Food Allergies in School and Designing 504 Plans

In the legal terminology, food allergies are an extremely serious condition because they can cause the “impairment of major life activities.” A food allergy may affect a student’s ability to eat, care for themselves, or breathe. This serious backdrop is why schools develop a 504 plan in collaboration with an affected parent and child. A comprehensive 504 plan should detail a student’s medical needs and condition, as well as the precautions that the school is taking in accordance with that condition. It of course also includes a plan of action if a student suffers an allergic incident at any point while in the school's care.

Each 504 plan is individualized and unique to each student’s particular experience. Depending on the student, a 504 plan might be 2 pages or it might be 20 pages. While not all accommodations will be necessary for every student, below are some general areas of concern that schools can use as a starting place in designing an effective plan. 

• Communications: For the purposes of protecting individual students, teachers might send regular emails that note any upcoming lesson plans that involve potential allergens (field trips, science experiments, art projects, etc.) It’s also important to set this expectation clearly with affected students - if you feel unwell, let a staff member know immediately, even if you need to interrupt. Broadly speaking, it is also important to communicate to all families and staff school policies regarding allergens on campus, and the seriousness of adhering to them. 
• Classroom Precautions: Obviously, there needs to be a plan in place for protecting a student while in class. Among other things, this should mean that allergens are avoided in classroom activities, snacks and other food are stored properly to avoid cross-contamination, and research is done to ensure that all classroom materials (including non-food substances) do not contain relevant allergens. This process should involve collaboration with the student’s guardian on areas of potential concern or alternative options for materials. Depending on the severity of the allergy, it may be necessary to avoid hosting outside events in a particular classroom. 
• Food and Beverage in the Classroom: Start simple. If a student is allergic to a particular food, their 504 plan should ensure that none of that food is consumed at any point in their classroom(s). It is general best practice to avoid “reward” foods (and instead to use stickers or other alternatives). If it does happen, any food eaten in the classroom must be checked for the allergen. One potential strategy is to ask the student’s parents to provide a list of acceptable snacks or foods. 
• Cafeteria/Lunchroom Planning: Establish an allergen-free table for the student, where only those with cleared allergen-free foods may sit. A copy of the student’s 504 plan and “safe” cafeteria menu items should be accessible to lunchroom staff. Precautions should be taken with cross-contamination. Staff should use fresh gloves when serving the student, and inform the family immediately if there are changes in food service provider or listed menu items. 
• Celebrations: If possible, a good community-wide shift to institute is minimizing the role of food in birthday/holiday/celebration parties. Things like birthday cake are okay, but should be eaten in the lunchroom with proper precautions, not brought into the classroom. If food is brought into the classroom, it must be cleared of relevant allergens. The affected student’s parent may help with alternative treats or advance planning. 
• Cleaning: All surfaces of an affected classroom should be cleaned with an approved cleaning agent and fresh/disposable rag to avoid cross-contamination. If the classroom is unavoidably used for outside purposes, it must be cleaned before the student re-enters. A student’s regular chair/desk should be cleaned daily. 
• Transportation and Field Trips: All bus drivers should be trained on how to recognize an allergic reaction as well as how to use an EpiPen. Food should not be allowed on the student’s bus, unless another student has a necessary medical need. The bus and seats will be regularly cleaned, and whenever possible, the student will sit close to the front of the bus/with another student who understands the allergy. For field trips, a good 504 plan contains protocols to notify the student’s guardian of an upcoming field trip with appropriate notice. The parent should be allowed to attend the field trip if they choose, and a trained staff member should carry epinephrine or other medications. The student should remain close to a trained individual throughout the trip.
• Emergency Planning: Of course, the 504 plan must take into account emergency scenarios, whether they affect only the student or the community as a whole. The student’s EpiPens should be unlocked at all times and accessible in different areas. One set should remain with the individual who handles campus health concerns, along with a copy of the 504 plan. The student’s teacher(s) should have access to EpiPens in an emergency bag whenever they are responsible for the student. If physician approved (and the student is judged to be mature enough), the student may carry around their own EpiPens in a personal emergency bag. For lockdown or “shelter-in-place” scenarios, the student’s guardians should provide an “Emergency Safe Foods” box or list of acceptable foods for their student. 
• Student’s Responsibility: As alluded to in the previous section, the 504 plan may take into account responsibilities entrusted to the student themselves. For example, they should feel confident notifying teachers if they see others with allergens or suspect a reaction is occurring. They may also carry around medications themselves. 

These examples are not comprehensive. A sample 504 action plan can be downloaded here.  This particular document utilizes an easy-to-follow design that can walk readers through important information about allergens, symptoms, and treatment instructions (even during times of high stress, like an anaphylactic emergency). 

If you'd like insight on an individual situation your school is dealing with, please contact us at "safety@joffeemergencyservices.com". We love talking about school safety!