Risk Management |
Article by Stacey Freed
From the May/June 2016 Net Assets
Last year, 16-year-old Colorado high school student Simon Katz ate s’mores, normally a safe treat for him, except that this one had Reese’s Peanut Butter Cups in it and Katz, who was severely allergic to peanuts, went into anaphylactic shock and died. The year before that, 13-year-old Brandon Dixon died after eating a nut-based candy bar at his school in Harlem, New York. And two summers before that at a camp in California, Natalie Giorgi ate a Rice Krispie treat—something she thought was safe—but which had peanut butter mixed in so as to be undetectable. She too went into anaphylactic shock and died.
Tragedies all. And each year the number of children with food allergies increases. Recent CDC estimates say 4 to 6 percent of U.S. children under 18 (nearly 4.5 million children) are affected by food allergies. In addition, “nearly 20 percent of the time a child has his or her first anaphylactic reaction to food is at school. They may not even know they have an allergy,” says Cathy Owens, RN, coordinator of Health Services for the Murrieta Valley Unified School District in California, who worked closely on a law requiring her state’s schools to stock epinephrine auto injectors, aka EpiPens.
With food allergies so prevalent, schools are being asked—possibly required—to step up. In 2012, the U.S. Department of Justice settled a case with Lesley University in which, “for the first time ever the government considers food allergies to be disabilities covered under the Americans with Disabilities Act,” explains Tina Rodriguez, CFO and general counsel for SAGE Dining Services, based in Baltimore. (Rodriguez spoke in February at the 2016 NBOA Annual Meeting about how independent schools are affected by this ruling.) “Anyone covered by ADA must accommodate.”
How are independent schools handling allergens in their dining halls to prevent tragedies, abide by the law and serve healthy food to students, faculty and staff?
No school wants to have to react to something that already happened. Whether a school has a self-operating dining hall or uses an outside service, it should have processes in place to learn about students’ food allergies. This process usually starts with a medical form that resides in the nurse’s office. Because of privacy laws around health issues, “schools need to make sure their health form has a caveat letting people know that if there’s a food allergy, the information will be shared with the dining staff,” says Beth Winthrop, national director of wellness for Sodexo Universities, which offers independent school dining services.
According to the CDC, these eight foods or food groups account for 90 percent of serious allergic reactions. Federal law requires that food labels in the United States clearly identify these allergens—or proteins derived from these allergens—that might be present in any food or in any ingredient.
Communication plays a major role in nailing down the process of providing students with healthy, safe meals. There is parental involvement at every grade level. “Our parents talk to the health center and to the resident director in the dorm, for example,” says Lee Willhite, food service director at Culver Academy, a co-ed boarding school in Culver, Indiana, whose dining hall is self-operated. “Parents communicate with [my office] and with the chef and we find out what [the child] can and can’t have.”
Students themselves should be involved, especially older students who will soon be making their own choices. “You have to have an open and honest conversation with students who have food sensitivities,” says Kelly Massett, food service director at St. Andrew’s School (Middletown, Delaware), a co-ed 9–12 boarding school that uses SAGE to run its kitchen. “We have students talk with the nurse and talk with us to learn how things are prepared and what they can eat. This is their home away from home, and the kitchen is their home kitchen.”
In some cases it would be easy enough to prepare a gluten-free meal or allow a child to order out, for instance, but learning about nutrition and what to eat is a life skill, says Rodriguez. “It’s an interactive process. It’s a school’s job and our job [at SAGE] on behalf of the schools to help teach kids how to eat. We make sure enough information is in the hands of the kids and the parents to allow them to safely navigate this.”
Because of the ADA ruling, independent schools are obligated to make “reasonable” accommodations to those unable to benefit from programs because of disabilities. But not all food allergies are the same. “The ones covered by this new ruling are the really severe ones,” Rodriguez says.
While a peanut allergy can be life-threatening, someone with celiac disease may get physically ill but will not die on the spot. Celiac, too, is covered under the ruling, which states, “celiac disease is an autoimmune disorder that affects the major life activity of eating and the major bodily functions of the immune, digestive, bowel, and neurological systems.” In other words, having celiac disease doesn’t allow a person to enjoy the same food options others do without compromising their own health.
