate in federally funded school meal programs, federal  regulations require all school districts to, among other things, develop  written food safety plans and obtain food safety inspections of their  schools. Specifically, each school district must implement a food safety  plan that complies with USDA regulations. USDA publishes guidance to  help schools develop plans that identify and mitigate food safety hazards  related to preparing, storing, and serving school meals. These plans  address such things as employee hand washing, proper heating and  cooling methods, documentation of food temperatures, quality assurance  steps, corrective actions, and record keeping. During reviews occurring  every 5 years, state officials, in collaboration with USDA regional officials,  are responsible for verifying school districts’ compliance with this  requirement. Nevertheless, although they believe compliance is high,  USDA officials said that information on compliance with this requirement  is not collected at the national level, although it is collected at the state  level. These officials added that USDA and state officials work with school  districts not in compliance to correct any deficiencies. All 18 school  districts we interviewed provided us documentation of their food safety  plans. (For a list of the school districts in our sample, see app. I.)
In addition, to help schools identify and correct immediate or persistent  food safety problems, schools in each district must be inspected by  relevant state or local health officials at least twice during each school  year. According to the most recent data available from USDA, about 77  percent of schools in the United States met or exceeded this requirement  during the 2009-2010 school year. The percentage of schools that meet the  requirement for two inspections annually has increased from about 58  percent since the 2005-2006 school year, when two inspections were first  required. Nevertheless, according to USDA data, about one in five schools  still do not meet the requirement. Although USDA officials reported that  they stress the importance of the inspections and encourage states to  provide them, schools that do not meet the requirement are not penalized.
In three of the school districts in our sample, all schools had received the  required two inspections during the 2009-2010 school year; the level of  compliance with the requirement varied among the other school districts.  Overall, 60 percent of the schools in the 18 school districts in our sample  received two or more inspections during the 2009-2010 school year.  However, in one large urban school district, fewer than 1 percent of the  schools received two inspections. When that district is excluded from the  calculation, 77 percent of schools in the remaining 17 districts met or  exceeded the requirement for two annual inspections.
According to USDA data, reasons cited by schools for not meeting the  requirement include insufficient staff or funding resources at state and  local health departments to conduct the inspections, the need for these  departments to conduct higher priority work, and the lack of inspectors in  small towns and rural areas. Although a few of the school districts we  interviewed mentioned reasons similar to these, officials in nine districts  we interviewed pointed to two additional issues. First, in five of the  districts, at least some of the schools that did not receive two inspections  were sites without kitchens, where food is delivered from kitchens at  other schools. Such sites had no kitchen facilities for the local health  department to inspect. According to USDA officials, the agency reminds  states each year that inspections are required for food preparation and  service areas in schools. Despite these reminders, we found that state  officials take different approaches to these sites in their annual reporting  of school inspections to USDA. For example, officials for one state include  such sites as not receiving required inspections, while another state  exempts these schools from inspections and does not include them in its  annual report to USDA. While federal regulations state that schools must  obtain a minimum of two food safety inspections during each school year,  they do not make a distinction between schools with or without kitchen  facilities. Furthermore, USDA has not issued guidance to states and school  districts that specifically addresses whether sites that do not prepare food  are subject to the inspection requirement and whether states may exempt  from inspections schools that do not prepare food. Second, seven school  districts we interviewed, including three of the ones that did not receive  inspections at some sites that lacked kitchens, said that they had to pay  local health departments for inspections, which takes funds away from  other parts of districts’ food service budgets. Officials in one of these  districts said that, although their schools are entitled to receive one  inspection per year free of charge, the district would have to pay the  county for a second inspection; as a result, most of the schools in this  district had received only one inspection. Fees paid by school districts for  the two annual inspections ranged from $75 to $618 per school site.
