504 Plan for Food Allergies at School: Step by Step Guide for Parents

Do you send your child to daycare, preschool, or school?  Having a food allergy makes this process all the more complicated and nerve-wracking!  You want to make sure your child is safe, but you don’t want your child to feel singled-out or excluded because of his or her food allergies, either.  One thing you’ll want to put into place? A Section 504 Plan for food allergies.

Sound intimidating?  Never fear!  We’ve got you covered with exactly how and why to pursue one.

What is a 504 Plan for food allergies?

Good question!  504 refers to a section under a federal civil rights act passed by the U.S. government called The Rehabilitation Act of 1973.  Basically, this law states that any public or private school receiving federal money must provide a plan to accommodate anyone with a disability.

A disability isn’t only the type you can visually see from the outside.  A disability is any “physical or mental impairment which substantially limits one or more major life activities.”  A major life activity is definitely impacted by a food allergy, wouldn’t you say?  For example, if a child with an allergy eats the food, that could cause anaphlaxis and interfere with a major life activity – aka breathing.

Many physical diagnoses (visible or nonvisible) like diabetes, food allergies, epilepsy, mental impairment, and others qualify too.

A 504 Plan is a written plan created to help the school or care facility accommodate and manage your child’s safety with regard to his or her food allergies.  It ensures your child can participate in activities alongside other students despite any food allergy diagnosis.  For example, the plan may outline things like:

• Which school personnel will be trained in using the epi-pen
• Where epinephrine and any medications will be kept
• Where the child will eat or how meals or snacks should be prepared
• What safety precautions would need to be taken on field trips
• What happens if the child is treated with epinephrine

It’s really important to have something like a 504 plan formally in place so that everyone is on the same page about handling your child’s food allergies and knows what to do in case a reaction occurs.

There are other types of plans that can be put into place for your child, such as Emergency Care Plans (ECP) or Individual Health Care Plans (IHCP).  These other plans mostly detail how to treat an allergic reaction, should one occur.  Because it’s covered under a federal civil rights act, a 504 Plan is commonly used by many school districts to officially outline the care and accommodations your child should receive.  Many times, the school or daycare will have all three plans in place: ECP, IHCP, and a 504.

How to request a 504 plan for your food-allergic child

To get the ball rolling with your school or daycare, the best thing to do is contact the principal or administrator in charge.  In smaller school districts, the principal may be the person that assembles a team and sets up a meeting to prepare the plan.  Larger school districts or daycare facilities will usually have a 504 Coordinator specifically responsible for gathering all the paperwork and putting together the meetings necessary to create a food-allergy management plan.

Often, the school registration process will involve some way for you to notify the school that your child has a food allergy.

So what should you do? Be proactive!  The best thing to do is contact your school or daycare as early as possible, preferably even before school starts.

If there’s a school nurse or nurse’s aide, contact them ahead of time to verify exactly what is needed for medications and so they can be aware of your child’s food allergies.

If you know your child’s teacher ahead of time, send an email or call the school to leave them a message.  He or she will be thankful for the heads-up about your child’s food allergies and will appreciate your cooperative attitude in seeking to work with the teacher as a team.

How to prepare for a 504 meeting

After you’ve requested a 504 plan for your child, you can expect the school to schedule a meeting where any involved teachers, cafeteria workers, nurses, etc. can be informed and help decide what will go into the plan for your child.  Parents don’t have to be included in these meetings, but schools usually do want a parent or guardian present.

Most schools and facilities have a set procedure for 504 plans.  Often, they will give you forms to complete before the 504 meeting.  In a food allergy situation, these forms may include:

• A consent form to create a 504 plan
• Physician diagnosis forms (to be signed by the child’s allergist or physician)
• Emergency care forms
• Medical permission forms
• Food preparation or cafeteria plan substitutions

Tips on that mountain of paperwork

Whew!  So that’s a lot of paperwork, right?  It can be overwhelming.  Remember though, it will be worth it when everyone has peace of mind about providing a safe and enjoyable school or daycare experience for your child.

• Be sure to have all the paperwork properly and clearly filled out and signed before the meeting. Seems obvious, but we all know how easy it can be to forget these things and be frantically scribbling on forms the night before they’re due.
• Start completing those forms as soon as you can. Many of us have learned the hard way that the days and weeks leading up to school can be tough for reaching pediatricians and allergists.  Contact any doctors right away to find out procedures they may have for completing school forms.  Many doctors will require you to fax or drop off forms ahead of time, require certain notice (for example, 48 hours to complete and sign forms) or have set days of the week for completing school paperwork.
• Bring a list of concerns, questions, or items that you want to make sure are covered in the meeting. It can be stressful or confusing once you’re sitting in a meeting with several people asking you questions and going over procedures and medical information.  In those situations, you can easily walk away and realize you are still uncomfortable about something, or realize that you totally forgot to ask about a certain scenario.  Bring a list, and check it twice.  And don’t be afraid to speak up and ask those questions or follow up for answers that don’t get resolved in the 504 meeting!  (Not sure what to even ask?  Keep reading!)
• Be sure to note any names, numbers, or contact information of those involved. You’ll want to have a plan for communicating with the teacher and nurse’s office (if there is one) so that when questions come up you’ll all know how to reach each other.
• Above all, have a positive attitude! The people in these meetings — principals, teachers, cafeteria workers, aides —  they truly want to make sure your child is safe! They care about your child.  They became educators and caretakers because they love children and want to make a difference in their lives!  The last thing a school wants is to be responsible should something traumatic or tragic happen.  It can be easy to feel like you need to fight for the rights of your child (and you do, in a sense, of course!)…but coming across as accusatory and overly-anxious will put everyone on the defensive.  It’s best to approach your school with an attitude of teamwork, cooperation, and encouragement.

