TABLE 1
Voluntary National Retail Food Regulatory Program Standards and Desired Conformance Outcomes
Standard
Description
Desired Conformance Outcome
1
Regulatory Foundation
A sound, science-based regulatory foundation for the public health program and the uniform regulation of industry, such as equivalency to the FDA Food Code , ideally the most recent version A trained regulatory staff with the skills and knowledge necessary to conduct quality inspections A regulatory inspection system that uses HACCP principles to identify risk factors and to obtain immediate and long-term corrective action for recurring risk factors
2 3
Trained Regulatory Staff Inspection Program Based on HACCP Principles
4 5
Uniform Inspection Program A quality assurance program that ensures uniform, high-quality inspections
Foodborne Illness and Food Defense Preparedness and Response
A food regulatory program with a systematic approach for the detection, investigation, response, documentation, and analysis of alleged food-related incidents that involve illness, injury, or unintentional or deliberate food contamination An effective compliance and enforcement program that is implemented consistently to achieve compliance with regulatory requirements Enhanced communication with industry and consumers through forums designed to solicit input to improve the food safety program; a further outcome is the reduction of risk factors through education outreach and cooperative efforts with interested parties The availability of resources to support a risk-based retail food safety program designed to reduce the risk factors known to contribute to foodborne illness A program that has identified elements that might need attention to further reduce the occurrence of foodborne illness risk factors
6
Compliance and Enforcement
7
Industry and Community Relations
8
Program Support and Resources Program Assessment
9
Note. FDA = Food and Drug Administration; HACCP = hazard analysis critical control point.
the 9 Retail Program Standards in their SA, they are required to submit a third-party veri- fication audit (VA) within 6 months arming their conformance. Enrolled programs are encouraged to continue work on achieving conformance with individual standards dur- ing a 5-year cycle. In addition to FDA’s eorts to promote enrollment in the Retail Program Standards, increases in funding and agency support at the national level have led to increased par- ticipation in the program. The Retail Pro- gram Standards Cooperative Agreement Pro- gram (RPS CAP) is a grant program oered by the National Association of County and City Health Ocials (NACCHO) in which SLTT agencies enter into cooperative agree- ments directly with FDA to work on multi- year projects related to advancing confor- mance with the Retail Program Standards. FDA’s total funding for RPS CAP from 2012 to 2021 was $30,412,000. Also oered is the NACCHO Retail Program Standards Mentor- ship Program CAP, which is a grant program that enabled SLTT agencies to participate in peer-to-peer mentorship and work with other agencies that have a record of sustained suc- cess with the Retail Program Standards. From
2012 to 2021, funding from FDA for the Men- torship Program CAP totaled $3,767,000. In addition to funding opportunities and cooperative programs, we hypothesize that factors such as the size of the agency and the length of enrollment will aect conformance with the Retail Program Standards. In general, we observed that large SLTT agencies typically have more capacity to run additional pro- grams, and therefore we would expect these agencies to have a higher conformance with the Retail Program Standards. A census of LHDs by NACCHO in 2019 revealed that the number of full-time equivalents (FTEs) at a department increases with the size of the juris- diction (National Association of County and City Health Ocials [NACCHO], 2019). With this increase in FTEs, we expect that more sta will be able to dedicate time to work on the Retail Program Standards. Furthermore, we also expect that the longer an agency has been participating in the Retail Program Standards, the more comfortable the agency will become executing the necessary steps toward achiev- ing conformance with the standards and asso- ciated administrative procedures. The objectives of our study were to 1) understand if the current guidelines of the
Retail Program Standards are feasible for local retail food regulatory programs and 2) evalu- ate how grant funding is associated with con- formance and the amount of time it takes for LHDs to submit the required documentation. As the Retail Program Standards are based on the most current science available to FDA, identifying programs that can increase con- formance with the Retail Program Standards is likely to have a significant public health impact in the field of retail food service.
Methods
Study Design In our study, a successful SA is defined as one that was submitted within 12 months of enrolling in the Retail Program Standards or 60 months after a previous SA was submitted and where the SLTT food regulatory program reported conformance with ≥1 standard. The study population included all LHDs enrolled in the Retail Program Standards from its inception in 2002 through January 2021. All observations in the initial data set that rep- resented cycles for state and other nonlocal agencies were removed so that we could focus on Retail Program Standards conformance
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November 2023 • our4(l o- 4;0ro4me49(l e(l9/
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