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‘BUY AMERICAN’ REQUIREMENTS is conducted of a sample of supplier invoices or receipts for
compliance. Corrective action will be called for in the case of non-
CONTINUED FROM PAGE 12 compliance.

purchase. “If you want to serve bananas in March and then May, But so far, USDA has taken no scal action against a school
you have to ll out another form – and keep it on le,” she said. found to be in non-compliance, Shelton said.
Monitoring of Buy American is conducted by the Arizona Summing up, she provided answers to key questions. “Do
Department of Education, which sends an annual report on its we have to stop serving bananas, mandarin oranges and using
ndings to the USDA. Under an administrative review, state spices in our food service program?” she said. “De nitely
inspectors will look at labels on a variety of food products in all food not! e USDA permits some exceptions, especially when the
storage facilities. If non-domestic products are found, exception product cannot be produced in su cient quantities and or be
documentations will be reviewed. If not in compliance, corrective reasonably available. However, schools should limit the amount
action will be ordered. of non-domestic products they serve in their food service
Under a procurement review, procurement procedures of programs.”
solicitations and contracts are examined. In addition, a review How should schools make sure that they’re in compliance with
Buy American? “First o , the Buy American provision should
“Buy American must be written out in your always be included in the solicitation documents as well as
contracts and product speci cation lists,” Shelton said. “However,
procurement procedures or you must have a it is the school or district’s responsibility to check the products
written plan. That language must be in all of they are ordering and receiving to ensure the country of origin
does in fact re ect a U.S. produced or processed product.”
your product speci cations, bid solicitations, When Shelton asked if there were any questions or comments,
RFPs, contracts, purchase orders and an AASBO member expressed frustration at trying to plan meals
while meeting Buy American provisions. Shelton agreed, and said,
procurement documents.” “Keep track of it, and try to buy domestic products when possible.”

— Julie Shelton, Director School Food Programs, Arizona
Department of Education Julie Shelton can be reached at: Julie.Shelton@azed.gov or
(602) 542-6208.

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14 THE EDGE SUMMER 2018

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