What kinds of accommodations should I expect or ask about?

If you’re sending a child off to daycare or school for the first time, you may have no idea what kinds of things to ask regarding your child’s food allergy.  Here are some things to consider when discussing and requesting accommodations for your child:

• What are the eating conditions like for meals and snacks? Are there allergen-free tables?  Are tables wiped down prior to eating?  Are kids required to wash their hands before meal and snack times?  (Note – schools may have a nut-free table but a dairy-free or top-8-allergen-free table is not nearly as common.)
• If the child needs alternative foods, will the parent supply those? Will lunch be packed every day?
• If a cafeteria is preparing the food, what are the procedures for safeguarding food prep for someone with food allergies? Is there a separate prep area? Are there special markers to indicate allergy-safe ingredients or to mark the child’s food?  (Note – you’re probably familiar with the fact that milk is the go-to drink of choice at school.  For students with a dairy allergy and 504 plan, the school is legally required to provide a substitute which may include a non-dairy milk alternative, juice, water, a special formula, or another beverage. )
• Are there any school or class activities involving food that may contain an allergen? How will that be accommodated?
• Are there any food-based rewards? Will the parent or school provide alternatives? How are class parties handled? Is there a possibility of non-food rewards or treats?
• Are there any school supplies that may contain or be exposed to an allergen? How will that be accommodated?
• What are the procedures for field trips? How does the school or daycare ensure proper medications are available on trips?  Does a parent or guardian need to attend?  If not, who will be trained in any medications?
• Will the teacher or primary caregiver be trained in epinephrine use? What about recess aides, cafeteria aides, or other school personnel?
• Is there a nurse or medical aid on the premise?
• For bus riders – do drivers know how to administer epinephrine? Is food or drink allowed to be consumed on the bus?
• Depending on the child’s age, will the child self-carry an auto-injector? If not, where will the medication be kept?
• What is the course of action if your child eats a known allergen, or if an adult suspects one is eaten? What is the course of action if symptoms are or are not present? (Be sure everyone is clear on the treatment that your allergist or doctor recommends.)

Some common provisions in a 504 Food Allergy Plan:

Remember that a 504 Plan helps you and the school know how to deal with everyday situations involving allergens in foods or products.  This plan will affect the daily duties of the teacher and other personnel, so be reasonable in your expectations.  You want the school to accommodate your child, but keep in mind the school is working to help other children and manage other health and safety needs, as well.

Not sure what fair food-allergy accommodations like look like in everyday context at a school or daycare?  It depends a lot on the institution and the resources available.

Some examples of common accommodation requests are:

• Asking that your child eat at an allergen-free table, if available
• For younger children with snack times, asking that the teacher or helper wipe down the eating area with disinfectant wipes or with a soapy cloth
• Asking that children wash their hands before and after eating times or when working with possible food allergens for a class activity (hand sanitizer does not remove allergens!)
• Asking that the teacher let you know ahead of time about any school projects involving any foods so you can find and provide alternatives for your child
• Agreeing to supply snacks or alternative birthday treats for the teacher to keep on hand should something come up

There is no magic formula for creating a Section 504 Plan, but that means that you and your child’s educational team can customize the plan for everyone involved.  That’s a good thing!

Additional tips and resources

The best thing you can do for your school and your child is to be prepared and informed when asking for a 504 Plan. This gives you the confidence to advocate successfully for your child. Being calm, well-informed, and prepared will also help those schools who aren’t as familiar with food-allergy accommodations.

It can feel intimidating, but don’t be afraid to ask for a 504 plan for food allergies and/or some sort of emergency care plan.  You can do this!  And you can bet that it the long run, you, your child, your child’s teacher, and other school staff will appreciate the peace of mind of having a food-allergy safety plan in place.  Food allergies shouldn’t hold you or your child back from having an awesome daycare or school experience!

Need some more information, or just want to make sure you’ve got all your ducks in a row?  We hear you!  Check out these helpful resources:

• • The U.S. Department of Education outlines the provision of Section 504 if you need more explanation.
  • The Centers for Disease Control and Prevention has put together very thorough and helpful guidelines for managing food allergies in schools, early care, and education programs.  There are several resources on this page, including toolkits for nurses.
  • The Food Allergy Research and Education organization (FARE) has a list of school guidelines by state. (not all states have specific guidelines)
  • Kids With Food Allergies (A division of the Asthma and Allergy Foundation of America) has a great webinar video from an attorney explaining answers to common questions parents have about section 504 plans, which I’m embedding below.

Share:  Do you have any other questions about 504 plans for food allergies?  What was your experience like in this process?