Officials in one large urban district estimated they spent approximately  $65,000 on inspection fees in the 2009-2010 school year.
section_title: School Districts Have Also Implemented a Number of Additional Practices Related to Food Safety
paragraphs: In addition to the steps school districts take to meet federal requirements,  all of the school districts we contacted had implemented other steps to  help ensure the safety of the meals they served. These steps include  establishing purchasing specifications related to microbial contamination  and food safety, considering food safety in deciding which foods to order,  and other practices related to inspections and use of technology. We  selected our nonprobability sample of 18 school districts to include  districts more likely to have developed purchasing specifications and  other food safety practices because of their size, prior experience with  foodborne illnesses, and other factors.
subsections: section_title: While Several School Districts Have Established Purchasing Specifications Related to Microbial Contamination, Some Are Not Aware of More- Stringent Commodity Program Specifications for Some Foods
paragraphs: Several of the school districts in our sample have established their own  microbial purchasing specifications for the food items they purchase in  the commercial marketplace that are more stringent than current federal  regulatory requirements. Overall, 10 of the 18 school districts we  interviewed had developed purchasing specifications related to microbial  contamination or, more generally, food safety. These districts included 6  large urban school districts and 4 smaller urban and suburban districts; 2  of these districts participate in food-buying cooperatives with other  districts. Five districts’ purchasing specifications identified specific  pathogens that the districts ask their suppliers to test their food for, along  with acceptable limits of each. For example, 1 large urban school district  requires that all frozen fully cooked meat and poultry and all ready-to-eat  meat and poultry products it buys commercially be tested for certain  pathogens, including Clostridium perfringens, Listeria, Salmonella,  Shigella, and Staphylococcus aureus. The district rejects any products that  exceed its thresholds for the presence of these and other microbes. The  other 5 school districts have implemented purchasing specifications  related more broadly to food safety. For example, 4 of these districts’  specifications require their suppliers to have in place plans designed to  reduce or eliminate microbial contamination. In addition, 5 of these 10  districts’ purchasing specifications described the districts’ right to send  suppliers’ products for additional microbial testing, although these clauses  often listed neither specific pathogens to be tested for nor thresholds.
Despite some districts having taken such additional steps, none of the  state officials and few of the district officials we interviewed were aware  that, for seven products, the commodity program’s purchasing  specifications related to microbial contamination are more stringent than  federal regulatory requirements for the same foods in the commercial  marketplace. Among the officials in the four school districts that had some  awareness of these differences, officials in two districts said they learned  of the differences through media stories about the commodity program’s  specifications for raw ground beef. Officials in nine of the school districts  we interviewed said that greater knowledge of these differences might  affect their future purchasing decisions. More specifically, they said that  they could use this knowledge to make more informed choices about  which foods to purchase from the commodity program and which to  purchase from the commercial marketplace. For example, one district  official said the information would have an impact, although it would have  to be presented in context and in a way that district officials could easily  understand it. In 2003, we recommended that USDA’s commodity program  highlight on its Web page the more-stringent product safety specifications  it uses when purchasing foods it provides to schools, since this would help  schools ensure that the food they purchase is safe. USDA has not  implemented this recommendation. While USDA has set up a Web site that  includes links to online copies of the commodity program’s purchasing  specifications and related documents, USDA has not made clear that its  purchasing specifications related to microbial contamination for seven  commodity foods are more stringent than federal regulatory requirements  for the same foods in the commercial marketplace.
section_title: Food Safety Concerns Related to Staff and Facilities Limit the Kinds of Foods Some Districts Purchase
paragraphs: Although factors such as cost, nutrition, and quality also influence their  purchasing decisions, officials for several school districts we interviewed  limit the kinds of meat and produce they buy because of concerns about  microbial contamination and food safety, including concerns about their  own staff’s training and the adequacy of their facilities. Specifically, 9 of  the 18 school districts in our sample have discontinued buying raw meat— such as ground beef, chicken, or turkey—for their school meals. Each of  these districts said they purchase only precooked or processed meat  products, whether through the commodity program or in the commercial  marketplace. For example, 3 large urban school districts do not purchase  raw meat because they cannot ensure that the kitchen staff at the many  sites in their districts can handle raw meat safely and cook it to an internal  temperature that would kill pathogens. All of the school districts we  interviewed reported that they trained food service staff on food safety.
Nevertheless, officials in 8 of the 9 districts that no longer purchase raw  meat attributed that decision, at least in part, to concerns about their staff,  including staff turnover and qualifications. In addition to factors related to  staff, officials in 5 districts cited concerns about the adequacy of kitchen  facilities as a reason to eliminate the purchase of raw meat. For example,  officials in a large urban district said that some of its schools were over  100 years old and therefore lacked modern cooking facilities; in some of  its schools, the “kitchen” may be an old ball closet with ovens in it.  Without adequate staff and facilities, officials in these districts said it was  safer to purchase cooked or processed meat.
