Limitations Several limitations should be noted. Although participation was voluntary and the over- all response rate was 16.8%, the responding jurisdictions collectively regulate approxi- mately 70% of all retail food establishments in the U.S., thus providing a meaningful rep- resentation of national food safety oversight capacity. This disproportionate coverage of establishment-level programs reflects greater participation in larger, more complex regu- latory programs and supports the generaliz- ability of key findings regarding FDA-guided standardization. Nonrespondents are more likely to represent smaller, lower-resourced local agencies. To the extent that these agen- cies are also less likely to be standardized, the adoption rates observed in this census could modestly overestimate national rates. This pattern reinforces, rather than under- mines, the case for expanded outreach and engagement. Furthermore, data were self- reported and not independently verified. The cross-sectional design precludes assessment of trends or causal inference, and our study findings were not linked to inspection per- formance metrics or foodborne illness out- comes. Lastly, population projections apply respondent-observed rates uniformly across jurisdiction types and might not capture regional variations. Conclusion and Recommendations The RFRWS Census establishes the first national baseline of inspector standardization and a precisely quantified expansion target. We found that FDA-guided standardization covers approximately 70% of the nation’s retail food establishments and demonstrably prepares inspectors more thoroughly across all measured dimensions. Approximately 1,545 jurisdictions and 9,340 inspectors remain outside FDA-guided processes; how- ever, achieving an 85% standardization man- date would require standardizing approxi- mately 7,940 additional personnel. Six recommendations, derived directly from the RFRWS Census findings, provide the strategic framework for action. 1. Enhance Resource Allocation for Compli- ance With Standard 2 : Workforce capac- ity disparities among non-FDA-guided and nonstandardized jurisdictions signal an urgent need for focused investment. Federal and state agencies should fund
to engagement are logistical and resource- related (e.g., time, staffing, training access), not attitudinal. That distinction matters: It means that targeted outreach and flexible delivery can move these agencies—and the infrastructure to do so already exists. Alignment With Existing Literature The findings of the RFRWS Census extend and contextualize a substantive body of prior research on retail food inspection qual- ity. Studies have documented that inspector characteristics and preparation are associ- ated with meaningful differences in violation detection rates (Firestone et al., 2020; Ibanez & Toffel, 2019; Jones et al., 2004); inspec- tion scheduling can introduce systematic bias into assessment outcomes (Ibanez & Toffel, 2019); and inconsistent interpretation of risk factors across jurisdictions undermines the comparability of regulatory data and its downstream utility for outbreak prevention (Irwin et al., 1989; Lee & Hedberg, 2016; Leinwand et al., 2017). The census adds a structural dimension to this evidence base. It moves the conversation beyond documenting that variability exists to quantifying the extent to which the workforce has access to a standardized, evidence-based preparation process. The 26-percentage-point gap in HACCP plan verification between FDA- guided and non-FDA-guided jurisdictions, the 28-point gap in LearnED curriculum comple- tion, and the 41-point gap in a written risk control plan assessment are not random varia- tions—rather, they are the product of struc- tural differences in inspector preparation. Our study provides the first national-scale quantification of that structural gap and, crucially, links the gap directly to a concrete, achievable intervention pathway. Prior quali- tative assessments of local health department engagement with FDA program standards (NACCHO, 2014; Shah et al., 2022) and investigations into regulatory program varia- tion across jurisdictions (Idjagboro et al., 2020; Kambhampati et al., 2016) identified similar themes of resource constraints and structural capacity disparities. The RFRWS Census provides the quantitative evidence base that those assessments called for. Taken together, the literature frames inspector stan- dardization not as a procedural requirement but as a public health infrastructure invest- ment with measurable, scalable returns.
training, staffing, and technical assistance to support Standard 2 adoption, leverag- ing flexible models such as the RFFM Grant Program. The large number of nonparticipating jurisdictions (73%) that expressed interest in the RFFM Grant Program represents an identified group interested in engagement. 2. Develop Regional Standardization Net- works : Most local jurisdictions lack inter- nal capacity to conduct standardizations. Networks of FDA or state-standardized professionals serving as mobile or remote standardizers would extend program reach, and regional collaboration hubs connect- ing contiguous SLTT agencies could sup- port jurisdictions that are unable to sustain the process independently. 3. Promote and Incentivize Cross-Jurisdic- tional Standardization Support : A struc- tural paradox exists: non-FDA-guided jurisdictions (80%) seek external stan- dardization support, whereas FDA-guided jurisdictions (70%) limit efforts to within their own agency. Formal incentives and interagency sharing agreements could redi- rect existing capacity toward underserved neighboring programs. 4. Reinforce Full and Consistent Implemen- tation of Standard 2 : Programs omitting crucial Standard 2 elements, including HACCP verification (FDA-guided: 88% versus non-FDA-guided: 62%), risk con- trol plan development (79% versus 38%, respectively), and process flow chart evalu- ation (75% versus 38%, respectively), should be supported through compliance checklists and targeted guidance to ensure full protocol fidelity. 5. Explore and Formalize Alternative Stan- dardization Delivery Models : Accredited third-party organizations, virtual standard- ization components, and train-the-trainer frameworks should be included to reduce dependence on limited FDA or state staff and lower participation thresholds for low- capacity jurisdictions. 6. Establish a Dedicated Standardization Grant or Broker Program: A grant- supported broker program could sys- tematically connect jurisdictions seeking inspector standardization with qualified providers. This approach would replace reliance on informal, individual arrange- ments with a coordinated, sustainable
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November 2026 • Journal of Environmental Health
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