and more capable of sustaining them. State- level adoption remains at 77%, reflecting strong institutional alignment at the gov- ernance tier most directly linked to federal guidance. Together, these findings document a working model that reaches a substantial share of the regulated food supply. Additionally, FDA-guided jurisdictions show consistent performance advantages across every measured dimension of inspector preparation. Compared with non-FDA-guided counterparts, FDA-guided programs show higher rates of LearnED curriculum comple- tion (by 28 percentage points), greater adher- ence to joint and independent field inspection requirements (by 20–28 percentage points), higher rates of timely standardization within 24 months of hire (by 25 percentage points), and greater inclusion of a written risk control plan assessment in performance evaluation (by 41 percentage points). These gaps reflect substantive differences in how thoroughly inspectors are prepared for fieldwork. Research shows that inspec- tor-level variation directly affects violation detection rates and inspection comparability (Ibanez & Toffel, 2019; Jones et al., 2004; Lee & Hedberg, 2016; Ma et al., 2017). The FDA-guided model addresses this variation at its root.
TABLE 4
Performance Areas Evaluated During Initial Inspector Standardization
Performance Area
FDA-Guided %
Non-FDA-Guided %
Effective communication
94 94 88 79 75 76
98 93 62 38 38 52
Knowledge and use of required inspection equipment
Verification of existing HACCP plan
Written RCP development Written process flowcharts
Oral communication of the seven HACCP principles
Note. FDA = Food and Drug Administration; HACCP = hazard analysis critical control point; RCP = risk control plan.
TABLE 5
Barriers to Implementing or Maintaining Inspector Standardization, by Category
Barrier Domain
FDA-Guided #
Non-FDA- Guided #
No Standardization #
Total # (%)
Time constraints
32 18
5 6 4 2 1
21 12
58 (48) 36 (30) 16 (13)
Staffing limitations Training access Funding/budget
8 2 1
4 5 0
9 (7) 2 (2)
Opportunity: A Quantifiable, Achievable Expansion Pathway
Administrative/procedural
Total mentions
61
18
42
121 (100)
The RFRWS Census also illuminates the full scale of the remaining opportunity with a precision that has not previously been available. Among respondents, 249 jurisdic- tions (47%) operated without FDA-guided standardization, either using alternative approaches (12%) or no formal process at all (35%). Local agencies, which conduct most retail food inspections and serve as the prin- cipal line of defense against foodborne illness at the point of consumer exposure, showed the lowest FDA-guided adoption (49%) and the lowest workforce capacity. Moreover, the census showed that non- standardized local agencies averaged only 5 inspectors and 4 FTEs per jurisdiction but regulate an average of 690 facilities, which is well below the 1,887-facility average for FDA-guided programs. This capacity gap has implications for both inspection frequency and depth: Smaller agencies with no formal standardization are likely also the programs
Note. FDA = Food and Drug Administration.
not currently participating in the program, 73% expressed interest in learning more. In aggregate, 84% of surveyed jurisdictions were already aware of or interested in the RFFM Grant Program. This finding points to a sub- stantial reservoir of programmatic engagement readiness across the system—jurisdictions that are already interested and potentially posi- tioned for outreach and onboarding. Discussion Although our study did not directly evalu- ate inspection outcomes or foodborne illness incidence, previous research has documented variation in violation detection among inspectors and associations between regula- tory program characteristics, inspection find- ings, and foodborne illness outcomes (Baker
et al., 2026; Jones et al., 2004). Inspector standardization, therefore, represents a struc- tural intervention with potential downstream effects on food safety performance. Progress: A Majority-Adoption Model Anchored in High-Coverage Jurisdictions The RFRWS Census highlights measurable progress in FDA-guided inspector standard- ization. More than one half of responding jurisdictions have adopted FDA-guided pro- cedures, and these jurisdictions collectively regulate approximately 70% of all retail food establishments. This pattern is not coinci- dental: Larger, more complex programs with greater workforce capacity are both more likely to implement FDA-guided procedures
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November 2026 • Journal of Environmental Health
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