ADVANCEMENT OF THE PRACTICE
63% fewer than FDA-aligned agencies. This disproportionate coverage is a defining feature of the FDA-guided model: Adopting agencies tend to be the larger, more complex programs overseeing the largest share of the regulated food supply.
TABLE 2
Workforce Capacity and Establishment Coverage by Standardization Category
Standardization Category
Average # of Employees
Average # of Full-Time Employees
Average # of Facilities Inspected
Estimated % of National Coverage
Training, Eligibility, and Performance Criteria
FDA-guided jurisdictions demonstrated consistently stronger adherence to inspec- tor training and eligibility criteria com- pared with non-FDA-guided jurisdictions across every measured dimension (Table 3). Completion of the FDA’s LearnED cur- riculum was required by 84% of FDA-guided programs versus 56% of non-FDA-guided programs. Joint and independent prestan- dardization field inspection requirements were met at rates of 82–84% in FDA-guided programs compared with rates of 56–62% in non-FDA counterparts. Timely standardiza- tion within 24 months of hire was achieved by 64% of FDA-guided programs compared with 39% of non-FDA-guided programs, and the requirement for ≥100 inspections in the prior 3 years was present in 38% of FDA- guided programs compared with only 16% of non-FDA-guided programs. Performance evaluation practices during initial standardization reinforced this pat- tern (Table 4). HACCP-related competen- cies, which are central to risk-based food safety oversight, showed the largest gaps between the two groups. Verification of exist- ing HACCP plans was evaluated by 88% of FDA-guided programs but by only 62% of non-FDA-guided programs. Written risk control plan development was assessed in 79% of FDA-guided programs ver- sus 38% of non-FDA-guided programs, and written process flowcharts were evaluated in 75% versus 38%, respectively. Communication skills and equipment knowledge were assessed at similarly high rates in both groups. Standardization Maintenance Practices Standardization maintenance practices fur- ther distinguished the two models. The most common maintenance requirement was continuing education: 77% of FDA-guided jurisdictions required completion of 20 con- tact hours of continuing education every 36 months, compared with 48% of non-FDA- guided programs. Attendance at annual retail
FDA-guided
11
10
1,887 1,456
70 12 18
Non-FDA-guided No standardization
8 5 9
7 4 8
690
National total
1,403
–
Note. FDA = Food and Drug Administration.
TABLE 3
Minimum Eligibility and Training Criteria: FDA-Guided Versus Non-FDA-Guided Standardization
Eligibility/Training Criterion
FDA-Guided %
Non-FDA-Guided %
Completed FDA LearnED curriculum coursework 25 joint field inspections prior to standardization 25 independent inspections prior to standardization Standardized within 24 months of hire/assignment ≥1-year full-time retail food inspection experience in past 3 years
84 82 84 64 56
56 62 56 39 28
≥100 inspections in the past 3 years
38
16
Note. FDA = Food and Drug Administration.
food protection seminars was required in 34% of FDA-guided jurisdictions compared with 21% of non-FDA-guided programs. Moreover, non-FDA-guided jurisdictions were more likely to report “other” mainte- nance practices (46%), reflecting the diver- sity and variability in their approaches. Some respondents in both categories reported no formal maintenance protocols, noting that policy development was still in progress. Barriers to Standardization More than one half of FDA-guided jurisdic- tions (53%) reported at least one barrier to implementing or maintaining inspector stan- dardization. Time constraints were the most frequently cited barrier overall (48% of all mentions), followed by staffing limitations (30%), training access (13%), funding and
budget constraints (7%), and administrative or procedural challenges (2%) (Table 5). Notably, barriers were reported across all three standardization categories, including among FDA-guided jurisdictions, indicating that achieving and maintaining standardiza- tion is an active, ongoing challenge even for programs that have adopted the model. The concentration of time and staffing barriers among FDA-guided agencies suggests that expansion efforts must account for the pro- gram’s maintenance burden and go beyond onboarding only. Awareness of the NEHA-FDA RFFM Grant Program Among all 530 surveyed jurisdictions, 68% reported awareness of the NEHA-FDA RFFM Grant Program. Among the 168 jurisdictions
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Volume 89 • Number 4
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