ADVANCEMENT OF THE PRACTICE
TABLE 6
National Standardization Opportunity Analysis: Estimated Jurisdictions and Inspectors by Category (Projected to Full SLTT Population)
Metric
Level
FDA-Guided # (%)
Non-FDA-Guided # (%)
No Standardization #
Total #
Estimated total jurisdictions
State Local State Local State Local State Local State Local
50
5
10
65
1,470 1,100
360 130
1,170
3,000 1,350
Estimated total inspectors with RFI duties
120
11,760
3,240
5,850
20,850
Inspectors requiring standardization (85% target) Directly standardized by an FDA FSIO
935
111
102
1,148
9,996
2,754
4,973
17,723
365 (39)
56 (50) 193 (7) 37 (33) 799 (29)
– – – –
– – – –
1,300 (13)
Standardized by an FDA- standardized individual
473 (43)
6,997 (70)
Note. Dashes (–) indicate categories where this metric is not applicable (i.e., no formal standardization process). FDA = Food and Drug Administration; FSIO = Food Safety Inspection Officer; RFI = retail food inspection; SLTT = state, local, tribal, and territorial.
least equipped to consistently apply risk- based principles. Projecting the RFRWS Census findings to the full SLTT population provides a concrete picture of the engagement opportunity (Table 6). Applying the respondent-observed distri- bution to all registered SLTT jurisdictions yields an estimated 1,545 agencies currently outside FDA-guided standardization, approx- imately 1,530 local agencies using non-FDA- guided models (360) and with no formal pro- cesses (1,170), and 15 state-level agencies. Based on the average inspector workforce sizes observed across census respondents in each category, we calculated that an estimated 9,340 inspection personnel work in those agencies. Applying the 85% standardization mandate reported by standardized jurisdic- tions, we found that approximately 7,940 additional inspectors (7,727 at the local level and 213 at the state level) would require stan- dardization to achieve full alignment. These numbers represent a defined, achievable tar- get that is not an abstract aspiration but a concrete workforce development goal. Infrastructure Challenges: A System Reliant on People Census findings reveal an important struc- tural characteristic of the standardization pathway that has strategic implications for
any expansion effort. Among local FDA- guided jurisdictions, only 13% of inspectors are directly standardized by FSIOs. The vast majority (70%) of inspectors are standardized by an FDA-standardized individual within their jurisdiction or state agency, meaning that the system relies on people. This person-training-another-person model has enabled the program to reach its current scale, but the reliance on people also creates fragility in that retirements, staff turnover, or departures of key standardized personnel can disrupt the capacity of entire jurisdictions to maintain or expand standardization (Newman et al., 2014). At the state level, states including Connecticut, Indiana, Minnesota, Texas, and Utah have developed robust internal capacity via FDA-standardized state officers who certify local inspectors, but this model has not been replicated uniformly. Furthermore, we found many jurisdictions noted that FDA lacks suf- ficient capacity to directly standardize person- nel across all areas under its oversight, which means that local and regional standardization capacity is essential. The disconnect between FDA-guided and non-FDA-guided agencies on cross-jurisdic- tional support compounds this challenge. Based on the census findings, 80% of non- FDA-guided jurisdictions report that they rely on external support for standardization.
By contrast, nearly 70% of FDA-standardized jurisdictions report limiting standardization efforts to within their own agency boundar- ies, thereby providing little spillover benefit to neighboring programs or resource-con- strained programs. This structural mismatch between where capacity resides and where it is needed is central to any scalable expansion strategy. Addressing the mismatch will require delib- erate incentives, formal recognition pro- grams, and interagency sharing agreements that make external standardization support both feasible and implementable for capacity- holding jurisdictions. Engagement Readiness: A Moment for Action Perhaps the most actionable finding from the RFRWS Census is the system’s programmatic engagement readiness. The majority of sur- veyed jurisdictions are already aware of the NEHA-FDA RFFM Grant Program or are actively interested in learning more. Among nonparticipating jurisdictions, nearly three quarters (75%) expressed interest in pro- gram engagement. These jurisdictions are not passive actors waiting to be discovered; they are agencies that have self-identified as interested but have not yet engaged with the RFFM Grant Program. The primary barriers
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Volume 89 • Number 4
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