Although half the districts we interviewed do not buy raw meat, the other  half do. Officials in many of these nine school districts told us they buy  raw meat because it costs less than precooked products, and their staff  and facilities are adequate and able to handle it. For example, the director  of one midsize urban school district’s food service department indicated  that the district has tended to buy more raw meat in recent years, because  it is less expensive than precooked products, and the district has the  facilities to cook and cool these products safely. While these nine districts  buy raw meat, four of them limit its handling in some way, such as  handling it only in a small number of appropriately equipped facilities. For  example, one small urban school district receives raw ground beef at only  one of its kitchen facilities, where it is cooked in one location in that  kitchen by two staff members who have been specifically trained to handle  and prepare it safely.
Moreover, we found that about 30 percent (39 million pounds) of all  ground beef sent to schools by USDA’s commodity program in the 2009- 2010 school year was uncooked. Schools in every state that receives food  from the commodity program received this raw ground beef. The  remainder of the ground beef from the commodity program was cooked  before being sent to schools. In addition, none of the school districts we  contacted reported purchasing irradiated food, such as ground beef.  Largely, school officials said they did not buy irradiated food because  parents did not want it served to their children. Officials of USDA’s  commodity program said that, while the program continues to offer  irradiated beef products, school districts have not ordered any such  products in several years. We have reported that irradiation kills 99.9  percent of the pathogens on food.
Many of the officials in the school districts we interviewed raised concerns  about the safety of fresh produce that, in some cases, were similar to those  raised about raw meat. While all 18 of the districts in our sample reported  buying fresh produce, officials in 12 districts raised concerns about its  safety. For example, 1 suburban school district stopped purchasing bagged  lettuce after some of its students were sickened by it in 2010 during a  multistate outbreak of foodborne illness. While the district now purchases  heads of lettuce and has its own staff wash and chop it, its food service  director acknowledged that the lettuce is now vulnerable to mishandling  by the district’s own staff. Officials in another school district said that  handling fresh produce safely is a concern because of difficulty  maintaining it at or below 41 degrees in its facilities. These officials said  that if the district cannot maintain produce at a safe temperature, it might  have to throw away any leftover salad, which could make fresh salads too  expensive to serve. Nevertheless, 8 of the school districts in our sample  indicated that the recent trend in their district has been toward buying  more fresh produce. For example, 1 large urban school district indicated  that it was expanding its purchases of fresh produce and the number of  salad bars in its schools. In addition, 10 of the school districts we  interviewed said they obtained at least some produce through the  commodity program from DOD. While the remaining 8 school districts said  they purchase all of their fresh produce in the commercial marketplace,  none attributed this practice to concerns about the safety of produce from  DOD.
section_title: School Districts Also Employ a Number of Other Practices to Help Ensure Food Safety
paragraphs: In addition to establishing purchasing specifications related to microbial  contamination and limiting the kinds of foods they purchase, school  districts employ a variety of other practices to help ensure the safety of  the food they purchase, including:  Internal inspections: Ten school districts reported that the district’s own  officials, usually managers, inspect individual schools’ kitchen facilities on  a periodic basis. For example, one large urban district reported that its  officials had been trained by county health inspectors to conduct kitchen  inspections, and these officials did so throughout the district.
Visiting vendors’ facilities: Ten school districts reported that the districts’  own officials visited food vendors’ facilities before or during contract  periods to learn more about the vendors’ food safety procedures, among  other things. For example, one district’s food service director reported  visiting the facilities of two of its suppliers, which helped the director  understand the vendors’ food production processes and their standards.
Technological procedures: Two school districts reported using technology  to help monitor or improve food safety in school kitchens. For example,  officials in one district centrally monitored the temperatures in all of the  district’s walk-in freezers and coolers, as well as the temperature of food  as it was being prepared in the district’s kitchens.
