Retail Program Standards Blog Series: Standard 1

This post is the second in a new Retail Program Standards blog series from NACCHO to showcase 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.

Note: The RFAs for the eighth cohort of the mentorship program are now available, and applications for both mentors and mentees are accepted through October 12, 2018. Learn more.

Last month we started with the Self-Assessment, and we now move on to Standard 1: Regulatory Foundation.

This post includes responses from two jurisdictions:

  • Erik Johnson, Environmental Health Specialist, Hoke County Health Department, Raeford, NC
  • Jeremy Fruk, Public Health Sanitarian II, Health Department of Northwest Michigan, Charlevoix, MI

What was your biggest challenge in working toward Standard 1, and how have you worked to overcome that challenge?

Johnson: The biggest challenge regarding Standard 1 was the sheer volume of statutes and rules that had to be carefully researched and understood to determine whether we were in conformance. In several instances, it was the combination of a multitude of statutes and/or rules that met the standard, not just one. Finding enough “quiet time” to wade through these legal documents and perform an accurate assessment was quite challenging.

How do you sustain momentum in your work on Standard 1?

Johnson: We sustain momentum by staying abreast of legislative changes and paying attention to upcoming and proposed changes to the FDA Food Code. Since working through Standard 1, I find that I am more interested in what our legislature is up to, and I follow the various bills as they work their way through the state house and senate. When a new bill is signed, I pay attention to what this means for our work and look to our state specialists for help in interpreting how our work will be impacted. Additionally, I feel it is important to contact legislators with my own professional opinions regarding proposed rules. I encourage others to do the same and consider attending meetings of the Conference for Food Protection and provide input to the updates to the FDA Food Code.

Fruk: To sustain momentum in Standard 1, the Health Department of Northwest Michigan (HDNW) must be committed to updating existing policies and regulating under future updated/revised food codes that coincide with Standard 1.

What tips do you have for other jurisdictions working toward Standard 1?

Johnson:

  1. Realize up front that Standard 1 is labor-intensive. To do it thoroughly is going to take some time. If you understand that up front it will help.
  2. Block off some time each week to work exclusively on Standard 1. I strongly suggest picking a time that is usually not hectic in your office and adding it to your schedule just like any other appointment, and then stick to it each week. You will be surprised how much you can accomplish.
  3. Utilize the work of those who have gone before you! I was extremely fortunate to have the prior work of several NC counties available to me to use as a template. Check out the Retail Food Program Standards Resource Center on FoodSHIELD for uploaded Standard 1 documents and contact your colleagues in other jurisdictions who have completed the standard. Be careful not to give in to the temptation to simply copy and paste others’ work for this standard, however, as going through each section of code yourself and finding the applicable statutes and rules will ultimately serve to increase your confidence in the field.
  4. Take advantage of the NACCHO mentorship grant program, your FDA retail food specialist, AFDO grant programs, etc. The mentorship program will allow you to have one-on-one time with experienced folks who have been through what you are doing and are willing to assist in any way.
  5. Volunteer to do an audit at some point. The exposure to retail food safety programs in other states has been eye-opening to me. If you pick up even one significant tip from each person you come across then you eventually have a wealth of knowledge to draw from.

Fruk: The ease or difficulty of meeting Standard 1 can vary from agency to agency. It is going to depend on the agencies’ existing policies and what food code they are currently using. My tip would be to review your existing policies and the food code and complete a self-assessment. Determine what does not meet Standard 1 and see what can be changed. Some changes may not be able to be done immediately; however, you are now aware of your gaps and can set goals and deadlines to meet Standard 1. I would also recommend attending an FDA Self-Assessment and Verification Audit Workshop. The workshop provided a very detailed overview of all the standards and the audit process.

How has your work on the Standard affected your community in terms of public health outcomes?

Johnson: Besides the obvious, but not insignificant, monetary benefits to our program from the grant money, the most lasting benefit has been the more comprehensive understanding of the regulatory foundation of what we do in the field. Before the work on Standard 1, many of the actions and behaviors I took each day such as entering an establishment for an inspection or issuing a notice of intent to suspend a permit were things I vaguely knew I had the legal right to do, but after discovering for myself the actual statutory authority in the law that delegates these rights, I have greater confidence to perform my job and know the limits of my authority so as not to exceed it as well. Surely it is our responsibility to know from where our authority derives and its limits.

We also have examples of a direct effect on our community. Like many areas, we have experienced increasing rates of illegal food sales with individuals cooking food in their homes and advertising on social media such as Facebook or Craigslist. The increased regulatory knowledge gained from our work on Standard 1 has allowed us to feel confident in planning strategies to address this problem by holding several “illegal catering” workshops as well as embarking on a multi-faceted marketing campaign to educate our community as to what is legal. Every person reached by this campaign is more informed and will hopefully spread the word to others, eventually resulting in a reduction in these types of illegal sales.

I cannot over-emphasize the importance of working on Standard One. There is a reason it is the first standard.

Fruk: Standard 1 helped HDNW gain momentum in meeting additional standards. Therefore, Standard 1 has affected our community indirectly, but again has given our agency momentum to start other standards that will have a positive impact on our community.

Stay tuned for the next post, which will focus on Standard 2: Trained Regulatory Staff, coming in October.

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

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