Documentation Requirements
Maryann Durrant (USBE):
Now that you’re familiar with what a CN label and Product Formulation Statement is, we’ll go over what documentation you need to have on hand when you are serving the products. Keep in mind that if you are serving a product that needs a CN label, it cannot be credited unless you have the documentation. An assumption that we see people make is that if they only credit one component of the item, they wouldn’t need a CN label. An example of this would be if a center served chicken nuggets, but didn’t have a CN label for them, they might assume that since they know there is meat in the product, they’ll credit the chicken nuggets as the meat/meat alternate and serve some bread along with it to fulfill the grain requirement. Unfortunately, that is not in compliance with the regulations. You also can’t remove the breading and weigh the breading and meat portion and count that as your crediting. With these products, there could be fillers and binders added that would affect the overall grain/protein content of the product so a weight of the product wouldn’t give an accurate picture as to what is really in the product.
The ideal situation regarding documentation of CN labels is that any product you’re serving that would require a CN label has the CN label on it. In this case, during a review, we would look in your freezer, note that you’re serving a product that has a CN label on the box and that would be it.
The next best option would be to have a copy or photograph of the original CN label on the package. An example of this would be if you purchased a box of chicken nuggets with a CN label, but if won’t fit in your freezer, so you take the bag of chicken nuggets out of the box and you recycle the box. Before you recycled the box, you would take a picture of the CN label and keep that on hand. You do need to make sure that the CN label that you have a picture of is for the exact product that you’re serving. You couldn’t use the picture of a CN label for one brand of fish sticks and then serve all different brands of fish sticks. You also can’t take a picture of a CN label on one product that you purchased and assume that the product will always stay the same. Make sure to check every time you purchase the product. If you’ve been purchasing a specific product that has a CN label, and the next time you go to purchase it, it doesn’t have a CN label, contact the manufacturer. If the product hasn’t changed, they just took the CN label off the packaging, you could still use the picture of the CN label that you’ve had on hand. If it has changed, the picture of that CN label will not be sufficient.
Another option for CN label documentation is the USDA CN Label List. This list has all of the current CN labeled products. There is a link to this list on the Canvas. If on a review we ask to see CN label documentation, you would be able to pull up this list, locate the product you’re using, and as long as we can verify that the product on the list is the same product that you’re serving, then you would have all of the documentation you need. You can also use this list if you’re looking to serve a CN labeled product. You’d be able to use the report to determine which products are CN labeled and then look for that product in the store.
The last option for documentation that would be acceptable for serving a CN labeled product would be to obtain the Product Formulation Statement. As we talked about at the beginning of the training, the Product Formulation Statement is not verified by the USDA and is therefore not as reliable as a CN label. You would be responsible for ensuring that the menu items meet the meal pattern requirements. You would need to verify the PFS before serving the product and if the manufacturer changes the product, a new PFS would need to be obtained.
Organizing your CN label information will vary depending on what documentation you’re using. If you’ve got a CN labeled product in your freezer, you would simply open your freezer. If you have a picture of the CN label or a product formulation statement, you’ll want to have a specific folder where they are kept. Again, if you’re using the USDA approved CN label list, you would simply access it on-line.
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