Arkansas Department of Education Smart Snacks Regulations and Second Trays

Memo Information

Memo Number
FIN-15-078
Memo Date
2/17/2015
Memo Type
Regulatory
Section
Fiscal & Administrative Services
Regulatory Authority
§7 CFR 210:11, USDA Policy Memos SP23-2014 and SP35-2014
Response Required
NO
Attention
Co-op Directors; Elementary Principals; Middle School Principals; High School Principals; Superintendents; Child Nutrition Directors

Contact Information

Memo Text

The purpose of this memo is to explain the relationship between the United States Department of Agriculture (USDA)’s Smart Snacks Regulations and Second Trays.  The Arkansas Child Nutrition Unit (CNU) wants to clarify that if second trays are served in any form, each item on the tray MUST meet Smart Snacks Regulations and Arkansas Nutrition Standards / Maximum Portion Size List.  For the purpose of this memo, “second trays” can refer to multiple forms of a reimbursable tray served as a second meal: whole trays as a la carte, entrée only as a la carte, or entrée and/or side items as a la carte. Reminders:Second trays are not reimbursable.Second trays are a la carte / competitive foods. Competitive foods MUST meet Smart Snacks Regulations.  Per USDA regulations, “Competitive food means all food and beverages other than meals reimbursed under programs authorized by the Richard B. Russell National School Lunch Act and the Child Nutrition Act of 1966 available for sale to students on the School campus during the School day.”  A second tray that meets meal pattern for breakfast or lunch will not necessarily meet Smart Snacks Regulations.  Each item on a second tray must be considered individually for comparison to the Smart Snacks Regulations and the Arkansas Nutrition Standards/Maximum Portion Size List.   Entrees of Second Meals Entrees that have been served as part of the National School Lunch Program (NSLP) or School Breakfast Program (SBP) reimbursable meal are exempt from the Smart Snacks requirements on the day of service in the NSLP and SBP, as well as the day after such an entrée is served in the NSLP or SBP as part of the reimbursable meal, whether as leftovers or simply cooked again on the second day (see USDA SP23-2014 Q&A Related to the “Smart Snacks” Interim Final Rule page 5 (2)).  On the third day, the entrée must meet Smart Snacks Regulations. Entrées are defined as an item that includes only the following three categories of main dish food items: A combination food of meat or meat alternate and whole grain rich bread; orA combination food of vegetable or fruit and meat or meat alternate; orA meat or meat alternate alone, with the exception of yogurt, low-fat or reduced fat cheese, nuts, seeds and nut or seed butters. For the SBP, schools may determine their entrée items. Side Items of Second Meals Side items (any item other than the entrée) on second trays have no exemptions and must meet Smart Snacks Regulations and Arkansas Nutrition Standards on each day served.  Please refer to Commissioner’s Memo FIN-14-080.  The Arkansas Maximum Portion Size Chart for SY2014-15 is attached below. How can my cafeteria sell WHOLE second trays? Entrée item must be evaluated.   Is it being served on the day of service in a reimbursable meal or the day after service?  If yes, the entrée is exempt from Smart Snacks Regulations.If no, the entrée must meet Smart Snacks Regulations (See attached flow chart and/or the Alliance Calculator) Side items must be evaluated. Must meet both Smart Snack Regulations (See attached flow chart and/or Alliance Calculator) and AR Nutrition Standards / Maximum Portion Size List (see attached list for SY 2014-15) everyday they are part of a second tray. How can my cafeteria sell only the entrée of a second tray?   Entrée item must be evaluated. Is it being served on the day of service in a reimbursable meal or the day after service?  If yes, the entrée is exempt from Smart Snacks Regulations.If no, the entrée must meet Smart Snacks Regulations (See attached flow chart and/or Alliance Calculator) How can my cafeteria sell the entrée and the side items of a second tray as individual items for a la carte? Entrée item must be evaluated.   Is it being served on the day of service in a reimbursable meal or the day after service?  If yes, the entrée is exempt from Smart Snacks Regulations.If no, the entrée must meet Smart Snacks Regulations (See attached flow chart and/or Alliance Calculator) Side items must be evaluated. Must meet both Smart Snack Regulations (see attached flow chart and/or Alliance Calculator) and AR Nutrition Standards / Maximum Portion Size List (see attached list for SY 2014-15) everyday they are part of a second tray. Example On Tuesday, chicken strips were served as the entrée of a reimbursable lunch.   Therefore, the chicken strips could be sold as a second meal (any form) on Tuesday or Wednesday without further documentation.  If chicken strips were served as a second meal on Thursday, they would have to meet Smart Snack requirements.  Any side dishes served with the chicken strips would require documentation that they meet Smart Snack Regulations and Arkansas Nutrition Standards on any day they are sold as part of a second tray (any form). Resources The nutrition standards and nutrient requirements for entrées and side dishes are outlined on the attached “Understanding Second Trays Flowchart.”  The attached USDA “Smart Snacks in School” handout and USDA’s “Smart Snacks in School Nutrition Standards Interim Final Rule Questions and Answers” are also helpful. The Alliance for a Healthier Generation Product Calculator may be used to determine whether entrées and side items on a second tray meet Smart Snacks requirements. https://schools.healthiergeneration.org/focus_areas/snacks_and_beverages/smart_snacks/alliance_product_calculator/   Additionally, Commissioner’s Memo FIN-14-080 addressing Maximum Portion Size and All Foods on Campus Rules for 2014-15 School Year has been attached.   Summary Second trays (including each item on the tray) must be treated as though they are an a la carte item; and, therefore, must meet all federal and state standards just as Arkansas Child Nutrition Programs have been approaching any snack item being sold in addition to reimbursable trays for many years now. Second Trays = a la Carte = Smart Snacks and Arkansas Nutrition Standards   If you have questions or concerns, contact your Area Specialist or Stephanie Alsbrook at Stephanie.alsbrook@arkansas.gov or (501) 324-9502.