Schools need to have a plan if a student has an allergic reaction. An epinephrine autoinjector, most commonly known by brand name EpiPen, should be stocked at every school, says Cathy Owens, RN, coordinator of health services for Murrieta Valley Unified School District in Murrieta, California. “Epinephrine is for a breach. The best laid plans don’t always work,” she says.
Yet, according to Food Allergy Research & Education (FARE), only 10 states require schools to have EpiPens on hand. New Hampshire has pending legislation, and the rest have guidelines “allowing” but not requiring schools to stock them. Owens doesn’t think that’s good enough. She worked closely with state legislators to get a bill passed in California stating that school districts must provide epinephrine autoinjectors during school hours. “It’s not required for private schools, but they should consider adopting the program,” Owens says.
Cost should not be a factor. Mylan, which produces the EpiPen, has a free EpiPen program for public and private schools if they have an order written by physicians. Unfortunately, “in some states physicians had difficulty with the idea of signing a prescription” because of liability issues, says Owens who also worked on a bill in California that provides indemnification for physicians.
A second roadblock is the fear among some educators about training unlicensed personnel to make medical diagnoses. Yet people are trained all the time to do CPR, Owen argues. Epinephrine (adrenaline) in an autoinjector is low dose, she says. “It may cause someone’s heart to race a little bit, but it wouldn’t harm someone who had difficulty breathing for whatever the reason. The fear that we may harm the person has been researched and reviewed and statistically proven incorrect. When in doubt give epinephrine. It saves lives.”
What are “reasonable” accommodations? They can be as simple as allowing a student to opt out of the meal plan—obviously not possible in a boarding school. Moreover, the dining hall is part of any school’s experience, and schools want both to take care of students’ nutritional needs and to ensure students don’t feel excluded. Although some of the dozen schools interviewed for this article are peanut-free, most are not, and none segregate students who have food allergies.
Depending on the size of their kitchen and dining spaces, some schools are responding with gluten-free pantries and cooking areas. Many offer gluten-free, lactose-free, vegan and vegetarian menu options. A lot of meals are prepared from scratch with a constant eye on ingredients.
“Safety is our number-one concern,” says Sodexo’s Winthrop. “It starts with how the dining hall receives food to make sure there’s no cross contact—for example, a nut product doesn’t leak onto something else. We’re careful in how we store it, prepare it and how we serve it. We keep all the implements separate.”
At The Harley School, a 527-student nursery through 12th-grade day school in Rochester, New York, Vicki Pasternak, food services director, offers a gluten-free option daily. She prepares it before making other foods, and dons gloves and cleans the prep area. “Nothing else gets touched other than what I’m handling right then and there,” she says.
Peter Walker, general manager of dining at the Walnut Hill School for the Arts in Natick, Massachusetts, has “‘the zone’—a place to house the gluten-free toaster, microwave and refrigerator that students and faculty can use.”
Pre-packaged foods can be a concern, and everyone has to check food labels often. “You buy a product you know is safe, and then you buy it again seven months later and read the label and see they’ve added something,” Pasternak says.
Schools let students know what’s in their food in a variety of ways. Strong Rock Christian School is a day school in Locust Grove, Georgia, that uses SAGE to serve about 820 students a day. “I have about 20 children and eight to 10 teachers who are gluten free,” says Shelly Lewis, director of food services. “Anyone can go online and see what’s on the menu and all the allergens listed.” Non-interactive iPad tablets in the dining hall show a diagram of the steam table with information on each item, its ingredients and allergens. “I didn’t want a student to leave the dining hall without having any nourishment [available to them] other than vegetables. I look at all eight allergens and try to get a menu that feeds everyone. Now I have children [with gluten-free issues] coming to me saying, ‘I can have pizza?’ To see their smiles is well worth the effort.”
Because Strong Rock uses SAGE, Lewis and everyone associated with the school has access to programs such as an online allergen filter. A person can click on an allergen such as milk and every menu item with milk in it will disappear. “Parents can see what their children can eat that day,” Lewis says. She also uses “the spotlight” system. Each menu item is marked with a colored dot—red, yellow or green. At the dining hall entrance is a poster with the color codes and their meaning: red means hold on, these foods are on the fattier side, fried or made with butter; yellow is slow down, these foods may have more sugar, calories or fats; green is eat all you want of these healthy fruits and vegetables or foods made with no oils or fats.
