Clarification of the Policy on Food Consumption Outside of Foodservice Area, and the Whole Grain-Rich Requirement

This memorandum is intended to clarify two issues regarding meals offered under National School Lunch Program (NSLP) and School Breakfast Program (SBP). First, the memorandum clarifies the policy of the Food and Nutrition Service regarding student consumption of certain lunch or breakfast items outside of the foodservice area and meal period. Second, it clarifies the requirement to offer whole grain-rich products in the NSLP and SBP.

Meal Items Outside the Foodservice Area

Meals offered in the NSLP and SBP are intended to be consumed at school in a designated foodservice area during the established meal service period. However, we recognize that with time limited lunch periods and the increased amount of fruits and vegetables offered as part of the meals, some students may be inclined to save some items for consumption at a later time. As a reminder, there is no federal prohibition of this practice, and FNS encourages it as a means of reducing potential food waste and encouraging consumption of healthy school meals. For food safety reasons, this practice should be limited to only food items that do not require cooling or heating, such as a whole fruit or a bag of baby carrots. In addition, schools may also wish to set up sharing tables for appropriate items to minimize food waste. Further, Program operators should be aware of all applicable state and local food safety regulations to ensure that their policies for saving or sharing food are consistent with such standards, as well as their own Hazard Analysis Critical Control Points plans.

We encourage program operators to use this flexibility to facilitate children’s consumption of fruits and vegetables, and help reduce food waste in the NSLP and SBP. Please note that this flexibility is intended to address practical constraints that may prevent students from consuming their entire meal in the foodservice area. It does not imply that school meals may be given to children to take home. In addition, we continue to encourage schools to allow students a reasonable amount of time to select and consume their meals during the meal service period.

Whole Grain-Rich Requirement

We also want to take this opportunity to clarify that 100 percent whole grain products are not required in the NSLP and SBP this current school year, nor will they be required beginning in School Year (SY) 2014-2015. Whole grain-rich products are required in both NSLP and SBP. For the current SY, half of all grains offered must be whole grain-rich. Beginning SY 2014-2015 (July 1, 2014), this requirement extends to all grains offered. Whole grain rich refers to products which contain at least 50 percent whole grains and the remainder of the grains can be enriched. For example, a product containing 2 cups of whole wheat flour and 2 cups of enriched white flour would meet the 50 percent whole grain-rich requirement if there are no other grains in the product.

Because these two misconceptions about school meal policies are being reported by school food authorities (SFAs) with increasing frequency, state agencies should distribute this memorandum to program operators immediately and ensure that SFAs are aware of the flexibilities available to them. SFAs and other program operators should direct any questions concerning this guidance to their state agency. State agencies with questions should contact the appropriate FNS regional office.

Cynthia Long
Deputy Administrator
Child Nutrition Programs