School Garden, Meet Rainwater and Compost…
On Wednesday, January 15, the Arizona Department of Health Services (ADHS) released updates to its school garden program guidelines, which guide how food must be grown in schools in order to be served in the cafeteria. This was a long process of negotiation, and we’re extremely happy with the outcome, as our three areas of concern have all been dealt with:
1. School-made compost now can be used to grow food for the cafeteria;
2. Rainwater now can be used as a source of irrigation water;
3. Non-latex disposable gloves are no longer required for harvesting; just proper hand-washing.
That said, schools will still need to get certified by the state school garden sanitarian and show they are maintaining the compost and rainwater up to the standards specified. You can find more details on the ADHS School Garden page, specifically with the Program Guidelines and the Food & Garden Safety page.
It’s a lot to sift through, so let us break it down for you with some broad generalizations, FAQ style:
What’s all this business about SOP’s and Attestations on the Food & Garden Safety page?
SOPs are standard operating procedures. ADHS has provided sample SOPs for your benefit. They are based on good science, so if you want to copy (and follow!) them word for word, you’ll be in good shape. However, they are not hard and fast rules. You can tweak them a little or make up your own from scratch.
The attestation is, first and foremost, a form you sign to attest that you will actually do what you say you’re doing in the SOP. Someone—ideally an individual closely involved with the garden, or the school principal—needs to sign the form and send it back to ADHS. Unlike the SOP, the rules listed on the attestation ARE hard and fast. If you decide to alter or write your own SOP, you need to make sure it at least follows the parameters set forth in the attestation.
What are the regulations for school-made compost?
School-made compost can now be used, so long as the school follows proper protocols. In a nutshell, this entails getting the pile to a high enough temperature, which happens naturally through microbial processes when the proper ratios of materials are added. For plant-based piles, 131 degrees (F) must be reached for 3 days; 15 days for compost piles with manure in them. These temperatures are easily reachable if you have a large enough pile and are balancing the input materials properly.
There are some other guidelines in there, such as keeping your compost pile a safe distance from flammable structures, since there have in fact been cases of compost spontaneously combusting. Also, washing hands and tools properly after handling compost. Things like that.
What are the regulations for using rainwater?
Rainwater can now be used to grow food for the cafeteria. We had quite a bit of conversation with ADHS about whether the water would need to be tested first. The end result is this: Testing is only required if you’re applying the water directly to the plant such that the edible portion is at risk of being contacted AND your rainwater is coming from a poorly designed and/or maintained system.
Another way of stating that is that if you have a well-designed and maintained system that meets their standards, you’re good to go! Alternatively, regardless of your system’s design, if you’re careful to apply the water directly to the soil (e.g. via drip irrigation), you’re good to go! No testing.
Pretty doable, we think.
What about gloves for harvesting?
Non-latex disposable gloves are no longer required. However, proper hand-washing will be required and as such, you should consider holding a proper hand-washing training with your students. In addition, harvesting equipment will need to be cleaned and sanitized between uses, so use hard plastic or metal containers, rather than, say wicker baskets.
What do we need to do to actually start serving food in the cafeteria?
Probably the biggest hurdle will be getting all your policies together into a central place, and making sure everyone is following them and keeping track of them. Consider making a binder and holding trainings for other teachers and students to cover the essentials.
With the unfortunate but very real danger of litigation in our society, documenting your practices will be essential. You’ll need to keep track of harvest days, trainings, soil history, etc. If you’re using your own compost or rainwater, you’ll need to keep track of temperatures for your compost piles, days when you emptied out the first flush on your cistern system, etc.
Once you have all your ducks in a row, you can contact Kathryn Matthewson at ADHS and request a site visit. Once she inspects your garden and gives you the green light, you’re free and clear.
What about other policies, like that of my local health department of school district?
You should clear your plans with your own district leadership before attempting to bring garden food into the school cafeteria. Following the guidelines put forth by ADHS though will put you in a good position. For example, in working with Tucson Unified School District, they have stated that they will abide by ADHS’s recommendations.
As for your local county health department, ADHS has been in touch with all the counties across the state and is taking care of all the legwork by providing an ADHS sanitarian to do the school garden certifications. Furthermore, the counties cannot make policies that contradict those of the state health department. As such, we feel confident in saying that if you follow ADHS’s guidelines for school gardening, you’ll be in good shape.
Is all this really worth the trouble?
Kids who participate in Farm-to-School programs do better academically on average, have fewer behavior problems, increase their knowledge, and develop healthier eating habits, according to many studies. Making the leap from the garden to the cafeteria helps kids make a difficult connection: that the food they eat both at home and in the cafeteria has the potential to be every bit as awesome as the food they’re so excited to grow in the garden. Cafeteria integration is a key part of Farm-to-School around the country and this new ruling clears the way for Arizona’s schools to make some really good headway.