7.72%Percent of private school students with food allergies.Source: SAGE survey of 206 private schools comprising 133,417 students
25%Of the severe and potentially life-threatening reactions (anaphylaxis) reported at schools happened in children with no previous diagnosis of food allergies.Source: CDC pamphlet
33%Of children with food allergies are bullied.Source: 2011 Journal of Pediatric Studies as reported on FARE website
50%–62%Of fatal or near fatal reactions to food are most often caused by peanuts. Source: CDC pamphlet
Training and education are key at every level, says Susan Cooper, director of wellness for Flik Independent School Dining. To that end, she speaks “in the classroom, with athletes, in the dorms, with little kids and big kids” as well as with school staff and dining hall personnel. There’s a lot of training around purchasing, she adds. Take gluten. “People associate it with wheat, but it’s often found in rye, barley and triticale, and it tends to be found in conventional oats. We train our kitchen managers to understand all the little details and nuances of each disorder. A wheat allergy is different from celiac disease, gluten intolerance or sensitivity.”
Sodexo, Flik and SAGE all offer services, training and support to their client schools. But any school or individual may access FARE, which offers training programs, information about legislation, personal stories, scientific research and videos. ServSafe offers food handler training and certification, and the CDC has a helpful 108-page pamphlet, “Voluntary Guidelines for Managing Food Allergies in Schools and Early Care and Education Programs.”
For nearly 50 years, there was a self-operated dining hall at Dunn School in Los Olivos, California. A few years ago, the rural, co-ed 6–12 boarding and day school set out to create more of a “food program than a cafeteria,” explains Chad Stacy, director of finance. “We wanted to focus on local, sustainable, healthy, whole foods, and, yes, allergies played into that; we were not being good to our vegans, our vegetarians, our gluten-free students and those with peanut allergies,” he says. “We tried it on our own for a year with the dining hall team. We did a lot of scratch cooking and local buying. We hit a lot of road blocks. After a year of fits and starts we decided to outsource [to Flik].”
Cost are a concern for any program, and it might seem that buying and correctly preparing healthy allergen-free foods could raise costs. Yet none of the schools interviewed for this article cited cost as a barrier to change. It’s “mostly about process and not cost,” Rodriguez says. Schools have identified cost-effective ways to accommodate many processes related to preventing cross-contamination, some as small as finding unused corners for storage, rearranging shelves and using rolling carts with gluten-free items. As Robin Reynolds, chef manager at Dunn School, notes, “food costs haven’t changed much, but [the new program focus] has made me and my staff be really creative for the better. We found out how to make vegan dishes taste just as amazing as a dish served with meat.”
Food costs haven’t changed much, but [the new program focus] has made me and my staff be really creative for the better. We found out how to make vegan dishes taste just as amazing as a dish served with meat.
Robin ReynoldsDunn School
Stacy decided to invest in a new physical layout with Flik’s help. Dunn School purchased “a new salad and deli bars and a lot of small wares” through the company, he says. The school also taps into Flik’s on-staff professionals for assistance with allergies and nutrition issues. “It’s hard to have just one person be an on-site food person, an amazing cook, an allergy expert, and work with and teach the kids,” Stacy says. “Flik is able to do that.”
The school has also shifted to making everything in small batches, so, for example, “50 chicken breasts don’t sit out on a steam table until they’re all gone,” Stacy says. The salad bar quadrupled in size, and he says the costs overall are roughly equivalent to the school’s previous program “but it’s a higher level of service and quality.” The capital improvements were built into the annual operating budget. Plus, he adds, “one of the hidden costs of a self-operated dining hall is unemployment and workers' comp benefits. When you offload it to another company they take on those benefits. We can keep that money off our books and it’s a huge savings.”
At Culver Academy, overall food services costs including labor and food have increased about 25 percent, says Willhite. About 100 of Culver’s 810 students have food allergies, 25 to 30 of them severe, and 51 dining hall employees prepare 25,000 meals a week. Willhite had new shelving built for gluten-free products and is investigating a gluten-free serving line. “The healthier foods—organic fruits, gluten-free breads, different produce, different chicken items, tapioca and potato flours—all that is costly.”
There’s no question that every independent school has to develop a process for handling food allergies in their dining halls. But as each school is unique, so too will be their solution. “Once you have a process that’s inclusive you can be more gracious and make everyone feel welcome,” Rodriguez says. “It’s not a cost issue; it’s a process issue. Through an interactive process you can make everyone happy.”
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