Food Safety Classes for Special Needs Individuals, High School Students and Non-Profit Organizations

State: AZ Type: Promising Practice Year: 2021

Maricopa County, located in the Arizona desert, is the fourth-most populous county in the U.S., with a population of 4.49 million residents (2019 Census) residing primarily in the Phoenix metropolitan area. According to the Arizona Department of Economic Security, its Division of Developmental Disabilities serves more than 40,000 people with developmental delays and disabilities and their families each year. The Arizona Developmental Disabilities Planning Council in 2012 suggested a prevalence rate of 1.8 percent, equivalent to 60,000 children and 100,000 Arizonans of all ages with a developmental disability. Of interest to Maricopa County Environmental Services Department (MCESD) is that many of these social services groups in Maricopa County offer some type of program that allows its members to gain knowledge and training with various aspects of working in the food industry which requires food safety training. When a nonprofit community service organization qualifies for a food permit fee waiver from MCESD, it may also request a food safety training class. This class is commonly called the Fee Waiver Class,” and it supports a strategic objective of the nonprofit organization (NPO) to provide services to a special group or program.


All food service worker (FSW) training was previously provided by MCESD until it was outsourced to private entities. Outsourcing did not cover Special Needs individuals or NPOs who in various ways handle food and do not have the funds to obtain food service worker cards. Having a basic knowledge of safe food handling practices can go a long way in preventing foodborne illnesses. Understanding this, MCESD had to come up with a way to bridge this gap to provide food safety training to underserved food service workers at no cost. Maricopa County Environmental Health Code has a provision that allows for fee waivers with Board of Health (BOH) approval, thus an inhouse guidance document and customer application were developed. The fee waiver form for NPOs and culinary programs is linked on the MCESD webpages,, and

MCESD provided food handler testing and issued food handler cards until 2016, then turned over training to ANSI-accredited third parties. However, two separate, unrelated programs for special needs individuals were retained to serve the community. One is the Limited Use Food Employee Certificate,” issued to an individual with a disability who works under direct supervision in a commercial or noncommercial operation. (This is discussed later.)


The other is the Fee Waiver Class,” a customized food safety class for an approved NPO under the Fee Waiver Program.” In calendar year 2020, 317 permit applicants received fee waivers (1.2% of approximately 25,000 non-mobile, fixed permits). Organizations that have requested Fee Waiver Classes” have included 501(c)(3) social services, high schools with culinary programs, DECA (Distributive Education Clubs of America) programs, food banks, senior centers, and churches. The class has remained popular for the past seven years, possibly because of the unique opportunity to receive training customized for the objectives of that organization.


Classes are often requested for groups of special needs youths. The classes are geared to their abilities, which range from mild autism to truly special needs. Department staff have generously taught the classes for years, collaborating with the organizations, school culinary teachers, IEP (Individualized Educational Plan) staff, etc. to meet the objectives of the training. For example, classes may be for high school students in transition programs, or students might be preparing to work in their school cafeterias. Compared to food handling classes for regular high school students who are tested with 40 multiple-choice questions each with 4 choices, the classes for special needs students are more visual, focus on aspects of personnel hygiene in food handling, and is followed by a test with 20 simple Yes or No questions.


Initially, class sizes were large; a few had 93, 74, and 63 students. To better serve the schools and their schedules, and accommodate students' questions, class sizes were reduced and classes were conducted more frequently. Due to class periods being one or two hours long, the classes now average one hour and 30-40 minutes, which includes the testing and grading. After a few visits to a school, MCESD became familiar with the school audio-visual hardware available, which helped save time setting up equipment and also facilitated the incorporation of online videos and DVDs to the class.


During the COVID-19 pandemic, MCESD quickly adopted virtual teaching for four scheduled classes using Microsoft Teams. With this app, the trainer and students can see one another to fully interact and ask and answer questions. The tests are accessible through a link sent to the organization prior to the class, and students log in to take the test. Fewer than in previous fiscal years (FY, July to June), the four virtual classes so far hosted 34 students, and more classes are scheduled in 2021.


From FY 2016 to FY 2020, an average of 400 participants were reached each year, and received their Fee Waived Food Employee Certificates.” The certificate is good for three years for working in the specified establishment.


