School Nutrition Association Milk, Eggs, Peanuts Oh My! Lesley Baradel, RD Wesley Johnson, JD
Objectives 1. Food Allergies basics 2. Current Laws and Regulations 3. Implications for School Nutrition and Food Allergy Management
National Peanut Board Farmer-funded $9 million for food allergy research, education and outreach Scientific Advisory Council Registered Dietitian www.nationalpeanutboard.org
Food Allergy Immune response May effect multiple organ systems Gastrointestinal (GI) Skin Respiratory Cardiovascular Can be deadly Diagnosed by proper testing by board certified allergist Exercise-induced food allergy Food Allergy
How Many People Have Food Allergies? What do you think? Adults More than 3% Children About 6% What are the most common for children? Milk 2.5% Egg 1.5-3.2% Peanut 1.2% 2. American Academy of Allergy, Asthma and Immunology. Available at: http://www.aaaai.org/media/statistics/allergy-statistics.asp#foodallergy
Common Food Allergy Reaction Symptoms Gastrointestinal itchy mouth or throat, abdominal pain, nausea, vomiting, diarrhea Eye Itching, watering, swelling Skin Hives, swelling, atopic dermatitis (eczema) Respiratory Wheezing, repetitive cough, laryngeal edema (swelling of the lips and throat), runny nose Generalized Anaphylaxis* Biphasic Response *Anaphylaxis may involve several of the symptoms listed above and may also involve difficulty breathing, a drop in blood pressure, or loss of consciousness. 5. FAAN. Symptoms. Available at: www.foodallergy.org/page/symptoms1
What about the smell? Reports are anecdotal (self-report) Studies have not reproduced lifethreatening reactions via inhalation or skin contact Hay fever-type reactions are possible Ingestion of the allergen has the potential for life-threatening anaphylactic reaction 6. Simonte SJ, et al. JACI 2003; 112:180-2. Available at: http://www.jacionline.org/article/s0091-6749%2803%2901120-5/abstract
The BIG 8 1. Milk 2. Egg 3. Peanut 4. Tree Nut 5. Fish 6. Shellfish 7. Soy 8. Wheat
Where are the Big 8?
Why the Increase? Hygiene Hypothesis? Environmental? Food Processing? Vitamin D Deficiency? We don t know. I m not dirty, I m challenging my immune system!
Why not just ban? Not recommended False sense of security Focuses on enforcement, not education Liability Where do you stop? Who decides? Customer service
School Allergy Management Guidance Food Allergy & Anaphylaxis Network www.foodallergy.org : School Guidelines Everyone has a part to play: Student Parent School
Team Approach is Essential Student Parent Teacher Administrator Foodservice Manager School Nurse Custodial Services Lunchroom Monitors Bus Driver/Transportation ASP Who Else?
Keys Include Collaborative Team Approach Communication Documentation Emergency Action Plan Training Everyone Emergency Medication Availability Comprehensive Management Plan Foodservice Plans, Training and Implementation
Food Safety in Schools
HACCP & SOP Food allergy management easily fits into HACCP How is cross-contamination/crosscontact currently prevented? What separation techniques are currently used? Has staff been trained to wash hands and change gloves between tasks? What standard operating procedures (SOP) exist or need to be written?
Preventing Cross-Contact Hand washing Handling food allergens Receiving On-site champion Designate areas for: Storage Preparation Cooking Service Prep potential allergens at the end of scheduled prep time
Cleaning Essentials What About Cleaning? Detergent and friction are adequate for removal on: Surfaces Hands *Sanitizer does NOT remove allergens* Separate cleaning, if you have separate tables Train staff 7. Perry TT, et al. JACI 2004; 113:973-6. Available at: http://www.inbio.com/us/images/pdfs/123_perry_jaci_2004.pdf
Reaction Do s Even if you do everything right, accidental exposure CAN happen Take every reaction seriously! Respond immediately follow the Emergency Action Plan, such as Call 911 Administer EpiPen or other Emergency Medication
Resources Food Allergy Research & Education www.foodallergy.org School Nutrition Association www.schoolnutrition.org National Association of School Nurses www.nasn.org/toolsresources/anaphylaxis National Peanut Board www.nationalpeanutboard.org
Legally Speaking Section 504 of the Rehabilitation Act of 1973 (Section 504) Mental or physical impairment that substantially limits a major life activity of Mitigation (epi pens, exposure limits, etc.) Episodic conditions Not all cases qualify case by case analysis!
Is an Individual Health Plan Sufficient? Torrington (CT) Board of Education, 60 IDELR 295 (OCR 2012) Allergies = Assessment for Section 504 eligibility Not substantially limiting? IHP sufficient Substantially limiting? Section 504 Plan IHP can be major component of plan Evaluation?
The Doctor s Role Accommodating Students With Special Dietary Needs (USDA, 2001) Guidance for Food Staff 7 CFR Part 15b Physician s Statement Required for Food Substitutions or Modifications
Discrimination Claims 34 CFR 104.4(a) Districts cannot discriminate against students on the basis of their disability, exclude, them from participating in or deny them the benefits of the school program Protective measures in all areas Washington (NC) Montessori Public Charter, 60 IDELR 79 (OCR 2012)
Free, Appropriate Education
Must You Accommodate Every Request? A.M. ex rel J.M. v. NYC Dept. of Educ., 112 LRP 3144 (E.D.N.Y. 1/17/12) Requested accommodation heating child s food in microwave Legal standard: Meaningful access to programs and services Individualized determination!
Proactive Responses Individualized Planning + Generalized Planning How to Handle Classmates? If you put it into the Plan then you must implement! Allergy Free? Compare: Catoosa County (GA) School District, 57 IDELR 141 (OCR 2011) Virginia Beach (VA) City Public Schools, 59 IDELR 54(OCR 2012)
OCR on Disability Based Harassment Dear Colleague Letter, Oct. 26, 2010 Previously no deliberate indifference Now Proactive response ID nature of the conduct Harassment based on disability? Steps to eliminate hostile environment, address its effects, take steps to ensure there is no recurrence
What Next? Universities facing ADA complaints Lesley University DOJ Settlement over mandatory meal plan University of Washington, Tacoma peanut/nut free classroom signs
Questions?