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Clarification Regarding the Use of Sharing Tables

Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information

To: School Nutrition Program Sponsors

Number: NSD-SNP-05-2008

Attention: Food Service Directors

Date: September 2008

Subject: Clarification Regarding the Use of "Sharing Tables" and Recycled Milk in School Nutrition Programs

Reference: California Health and Safety Code, Part 7; California Retail Food Code, sections 113739, 113756, 113757, 113781, 113789, 113871, 113897, 113996, 114000, and 114079; United States Department of Agriculture, Food and Nutrition Service Instruction 786-6.

This Management Bulletin (MB) provides new information and clarifies existing guidance regarding the use of "sharing tables" and the re-service/recycling of food and beverages in the National School Lunch and School Breakfast Programs.

"Sharing Tables" and Recycled Milk

In an effort to reduce the amount of food waste and encourage the consumption of food served, many school food service operations have established "sharing tables." Sharing tables are carts and/or tables where children can place unconsumed food and beverage items (pre-packaged food and beverages, unopened wrapped food and beverages, or food items with a peel) that they choose not to eat/drink. These tables provide an opportunity for other children to take additional helpings of food or beverages at no cost to them. In many instances, food and beverage items, especially unopened milk, have been reused by food service operations as part of a reimbursable meal, served a la carte, and/or used in cooking.

While the United States Department of Agriculture (USDA) guidance has permitted the use of both sharing tables and the recycling of food and beverages, including milk, State food safety laws are more restrictive; therefore, this practice is only acceptable when in compliance with applicable State and local health codes.

The following regulations are set forth by the California Retail Food Code (CalCode) as it pertains to both sharing tables and the recycling of food and beverages:

Please note that the definitions/terms used in this MB are outlined in CalCode, which is available for viewing at:

In CalCode Section 114079, the use of sharing tables is permitted only if all of the following conditions are met:

  1. No food or beverage may ever be returned to the food preparation, food service, or food storage areas for use by the food service operation or for any human consumption, except those items permitted in CalCode Section 114079(b).
  2. Potentially hazardous foods or beverages [as defined in CalCode Section 113871] on the sharing table are consumed or discarded within four hours of the food or beverage entering the temperature danger zone (41oF to 135oF).
  3. The sharing table is supervised by a member of the food service staff to ensure that no food, beverage, or condiment has been contaminated (e.g., opened, partially consumed, etc.) and the original packaging is maintained in sound condition.

Under no circumstances may any potentially hazardous food or beverage served or sold to a consumer be re-used or recycled by the food service operation for human consumption, even if temperature guidelines are maintained and the food or beverage container has been sanitized, (e.g., unopened milk containers on the sharing table that are placed in ice during the meal period and are wiped down at the end of the meal period with a clean towel and sanitizer solution may still not be re-used or recycled).

Best Practices for National School Lunch and School Breakfast Programs
  • Offer vs. Serve
    Food service operations with increased food costs (related to the amount of waste, and the amount of food discarded from sharing tables), may want to consider implementing Offer vs. Serve (OVS). OVS is a provision with two major goals: to (1) reduce food/plate waste in School Nutrition Programs, and (2) permit students to select only the foods they want to consume. Depending upon the agency/district’s menu planning option, OVS allows students to decline one or two food or menu items in the school meal at lunch (or one food or menu items at breakfast), and allows the sponsor to claim the meal for reimbursement. As stated earlier, implementing OVS is intended to decrease the amount of food/beverage waste; therefore, less food will end up on sharing tables or in the garbage. While OVS is required for lunch at the high school level, it is optional for all other grade levels.
  • Placement of Sharing Tables
    Placement of the sharing table at the end of a serving line (rather than further out in a cafeteria, for instance) can improve the supervision of the sharing table by foodservice staff, therefore ensuring that food contamination is reduced or eliminated.
  • Institute a No-Sharing Table Policy
    Many school foodservice operations have chosen to institute a no-sharing table policy eliminating all possible health concerns and other issues surrounding contamination or other questionable issues of sharing tables.
  • Handling Non-Potentially Hazardous Foods Left on the Sharing Table
    Non-potentially hazardous foods such as pre-packaged crackers/graham crackers, bowl pack cereals, and condiment packets, that are maintained in their original packaging, and are free from contamination may be re-used by the foodservice operation if they ensure that the sharing table is supervised by the foodservice staff. If the above requirements cannot be guaranteed, many school foodservice operations choose to leave these food items on the sharing table and have them available for students as additional snacks, which are not considered to be part of the reimbursable meal.
  • Residential Child Care Institutions (RCCIs) and/or Schools or Agencies Serving “Family Style” Meals
    RCCIs generally serve meals “family style,” where all food and menu items are placed on the table where students are eating, and students are allowed to serve themselves second helpings of food/menu items. When “family style” meals are served all food items on the table must be discarded at the end of the meal service and not re-served as part of another reimbursable meal.

To assist local enforcement agencies with routine food safety inspections, the California Department of Education’s Nutrition Services Division (NSD) strongly recommends that districts/agencies include the guidelines for sharing tables in their food service operation’s Hazard Analysis Critical Control Points (or “HACCP”) plan as well as provide proper food safety and food handling training to employees. Although CalCode regulations apply Statewide, certain counties may have instituted stricter regulations banning the use of sharing tables. The NSD also recommends that your district/agency discuss these issues with your local enforcement agency (health inspectors).

If you have any questions regarding this MB, please contact Ashley Osterman, Child Nutrition Consultant, School Nutrition Programs (SNP), at 916-445-1261 or by e-mail at, or Lori Porter, Child Nutrition Consultant, SNP, at 916-323-4100 or by e-mail at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Monday, June 27, 2016
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