NEA’s Concerns About Proposed USDA Regulations
NEA applauds the focus on professional development for all levels of food service personnel that is contained in the proposed regulations. This focus recognizes the skills, professionalism, and dedication of our members who meet the needs of the whole student every day. We also are glad that the regulations will apply equally to all food service programs and personnel, whether these programs are directly operated by school districts or run by food service management companies.
However, we have a number of concerns about the details of the proposed regulations. The most significant ones are:
- There must be clear standards to ensure the training is of high quality, relevant to the jobs of the people who are receiving it, and delivered in an appropriate format and language for the recipients. We also believe that on-line training should only be used as a supplement to in-person, hands-on training. It should not be the principal way that training is delivered.
- There must be guarantees that training is provided during paid work time, and at no cost to participants.
- The burden of ensuring that all employees are trained should be on the employer, and food service employees who do not meet the training requirements should be held harmless, unless that training is offered at no cost during regular paid working hours, and they do not have a valid reason for not participating in the training.
These concerns are spelled out in more detail in NEA’s comments, which also make additional points. Model comments from NEA have been made available. If you wish, you can simply insert your own information and submit these comments as your own.