After way too many hold-ups, our daughter’s school will be convening a group of professionals to oversee the implementation a legal document that will provide protection for her while in school. Because she is the first in our school district to be diagnosed with Celiac Disease (93% of people suffering from this are undiagnosed), we’ve hit quite a few roadblocks, but at least we’ve got a meeting at which to present our case for 504 implementation. I am sharing this plan in the hopes that other parents in our shoes might find it helpful.
Information on 504 plan from The National Organization for Celiac Awareness:“Section 504 is part of the Rehabilitation Act of 1973, and applies to all institutions receiving federal financial assistance, such as public schools. Under this law, public schools must provide a free appropriate public education and not discriminate against disabled students. This law acknowledges that the disability may not require special education services but a plan is needed to ensure the student receives an appropriate education accommodating the disability within the classroom. This law must accommodate a special diet, including the gluten-free diet which is the only known treatment for Celiac Disease.”
The Department of Education (ED) Office of Civil Rights regulations define a physical or mental impairment as any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine… The regulations do not spell out every disease and condition that may constitute physical or mental impairments. Section 504(a) of the Rehabilitation Act of 1973, as amended, 34 C.F.R. 104.3(j)(2)(i) and the Americans with Disabilities Amendments Act of 2008 (ADAAA), Title II regulation at 28 C.F.R. § 35.104.
Section 504 Plan for Gillian XXXXXXXXX
School: XXXXXXXX School
School Year: Late 2009/2010
Gillian XXXXX XX/XX/X X Celiac Disease
Student’s name Birth Date Grade Disability
Homeroom Teacher: XXXXXXXXX Bus Number:X
Objectives/Goals of this plan
Celiac disease is an autoimmune disease that causes damage to the intestinal
lining, interfering with the absorption of nutrients. Untreated, celiac disease
causes multi-system complications such as diarrhea, constipation, gas, bloating,
iron deficiency anemia, decreased bone density, failure to thrive, short stature,
and behavior problems.
The only treatment for celiac disease is a strict gluten free diet for life. Gluten is
found in wheat, rye, barley and contaminated oats. Therefore, all foods with
wheat, rye, barley and oats must be eliminated from the diet. In addition to the
foods being gluten free, it is equally important that these foods are not
contaminated by coming in contact with gluten containing foods during their
preparation or service.
1. Provision of Celiac Disease Care
1.1 All staff members involved in the care and education of Gillian must
receive training in the management of Celiac Disease. This includes teachers,
classroom assistants, substitute teachers, cafeteria workers, office staff, school
nurse, and any other staff that has primary care for her.
1.2 All staff who interacts with Gillian on a regular basis understands Celiac
Disease, can recognize symptoms of gluten ingestion, and work with other school
staff to eliminate the use of gluten containing foods in her meals,
educational tools, arts and crafts projects or incentives.
2. Meals and Snacks
2.1 The only treatment for celiac disease is a strict gluten free diet for life.
Gluten is found in wheat, rye, barley and contaminated oats. Therefore, all foods
with wheat, rye, barley and oats must be eliminated from Gillian’s diet. This includes
the obvious sources such as wheat breads, pastas, buns and rolls but it also
includes items such items as soy sauce, some broths and meat bases, some soups,
gravy thickened with wheat flour and breakfast cereals that contain malt or malt
flavoring. All labels must be carefully reviewed to be sure no gluten containing
grain is used in that food product. Also, items that are made in factories where equipment is shared with glutinous food cannot be served.
2.2 In addition to the food itself being free of gluten, the food cannot come in
contact with or be contaminated by gluten containing foods. This means the gluten-free foods need to be prepared in a separate area, cooked in separate pans, toaster oven or microwave, and served with clean gloves.
2.3 In order to provide a balanced meal containing the 4 groups necessary for
reimbursement, a gluten free bread or bread alternative must be offered at all
school meals. This would include such foods as a gluten-free bread, gluten-free
roll, gluten-free cereal and gluten-free pasta. The meat and meat alternative
must also be free of gluten containing grains such as fillers in hot dogs, poultry
injected with wheat or barley, and a gluten containing grain used as an extender
in other meat products.
2.4 School food service personnel will develop a system for identifying Gillian when moving through the cafeteria line so that a member of the staff can ensure the selected food is safe. To facilitate this, Gillian will identify herself to service staff or use specially code lunch tickets if desired.
2.5 The school will designate a person to be responsible for ensuring that lunch
tables and surrounding areas are thoroughly cleaned before lunch. It is
recommended that a designated sponge or cleaning cloth be used for the gluten
free area to avoid cross contamination.
2.6 Teachers will give Gillian’s parents a 48 hour notice of any special
events outside the classroom at which food will be prepared that is not from the cafeteria. The school will provide Gillian’s parents with a gluten-free food option for said event. Her parents may choose to provide appropriate food for the event.
2.7 Classroom parties where food will be shared will be gluten free. Gillian’s parents will supply lists of easy-to-find grocery items to homeroom parents and/or teachers.
2.8 Snacks will be available in the classroom, or Gillian’s backpack, or the nurse’s office (whichever is deemed most viable) in the event that she becomes hungry. Because she can only ingest a small amount of food at a time, she needs to eat more often. Gillian has promised to use this privilege conservatively. If it is more convenient and less disruptive for the class, she can quietly eat a small snack at her desk.
3. Bathroom Access
3.1 Accidental exposure to gluten may cause gas, bloating and diarrhea;
therefore, Gillian shall be permitted to use the bathroom without restriction. If she deems it necessary, she will be permitted to use the bathroom in the nurse’s office in case of serious stomach cramping and cold sweats, so that she can be overseen by an adult. Gillian has come to the edge of passing out when symptomatic.