section_title: Conclusions
paragraphs: For seven of the commodity foods it provides to schools, USDA’s  commodity program has developed purchasing specifications related to  microbial contamination that are more stringent than USDA’s and FDA’s  regulatory requirements for these same foods in the commercial  marketplace. The commodity program has developed such specifications  because it serves populations at increased risk of foodborne illnesses and  their more serious complications. Nevertheless, questions remain  regarding whether the program has identified the foods and pathogens  that present the highest risks to the populations the program serves.  Recent outbreaks involving, among other things, various fresh produce  items and non-O157 strains of toxin-producing E. coli, have revealed risks  not addressed by the commodity program’s specifications. More broadly,  questions remain regarding whether the process by which the commodity  program develops these specifications is sufficiently systematic and  transparent. Program officials told us they selected products for more- stringent specifications for the seven commodity foods based on their  views of the safety risk associated with different types of food; that they  developed these specifications through informal consultation with a  variety of groups and individuals; and that they did not document this  process. Moreover, although the commodity program undertook a very  public revision of its purchasing specifications for ground beef in 2010, a  committee of the National Research Council found that the new  specifications were developed through informal, ad hoc consultations and  that their scientific basis was unclear. Development of specifications for  foods offered by the program other than ground beef have not undergone  a similar level of review. In addition, although all 18 of the school districts  we interviewed considered food safety as part of their purchasing  decisions, few were aware of the commodity program’s more-stringent  specifications related to microbial contamination for the seven foods. As a  result, district officials lack information that could help them make more  informed decisions about whether to purchase food from the commodity  program or the commercial marketplace. Furthermore, without more  specific guidance from the commodity program as to how states and  school districts should count schools that do not obtain required health  inspections because they do not prepare food on site, the program may not  have accurate information on the extent to which kitchens that prepare  school meals meet state and local food safety requirements.
section_title: Recommendations for Executive Action
paragraphs: To strengthen USDA’s oversight of the safety of food purchased by its  commodity program and served in federal school meal programs, we  recommend that the Secretary of Agriculture instruct the commodity  program to take the following three actions:    develop a systematic and transparent process to determine whether foods  offered by the program require more-stringent specifications related to  microbial contamination, including steps to: identify pathogens, strains of  pathogens, or other foods that merit more-stringent specifications;  document the scientific basis used to develop the specifications; and  review the specifications on a periodic basis;   share information with school districts in a more explicit form regarding  the foods covered by more-stringent purchasing specifications related to  microbial contamination to enable districts to make more informed  choices; and issue more specific guidance to states and school districts regarding the  applicability of the regulatory requirement for food safety inspections to  schools that do not prepare food.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to USDA, the Department of Health and  Human Services (HHS), and DOD for review and comment. The  departments did not provide official written comments to include in our  report. However, in an e-mail received April 7, 2011, the USDA liaison  stated that USDA generally agreed with all of our recommendations. USDA  and HHS also provided technical comments. We incorporated these  technical comments into the report, as appropriate. DOD did not have any  comments on the report.
We are sending copies of this report to the appropriate congressional  committees; the Secretaries of Agriculture, Defense, and Health and  Human Services; and other interested parties. In addition, this report will  be available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. Key contributors to this report are listed in  appendix II.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The overall objective of this review was to assess the U.S. Department of  Agriculture’s (USDA) standards and procedures to ensure the safety of  food in school meal programs. Specifically, we assessed (1) the extent to  which federal purchasing specifications related to microbial  contamination for food in the commodity program differ from federal  regulations for the same foods available in the commercial marketplace;  (2) the extent to which the commodity program’s purchasing  specifications related to microbial contamination for raw ground beef  differ from those imposed by large federal and private-sector purchasers;  and (3) examples of standards and practices that exist at the state and  school district level to help ensure that food procured by schools is not  contaminated by pathogens.
To address the extent to which federal purchasing specifications related to  microbial contamination for food in the commodity program differ from  federal regulations for the same foods available in the commercial  marketplace, we reviewed applicable laws and regulations. We also  interviewed officials in both USDA’s commodity program and its meat and  poultry regulatory program, and gathered documentation related to  purchasing specifications and regulatory requirements. To determine the  purchasing specifications applied by the Department of Defense (DOD) to  the fresh produce it purchases for distribution to school districts through  the commodity program, we interviewed DOD officials and gathered  related documentation. We also gathered information on regulatory  requirements for fresh produce and other foods not regulated by USDA  through discussions with officials from the Food and Drug Administration  (FDA). FDA officials also provided us related documentation, including  agency guidance for good agricultural, manufacturing, and handling  practices. We then compared the purchasing specifications used by the  commodity program and by DOD with federal regulatory requirements for  food sold in the commercial marketplace. In addition, we discussed these  specifications and regulatory requirements with knowledgeable groups  and individuals—including representatives of industry associations and  consumer groups. To learn more about the extent to which outbreaks of  foodborne illness are associated with schools, we analyzed information  from the Centers for Disease Control and Prevention’s (CDC) Foodborne  Disease Outbreak Surveillance System, which collects information  reported to CDC by state and local health departments on outbreaks of  foodborne illness. Because this information system relies on voluntarily  reported outbreaks, and reporting varies greatly across states, it is not an  adequate way to determine the total number of foodborne illnesses or the  actual extent of outbreaks associated with schools. CDC defines such an  outbreak as two or more similar illnesses that result from the consumption  of a common food. We took a number of steps to assess the reliability of  this data, including interviewing CDC officials regarding how the data are  collected and entered, as well as electronic testing of the data. As a result  of these steps, we determined that the data were sufficiently reliable for  the purposes of our review.
