Retail Program Standards Blog Series: Standard 3

Dec 18, 2018 | Michelle Shapiro

The U.S. Food & Drug Administration’s (FDA’s) Voluntary National Retail Food Regulatory Program Standards (Retail Program Standards) are designed to help food regulatory programs enhance the services they provide to the public.

This post is part of NACCHO’s Retail Program Standards blog series showcasing the progress that communities across the country have made in retail food protection. Each month, we are featuring the experiences, challenges, and successes of jurisdictions that have worked toward each standard.

All jurisdictions featured have participated in NACCHO’s Retail Program Standards Mentorship Program, which provides peer-to-peer assistance and intensive technical support to help jurisdictions conform with the standards efficiently and effectively.

This month we are focusing on Standard 3: Inspection Program Based on Hazard Analysis Critical Control Point (HACCP) Principles, and we have responses from one jurisdiction:

  • Michelle Hansen, Voluntary National Retail Food Regulatory Program Standards (VNRFRPS) Program Manager, Marion County Public Health Department, Marion, IN

What steps did you take to get started in your work on Standard 3?

Hansen: When preparing for Standard 3, we began by completing the self-assessment. Many of our current practices already met the standardized requirements, so in an effort to conform, our major task was to reinforce the processes that were in place and document them. Fairfax County, our mentor in NACCHO’s Retail Program Standards Mentorship Program, played a key role in confirming that our written processes met the deliverables as per the Standard guidelines. They gave us the much-needed confidence that our work was on the right track.

What was your biggest challenge in working toward Standard 3, and how have you worked to overcome that challenge?

Hansen: There are many challenges as one works towards standardization and uniformity, many of which are related to documentation or the realization that there are gaps within the processes. Establishing and implementing written policies and addressing variance requests are part of this Standard, but our local level does not approve variance requests. Indiana State Department of Health (ISDH) shoulders that responsibility and then filters their variance approvals to our administrator, who in turn communicates them to our team for inspection purposes and regulation in the field. This presented a challenge. ISDH does not have a formal policy in place; however, they have all the tools available to document it. In an effort to comply and in discussions with our NACCHO mentor, we were able to work around this deliverable by documenting the ISDH variance request protocol, including their policy, definitions, scope, application for variance request, and flowchart, as well as the ISDH variance revocation processes.

Another challenge we face is not having the IN compliance, OUT of compliance, Not Applicable (NA), or Not Observed (NO) functionality to document the compliance status of each risk factor and intervention within our inspection software. This inhibits aspects of standardization because this type of inspection documentation is required within multiple standards. This challenge, though a prerequisite, does not stop us from moving forward. In fact, I feel that it helps us to refine our processes. As we incorporate a risk-based inspection process without the use of IN, OUT, NA, and NO and the defined line items, our team can continue to probe for food safety processes and systems.

What outcomes and benefits came out of working on Standard 3?

Hansen: I feel working on any of the Standards promotes communication, collaboration, and team building. Our department now understands the variance process, including what to look for and how to regulate it within our jurisdiction. I feel that the team is more supported to implement long-term corrective actions now that there is a written policy in place that can be referenced for establishment owners and operators. The HACCP process has been simplified, and the easy-to-follow “Cook & Chill” HACCP guides make the education process more streamlined. Questions are being answered, and better yet, questions are being asked.

How do you sustain momentum in your work on Standard 3?

Hansen: Our team is aware that the Standards are present in many, if not all, aspects of our food safety program, which prompts us to talk about areas that could use some attention. In the everyday questions pertaining to food safety, we discuss food processes, and Standards are sure to be in tow. It is becoming part of normal vernacular, which is the goal when standardization occurs.

What tips do you have for other jurisdictions working toward Standard 3?

Hansen: Take one deliverable at a time, and target ones that require discussions with your management team and/or inspection team. Make your processes realistic and gather input from key players for the best possible solution for all while adhering to jurisdictional regulations.

How has your work on the Retail Program Standards overall affected your community in terms of public health outcomes?

Hansen: The overall effect of the Standards on our community is still in process; our intervention implementation survey (Standard 9) will be conducted soon. However, we have noticed internal shifts. Data shows that our trainers have become more consistent in probing our establishments regarding their employee health policies. I also feel that it has shown on a more definitive level where we need to delve deeper into our inspection processes to produce a greater result.

Stay tuned for the next post, which will focus on Standard 4: Uniform Inspection Program, coming in January.

Contact Amy Chang at achang@naccho.org with any questions.


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About Michelle Shapiro

Michelle Shapiro is a communication specialist for the Environmental Health & Disability team at NACCHO.

More posts by Michelle Shapiro

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