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Please provide clarification on CAC Title 5 15500 and 15501.

Question:  I need to get some clarification on CAC Title 5 15500 and 15501.

My interpretation is that the soda sales at lunch time and donut sales before school are not permitted. The soda sales are done every day and the donut sales are every Friday.  This is at a school that is kindergarten to 8th grade. But they are not sharing bell schedules so kindergarten through 4th grade is not interacting with 5th grade to 8th grade.

Response:  You are correct that due to the Code of Federal Regulations, there is a new restriction that no food of minimal value can be served during a meal period and/or where meals are served or eaten.  Candy, ices and soda are examples of "food of minimal nutritional value" that are being referred to here. As you state, this means that soda and donuts are not allowable based on this federal rule if they are served during meal time.

Where you do have SOME flexibility is how many food sales you can do if you are elementary or secondary.  Since you have a K-8 school, elementary rules apply unless elementary and secondary are truly served food at different times.

Elementary schools can only hold food sales if:

· Nutrition requirements are met

o Less than 35% fat

o Less than 10% saturated fat

o Less than 35% sugar

o Water, milk and 100% fruit juice only (if cafeteria program not serving that day)

· After lunch is over

· There is no competition with the cafeteria program

· Food is not prepared on premises

· One food item only is sold

· Four times annually

Middle schools can only hold food sales, during the school day, if:

· Four annual sales for all groups

· One group can hold daily sales, up to three food types

· No soda/sugar drinks

· There is no competition with the cafeteria program

· Food is not prepared on premises

· Beverages sold during the school day have to be fruit based (50%, no sweetener), water, milk or electrolyte beverage (if not sold by cafeteria program)

11/21/05

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