The other food handler certificate for special needs individuals who work in food service is the Limited Use Food Employee Certificate,” which recognizes their training to perform specific activities of low public health risk under continuous supervision. The Certified Food Protection Manager (CFPM) of the establishment essentially sponsors the employee and has the responsibility of requesting the certificate on behalf of the applicant. In this role, the CFPM confirms the applicant's training and will provide continuous oversight of the applicant when handling food or food contact surfaces.


The evaluation to earn the three-year certificate requires a meeting with an Environmental Health Specialist (EHS), when the CFPM and the applicant are ready, to see them at work. The EHS expects that the applicant is trained and able to perform the assigned duties in accordance with the FDA Food Code, and evaluates whether the CFPM has policy, training, and verification procedures in place. If the special needs individual is present during subsequent inspections, the CFM should also be present and supervising the specific determined activities.


Despite few applicants for Limited Use” certificates, MCESD provides this opportunity to support the hiring of special needs individuals in food service to ensure that there is a fair process for adults with disabilities to participate to the best of their abilities. The requirements for the certificate help to ensure an appropriate level of food safety training and supervision.

Although social services are beyond the scope of its mission, MCESD supports those nonprofit community organizations by providing the opportunity to obtain waivers for food permit fees. The organization submits a waiver application which must be approved by the BOH. Fee-waived permits have included food banks; food jobber facilities and food services affiliated with churches, charitable organizations, and shelters; and schools. These services are invaluable to the at-risk and special populations who use them.


The Fee Waiver Class” supports services and programs, and frequently provides food training to youths in schools. MCESD supports community kitchens and shelters and helps ensure training in food safety practices for volunteers and employees who may not be food service professionals.


The Limited Use Food Employee Certificate,” created in 2013, is issued to an individual with a disability to work under direct supervision to perform specific food handling activities that present low public health risk. The application is submitted by the individual's supervisor at the food establishment. A career in food service may contribute to that individual's independence, self-reliance, and confidence.


MCESD supports food and shelter services that have the resources for the total well-being of the patrons, and participates with these groups to find solutions to food and shelter issues.

The Fee Waiver Program and its Fee Waiver Class” align with the mission of MCESD to provide safe food so that residents may enjoy living in a safe and healthy community. The health of the community is better with self-reliant special needs youth and adults, knowledgeable individuals who manage food safely in any kitchen, and safe food and shelter for at-risk populations.  


If the total dollar amount of the fees waived was divided by the number of students/attendees in the fee-waiver classes per calendar year, the amount could represent the amount invested” in each individual by MCESD. In 2018-2019, the average was $228. However, calendar year 2020 was not typical, and the per individual amount was $502.


The content and quality of both the tests and the teaching of the classes have been evaluated often over the years. Changes and improvements were made to accommodate the different groups that request the classes. As shown in the graph, participation in the Fee Waiver Class” has remained steady.

The fee-waiver classes were initially completely onsite. To minimize the disruption for students, several classes might be combined into one session, which occasionally resulted in class sizes of 50-90 students. Because it took too long to grade that many tests, changes were made to accommodate the schools and the MCESD staff. Smaller classes were conducted more frequently, and the content was restructured for one-hour class periods. The class size averages 22, but the range can vary from ten to 30. Proactive communication with the staff at each school about the availability of audiovisual equipment, such as an overhead projector, DVD player, sound system, etc., saved set-up time and increased efficiency.The Fee Waiver Class” averages an hour and 30-40 minutes to conduct, and over the course of a year is equivalent to about an hour and half every two weeks.


In the past few years, in close collaboration with several teachers at different schools, varied tests and teaching styles have been developed to accommodate the different types of students. In this way, the Fee Waiver Class has improved greatly. The teachers are grateful that we are able to offer this program that allows their students the added experience. Before COVID-19, there was no online version of the class. This year, schools requested an online version of the class. With the Microsoft Teams app, the students and teacher are able to interact during the class, and testing is administered by logging online.


For the MCESD staff who teaches these classes, the interactions with the special needs youths are especially rewarding. For this reason and those in the previous section, the intangible benefits are far greater than the relatively low cost of the classes. Likewise, the Fee Waiver Program will continue to be available to NPOs to recognize their invaluable services.