ADVANCEMENT OF THE PRACTICE
attend annual seminars, accumulate food safety contact hours, conduct standardization exercises with other staff, conduct training courses, and/or develop risk control plans. FDA’s VNRFRPS provide the overarching framework for standardization (FDA, 2024, 2025, 2026c). The program encompasses nine standards that jurisdictions voluntarily adopt to strengthen their retail food regula- tory programs. In general, standardization is most directly addressed by Standard 2 (Trained Regulatory Staff), with related rein- forcement through Standard 3 (Inspection Program Based on HACCP Principles), Stan- dard 4 (Uniform Inspection Program), and Standard 6 (Compliance and Enforcement). As of December 2024, 980 jurisdictions were enrolled in VNRFRPS, encompassing 68 state or territorial agencies, 91 district-level agencies, 549 county-level jurisdictions, 245 city- or town-level jurisdictions, and 27 other agencies (FDA, 2026a). Further, the 980 juris- dictions enrolled are out of an estimated 3,000 total SLTT agencies that are responsible for regulating retail food establishments in the U.S. Approximately 2,020 agencies were not enrolled in VNRFRPS. Nonenrollment does not necessarily indicate an absence of food safety efforts, as nonenrolled jurisdictions could be operating under locally developed programs, following state-mandated guidelines, or simply lacking the capacity and infrastructure to for- malize standardization processes. Despite the long-standing existence of the standardization program and its integra- tion into VNRFRPS, the national landscape of inspector standardization had never been comprehensively characterized. Crucial questions remained unanswered: • How many agencies—regardless of VNRFRPS enrollment—implement FDA- guided standardization? • What is the scale of the workforce that remains outside FDA-guided processes? • What barriers prevent adoption of the standards? • What is a realistic scope for the engage- ment opportunity if resources were deployed strategically? To address these questions, FDA engaged the National Environmental Health Associa- tion (NEHA) through the NEHA-FDA Retail Flexible Funding Model (RFFM) Grant Pro- gram, which is a $36 million partnership fully funded by FDA to design and administer a
national census under Objective 3 of the grant program. From May 2022 to December 2023, NEHA collaborated with FDA leadership, sub- ject matter experts in standardization proto- cols and VNRFRPS, and staff from the RFFM Grant Program to codevelop a 52-item census instrument (see supplemental file). The census instrument was designed to capture standardization practices across three distinct program pathways. A compre- hensive, verified directory of more than 3,000 SLTT agencies was assembled, and a custom secure web portal was built to support multi- session data entry and real-time engagement monitoring. The scope of this development effort reflects the priority NEHA and FDA placed on the census (National Association of County and City Health Officials [NAC- CHO], 2014; Shah et al., 2022). This article reports findings from this cen- sus, which we call the Retail Food Regulatory Workforce Standardization (RFRWS) Census. Along with documenting the current national landscape of standardization, it quantifies the scope of the remaining engagement opportu- nities. It estimates the number of jurisdictions and inspection personnel that potentially could be brought into FDA-guided stan- dardization. Lastly, this instrument enabled the formation of six data-grounded strategic recommendations to advance consistency in retail food safety oversight.
laborative consultation with leadership at FDA, subject matter experts in standardiza- tion protocols and VNRFRPS, and staff from the RFFM Grant Program. The final census instrument consisted of 52 items organized around two qualifier questions: 1) Do your jurisdiction’s training requirements include a standardization process for retail food safety inspection staff? (Q5) and 2) Does your juris- diction’s standardization process follow the FDA Procedures for Standardization of Retail Food Safety Inspection Officers? (Q6). Based on responses, participants were routed to one of three tailored sections: 1. FDA-Guided Standardization (Q7–Q26): Examining alignment with FDA bench- marks, restandardization frequency, per- formance areas, and recordkeeping. 2. Non-FDA-Guided Standardization (Q27– Q45): Assessing internally developed mod- els and deviations from FDA standards. 3. No Standardization (Q46–Q52): Captur- ing reasons for absence of standardization, interest in future engagement, and substi- tutes for standard-aligned training. Items captured workforce size and work- load, training and eligibility criteria, perfor- mance evaluation areas, maintenance and restandardization practices, and barriers to implementation. Additionally, items had optional open-text fields for contextual detail. Data Collection A comprehensive directory of more than 3,000 verified SLTT agency contacts was compiled between January 2024 and June 2024. Par- ticipating jurisdictions received personalized email invitations with unique login creden- tials. The census was administered from July 2024 to January 2025 via a secure, interactive web portal that allowed multisession partici- pation, enabling respondents to save progress and revise entries before final submission. An administrative dashboard enabled real-time monitoring of response rates, participation by jurisdiction, and downloading of datasets for ongoing programmatic planning. A total of 530 jurisdictions submitted completed responses (overall response rate: 16.8%).
Methods
Study Design and Census Population A cross-sectional census design was used to enumerate standardization practices across all identifiable SLTT retail food regulatory agencies in the U.S. and its territories. The census population comprised approximately 3,000 local jurisdictions and 65 state or ter- ritorial agencies, totaling 3,065 agencies. Participation was voluntary, responses were deidentified prior to analysis, and ethical clearance was granted by the institutional review board at California Baptist University (IRB #037-2327-EXM) in accordance with the Declaration of Helsinki (World Medical Association, 2013). Instrument Development The census instrument was codeveloped over approximately 19 months (May 2022– December 2023) through iterative col-
Statistical Power and Sample Size Justification
Although the census was designed as a population-level instrument targeting all of the approximately 3,065 identifiable SLTT
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Volume 89 • Number 4
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