3.2 Benadryl will be available to Gillian should accidental exposure occur, as hives often appear when cross-contamination occurs. This can be dispensed at the nurse’s office at Gillian’s digression.
3.3 Gillian will also need access to hand washing facilities after handling
products that contain gluten such as Play Dough or paper-mâché.
4. Classroom Art Projects
4.1 Rubber gloves will be accessible to Gillian for projects that contain gluten such as Play Dough or paper-mâché. As stated in item 3.3, Gillian will need access to hand washing facilities after handling these products.
4.2 Parents will be informed at least 48 hours in advance of any non-airborne gluten-containing items being used in a project so they can make appropriate substitution if necessary (I.E. gluten-free ginger bread cookies for building a house).
4.3 School projects utilizing glutinous ingredients which can become airborne (I.E. volcanoes) must be substituted with another project or gluten-free ingredients, such as gluten-free flour.
5. Field Trips and Extracurricular Activities
5.1 Parents will be notified of upcoming field trip plans that would involve food or
food-related activities. The school will provide parents with a gluten-free meal
option for any off-campus school-sponsored activity. The parents may choose to
provide appropriate gluten-free alternatives.
6. Communication
6.1 The school staff will keep Gillian’s Celiac Disease confidential, except to
the extent that Gillian decides to openly communicate about it with others.
6.2 The school staff will provide reasonable notice to her parents when
there will be a change in planned activities such as field trips or parties.
6.3 Each substitute teacher and substitute school nurse will be provided with
written instructions regarding Gillian’s Celiac Disease care.
6.4 Prior to the beginning of every school year the new classroom teacher will
receive a copy of the 504 plan and will review it to ensure that the steps
necessary to keep Gillian safe are clear and understandable. Written
documentation of this process will be provided to her parents before Gillian
enters the classroom.
7. Emergency Evacuation and Shelter-in –Place
7.1 In the event of emergency evacuation or shelter-in-place situation the
student’s 504 Plan will remain in full force and effect.
7.2 Gillian’s parents shall provide the school with a 3 day emergency
supply of non-perishable gluten free foods.
8. Parental Notification
8.1 Gillian’s parents shall be notified immediately in the following
situations:
* The student has eaten a food item that contains gluten.
* The student has symptoms of gluten ingestion such as abdominal
pain, cramping, diarrhea, or hives.
9. Emergency Contacts:
XXXXXXX


















That is amazing! The fact that you have been able to get the school to implement this is impressive. Good work and I hope that they stick to the plan!
Tracy D´s last blog ..Soup, Snow and Sauce
I haven’t gotten them to implement this yet, but I’ve prepared it for the meeting…believe me, when this gets implemented, you’re going to see me do a happy dance all the way at your house:)
I’ll keep my fingers crossed that they see reason! There are enough children who are on gluten free diets anymore that they need to have SOMETHING in place!
We have something very similar to this for Parker, only his is for gluten/casein/soy.
Still, this is MUCH more detailed and MUCH better than the one I’ve written. LOL
Please keep us updated. I’ll be interested to hear how the school responds to all these things. In my experience, although they’re required by law to do so, most schools are very reluctant to implement these types of plans. Bah.
Good luck!
Reluctant isn’t the word I would use:) Still, this is the standard 504 that’s being used all over the U.S., so they can fight it, but it will be very expensive for the school system to spend money in court. We’re ready in case that happens, but of course I’d like Gillian taken care of as soon as possible. This has been dragging on for three years, and the terms like ‘gross misconduct’ are being bandied about. Again, we won’t even go there if Gillian’s 504 gets passed, and we can simply move forward. I’m not one to hold a grudge.
Bridgett, did you write up your plan yourself, or did the school do it for you?
Tracy, 97% of people with Celiac are still undiagnosed…the schools are going to have to handle this, because Gillian’s the first of many to come…
I foresee a future sometime soon when all foods/ snacks/ craft items/ etc in a school will have to be peanut free, soy free, gluten free etc. It would really make sense for the schools to implement this. Then there would be less worry about allergic reactions, special diets and health issues. And it wouldn’t hurt any of the kids. It would also be REALLY NICE if they actually offered vegetarian options for children. As of right now, my 4 yo who refuses to eat meat just ends up eating his veggies and bread every day. How is that serving him a nutritious meal? NO protein at all. (sorry, that’s my beef with the school here right now! LOL)
I certainly hope your daughter’s school listens to reason soon. It is ridiculous that you have been trying for 3 years to have her dietary and health needs met!
Tracy D´s last blog ..I Knitted!
THANK YOU for posting this!!! Celiac is RAMPANT in my family, and I have long-suffered from an auto-immune myself, for now diagnosed as Rheum Arth. I say for now, because my father has CD, I have many symptoms, but am antibody negative… and have trouble finding a doc willing to do an endoscopy to look further. So for now I live with daily debiliating pain as I attempt to mother my babies… and of course onset was my first pregnancy, again typical for onset of CD. I also have 2 antibody positive siblings (out of 4 kids!) that are for now disease free. Most of all, however, I have two kids that I know are prone, as the disease extends through my family line, as well as my hubby’s. My daughter already suffers from SEVERE soy and milk allergies, and I had NO clue that when she goes to school it was her RIGHT to be protected! How amazing to also find this valuable info in a Pagan blog! Many thanks again! Best to you and Gillian!