1 I USDA Fp9d Distribution ,'Nf,(ional r,licy Memorandum <. United States Department of DATE: June 9, 2010 Agriculture POLICY NO.: FD-I07: National School Lunch Program (NSLP), Child and " Food and Adult Care Food Program (CACFP), Summer Food Service Nutrition Program (SFSP), Commodity Supplemental Food Program Service (CSFP), Food Distribution Program on Indian Reservations 3101 Park ,(FDPIR), the Emergency Food Assistance Program (TEFAP), Center Drive and, Charitable Institutions Alexandria, VA 22302..1500 SUBJECT: Storage and Inventory Management ofUSDA Donated Foods, In accordance with 7 CFR 250.14(b), State distributing agencies and recipient agencies , must ensure that foods donated by the Department ofAgriculture (i.e., USDA donated foods) are stored in a manner to protect them from spoilage, infestation, damage, or otherconditionthatmayjeopardizethewholesomeness arsafetyofthefoods. USDA donated foods must be maintained in sanitary conditions, at the proper temperature and humidity, and with adequate air circulation. In addition to proper storage practices, , effective inventory management is necessary to ensure that USDA donated foods are distributed in a timely manner, and in optimal condition. As a general rule, distributing and recipient agencies should llSea fIrst-in-fust-out (FIFO) system ofinventory management. In order to implement FIFO, USDA donated ,. food cases or other containers should be marked with.the date oftheir receipt at the storage facility. However, distributing and recipient agencies should also be aware of dates placed on food products by the manufacturers that help to determine how long food products can be expeCted to remain in optimal condition. Such product dates must be considered, along with FIFO, in management ofdonated food inventories. Because different product dates have different meanings, it is important to know which product date is used and to understand what it means. It is also important to understand ,,' that, except for expiration dates, product dates do not necessarily indicate when foods are no longer safe to consume.' The following paragraphs describe the meaning of some product dates that may be found on USDA donated foods. Expiration and Use-by Dates Generally, "expiration" dates and "use-by" dates are the last dates that the manufacturer recommends a food itembe consumed to ensure peak: quality and nutrient retention. .However, thereis no regulation requiring that manufacturers mark their product with such dates. The one exception to these general rules is infant formula. The Food and Dru~ AN EQUAL OPPORTUNITY EMPLOYER AND PROVIDER (FoodDistribution Web site: www.fns.usda.gov/fdd) '" Policy Memorandum No. FD-107 Page 2 Administration (FDA) requires manufacturers mark infant formula with a '"use-by" date. Additionally, the FDA prohibits the sale ofinfant formula after the use-by date. In accordance with FDA rules, infant formula that is past its use-by date must not be distributed to program recipients. Similarly, per manufacturer recommendations regarding other foods, other USDA donated food that is past its expiration date or its use.,by date must not be distributed to program recipients. Accordingly, distributing and recipient agencies must manage their inventories to ensure that program recipients have an opportunity to consume all USDA donated foods (i.e., infant formula and other foods) before their expiration dates or use-by dates have passed. Best-if-used-by Dates A "best-if-used-by" date is the last date a food item will be at its peak, in terms of flavor and quality. At some point after that date, the product will begin to undergo changes in taste, color, texture, and/or nutrient content. However, the product may be wholesome and safe to consume, and retain most ofits nutrient value, long after the "best-if-used-by" date. Nevertheless, distributing and recipient agencies must consider "best-if-used-by" dates in managing their USDA donated food inventories, and ' distribute USDA donated foods in a manner that allows them to be consumed by such date. Sell-by Dates and Pack Dates . A "sell-by" date is the date by which the manufacturer recommends that a store sell the food product, and is not necessarily a reliabie indicator ofhow long it may retain its wholesomeness or nutritional value. A "pack date" indicates when the product was packaged or processed. While it may help to determine the age ofthe product, it does not necessarily provide useful information on its wholesomeness or nutritional value. Food Safety USDA donated foods that show signs ofspoilage, infestation, or other visible defects shouldnotbe used ordistributed, regardless ofproduct dates orwhenthe foods were received, as such food is generally considered not fit for human consumption. Ifthere are no visible defects; but there is a question as to the wholesomeness or safety of USDA donated foods, the distributing or recipient agency must have the foods inspected by State or local health authorities as soon as possible, and must contact FNS before taking further action. Single Inventory Management School food authorities, other recipient agencies in child nutrition programs, and charitable institutions may use single inventory management, in which USDA donated foods are stored and inventoried together with purchased foods or other foods. In such Policy Memorandum No. FD-I07 Page 3 case, USDA donated foods are subject to the same safeguards and effective management practices as other foods, and must be treated as other foods when safety is in question. Consequently, such recipient agencies must comply with State or local laws or regulations in determining the safety offoods (including USDA donated foods). ~ Cathie McCullough Director Food Distribution Division