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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, as outlined in CalCode are included on the last pages of this document. The entire CalCode is located at the following Web site:

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).

The following CalCode Section defines the Re-service of Food and Beverages:

114079. Returned food and reservice of food

  1. Except as specified in subdivision (b) [BELOW], after being served or sold and in the possession of a CONSUMER, FOOD that is unused or returned by the CONSUMER shall not be offered as FOOD for human consumption.
  2. A container of FOOD that is not potentially HAZARDous may be transferred from one CONSUMER to another if the FOOD is dispensed so that it is protected from contamination and the container is closed between uses, such as a narrow-neck bottle containing catsup, steak sauce, or wine, or if the FOOD such as crackers, salt, or pepper, is in an unopened original package and is maintained in sound condition, and if the FOOD is checked periodically on a regular basis.
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

Referenced CalCode Definitions and Provisions

Excerpts from the California Retail Food Code:

  1. "Beverage" means a liquid for drinking, including water.
  2. "Condiment" means a nonpotentially hazardous food, such as relishes, spices, sauces, confections, or seasonings, that requires no additional preparation, and that is used on a food item, including, but not limited to, ketchup, mustard, mayonnaise, sauerkraut, salsa, salt, sugar, pepper, or chile peppers.
  3. "Consumer" means a person who is a member of the public, takes possession of food, is not functioning in the capacity of an operator of a food facility, and does not offer the food for resale.
  4. "Food" means a raw, cooked, or processed edible substance, ice, beverage, an ingredient used or intended for use or for sale in whole or in part for human consumption, and chewing gum.
  5. Food Facility
    1. "Food facility" means an operation that stores, prepares, packages, serves, vends, or otherwise provides food for human consumption at the retail level, including, but not limited to, the following:
      1. An operation where food is consumed on or off the premises, regardless of whether there is a charge for the food.
      2. Any place used in conjunction with the operations described in this subdivision, including, but not limited to, storage facilities for food-related utensils, equipment, and materials.
    2. "Food facility" includes permanent and nonpermanent food facilities, including, but not limited to, the following:
      1. Public and private school cafeterias.
      2. Restricted food service facilities.
      3. Licensed health care facilities.
      4. Commissaries.
      5. Mobile food facilities.
      6. Mobile support units.
      7. Temporary food facilities.
      8. Vending machines.
      9. Certified farmers' markets, for purposes of permitting and enforcement.
    3. "Food facility" does not include any of the following:
      1. A cooperative arrangement wherein no permanent facilities are used for storing or handling food.
      2. A private home.
      3. A church, private club, or other nonprofit association that gives or sells food to its members and guests, and not to the general public, at an event that occurs not more than three days in any 90-day period.
      4. A for-profit entity that gives or sells food at an event that occurs not more than three days in a 90-day period for the benefit of a nonprofit association, if the for-profit entity receives no monetary benefit, other than that resulting from recognition from participating in an event.
      5. Premises set aside for wine tasting, as that term is used in Section 23356.1 of the Business and Professions Code and in the regulations adopted pursuant to that section, if no food or beverage is offered for sale for onsite consumption.
      6. Premises operated by a producer, selling or offering for sale only whole produce grown by  the producer, or shell eggs, or both, provided the sales are conducted on premises controlled by the producer.
      7. A commercial food processing plant as defined in Section 111955
  6. Potentially Hazardous Food
    1. "Potentially hazardous food" means a food that is natural or synthetic and that requires temperature control because it is in a form capable of supporting the rapid and progressive growth of infectious or toxigenic micro-organisms, the growth and toxin production of Clostridium botulinum, or, in raw shell eggs, the growth of salmonella enteritidis.
    2. "Potentially hazardous food" includes a food of animal origin that is raw or heat-treated, a food of plant origin that is heat-treated or consists of raw seed sprouts, cut melons, and garlic-in-oil mixtures that are not acidified or otherwise modified at a food processing plant in a way that results in mixtures that do not support growth as specified under subdivision (a).
    3. "Potentially hazardous food" does not include any of the following:
      1. A food with an aw value of 0.85 or less.
      2. A food with a pH level of 4.6 or below when measured at 75oF.
      3. A shell egg that is not hard-boiled but has been treated to destroy all viable salmonellae.
      4. A food in an unopened, hermetically sealed container that is commercially processed to achieve and maintain commercial sterility under conditions of nonrefrigerated storage and distribution.
      5. A food that has been shown by appropriate microbial challenge studies approved by the enforcement agency not to support the rapid and progressive growth of infectious or toxigenic micro-organisms that may cause food infections or food intoxications, or the growth and toxin production of Clostridium botulinum, such as a food that has an aw  and a pH that are above the levels specified under paragraphs (1) and (2) and that may contain a preservative, other barrier to the growth of micro-organisms, or a combination of barriers that inhibit the growth of micro-organisms.
      6. A food that does not support the rapid and progressive growth of infectious or toxigenic micro-organisms, even though the food may contain an infectious or toxigenic micro-organism or chemical or physical contaminant at a level sufficient to cause illness.
  7. "Sanitization" means the application of cumulative heat or chemicals on cleaned food-contact surfaces that, when evaluated for efficacy, is sufficient to yield a reduction of five logs, which is equal to a 99.999 percent reduction, of representative disease micro-organisms of public health importance.
  8. Hot and Cold Holding Potentially Hazardous Food
    1. Except during preparation, cooking, cooling, transportation to or from a retail food facility for a period of less than 30 minutes, or when time is used as the public health control as specified under Section 114000, or as otherwise provided in this section, potentially hazardous food shall be maintained at or above 135oF, or at or below 41oF.
    2. Roasts cooked to a temperature and for a time specified in subdivision (b) of Section 114004 may be held at a temperature of 130oF.
    3. The following foods may be held at or below 45oF:
      1. Raw shell eggs.
      2. Unshucked live molluscan shellfish.
      3. Pasteurized milk and pasteurized milk products in original, sealed containers.
      4. Potentially hazardous foods held for dispensing in serving lines and salad bars during periods not to exceed 12 hours in any 24-hour period or held in vending machines. For purposes of this subdivision, a display case shall not be deemed to be a serving line.
      5. Potentially hazardous foods held for sampling at a certified farmers' market.
      6. Potentially hazardous foods held during transportation.
  9. Time as a Public Health Control
    1. Except as specified in subdivision (b), if time only, rather than time in conjunction with temperature, is used as the public health control for a working supply of potentially hazardous food before cooking or for ready-to-eat potentially hazardous food that is displayed or held for service for immediate consumption, the following shall occur:
      1. The food shall be marked or otherwise identified to indicate the time that is four hours past the point in time when the food is removed from temperature control.
      2. The food shall be cooked and served, served if ready-to-eat, or discarded within four hours from the point in time when the food is removed from temperature control.
      3. The food in unmarked containers or packages or marked to exceed a four-hour limit shall be discarded.
      4. Written procedures shall be maintained in the food facility and made available to the enforcement agency upon request, that ensure compliance with this section and Section 114002, for food that is prepared, cooked, and refrigerated before time is used as a public health control.
    2. Time only, rather than time in conjunction with temperature, may not be used as the public health control for raw eggs in the following food facilities:
      1. Licensed health care facilities.
      2. Public and private school cafeterias
Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Monday, August 3, 2015

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