To assess the extent to which the commodity program’s purchasing  specifications related to microbial contamination for raw ground beef  differ from those imposed by other large federal and private-sector  purchasers, we analyzed the commodity program’s purchasing  specifications for raw boneless beef and ground beef. We also conducted  site visits to three beef slaughter and processing facilities to gather  information on the slaughter and grinding process for ground beef, as well  as on these suppliers’ perspectives on the differences in the specifications  used by the commodity program and private-sector purchasers. To gather  information on the specifications used by other large purchasers of raw  ground beef, we selected a nonprobability sample of private-sector  companies based on input from interviews with federal officials, industry  representatives, and consumer advocates. Our sample included two quick- service restaurant chains, two chains of food retailers, one food  distributor, and one food service management company. We also selected  DOD as a large federal purchaser of ground beef. We interviewed officials  from each of these purchasers and gathered documentation regarding  their purchasing specifications for boneless beef and ground beef. In some  cases, officials for private-sector companies declined to provide detailed  information on one or more aspects of their specifications. We then  compared the specifications related to microbial contamination of these  seven large purchasers with those of the commodity program. Specifically,  we compared purchasers’ specifications related to the slaughter process,  their oversight of beef suppliers and grinders, and their microbial testing  practices. Additionally, to gather information on the scientific basis of the  commodity program’s purchasing specifications for ground beef, we  reviewed the findings of a National Research Council report issued in  November 2010.
To identify examples of standards and practices used at the state and  school district level to help ensure that food procured by schools is not  contaminated by pathogens, we selected a nonprobability sample of five  states and 18 school districts to review. We selected this nonprobability  sample of school districts to include districts more likely to have  developed purchasing specifications and other food safety practices,  based on input from state and school district officials. To select this  sample, we searched media reports of foodborne outbreaks involving  schools in selected states over the past 10 years. We also considered  factors such as geographic dispersion and differences in the state agency  responsible for the commodity program. Based on these and other factors,  we selected five states: California, Nebraska, New York, Texas, and  Virginia. We then selected a nonprobability sample of school districts in  each state. In addition to input from state officials, we considered each  district’s size, indications of a prior experience with foodborne illnesses,  and other factors, including whether a district used a food service  management company or participated in a food-buying cooperative. We  either visited or interviewed by phone officials in 18 school districts across  the five states, including three that had been tied to foodborne outbreaks  by media reports, four that were operated by or consulted with food  service management companies, and six that participated in food-buying  cooperatives. We selected school districts for the following localities: in  California, Berkeley, Burbank, Los Angeles, San Diego, San Jose, San  Marcos, Solana Beach, and Vallejo; in Nebraska, Elkhorn, Lincoln, and  Omaha; in New York, Dix Hills, New York, and Wappingers Falls; in Texas,  Dallas and Houston; and in Virginia, Alexandria and Arlington. We also  gathered documentation from these states and school districts, including  copies of food safety plans and purchasing specifications, among other  things. We used the interviews and documentation to identify food safety  practices used by school districts, including the extent to which their  activities were consistent with federal regulatory requirements and  practices the districts themselves had developed. The results from these  states and districts cannot be generalized to other states and districts.
We conducted this performance audit between February 2010 and May  2011, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Cheryl A. Williams, Assistant  Director; Kevin Bray; Ellen Chu; G. Michael Mikota; Justin L. Monroe; Nico  Sloss; and Amy Ward-Meier made key contributions to this report. Also  contributing to this report were Mitchell Karpman and Anne Rhodes-Kline.