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Voluntary National Retail Food Regulatory Program Standards

ProgramStandards2022-VNRFRPS-Compiledupdate

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Voluntary National Retail Food
Regulatory Program Standards

2022
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Food Safety and Applied Nutrition
College Park, MD 20740

Voluntary National Retail Food Regulatory Program Standards – January 2022

PAPERWORK REDUCTION ACT OF 1995
This document contains information collection provisions that are subject to review by the Office of
Management and Budget (OMB) under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). The
time required to complete this information collection is estimated to average 94.29 annual hours per
recordkeeper for each enrolled jurisdiction to complete the management tasks for recordkeeping for selfassessment, risk factor study, and verification audit. FDA estimates a total of 30 minutes annually for each
enrolled jurisdiction to complete the following: FDA Form 3598, ``FDA National Registry Report,'' and
“Documentation of Successful Completion – Field Training Process” forms. FDA's recordkeeping and
reporting burden estimate includes time required for a state, local, or tribal agency to review the
instructions in the Program Standards, compile information from existing sources, and create any records
recommended in the Program Standards that are not already kept in the normal course of the agency's usual
and customary activities. Worksheets are provided to assist in this compilation. Send comments regarding
this burden estimate or suggestions for reducing this burden to: Office of Food Safety, Retail Food
Protection Staff, (HFS-320), Center for Food Safety and Applied Nutrition, Food and Drug Administration,
5001 Campus Drive, College Park, MD 20740.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. The OMB control number for this
information collection is 0910-0621 (expires 09-30-2023).

COMMENTS AND INQUIRIES
To promote uniform and reasonable application of these Standards, interested persons are invited to
submit comments and inquiries to their FDA Retail Food Specialist or to the Retail Food Policy Team
in the FDA Center for Food Safety and Applied Nutrition at: [email protected].

Voluntary National Retail Food Regulatory Program Standards – January 2022

Table of Contents
INTRODUCTION TO THE STANDARDS
Introduction ...................................................................................................................................................... i
Purpose ............................................................................................................................................................ ii
Scope ............................................................................................................................................................... ii
History ............................................................................................................................................................ iii
Impact on Program Resources........................................................................................................................ iii
Comments and Inquiries................................................................................................................................. iii
DEFINITIONS
Definitions ...................................................................................................................................................... iv
STANDARD 1: REGULATORY FOUNDATION
Standard 1: Regulatory Foundation.............................................................................................................. 1-1
Standard 1: Self-Assessment and Verification Audit Form ......................................................................... 1-4
Standard 1: Self-Assessment Worksheet for Part I .................................................................................... 1-11
Standard 1: Self-Assessment Worksheet for Part II ................................................................................... 1-26
Standard 1: Self-Assessment Worksheet for Part III ................................................................................. 1-59
Standard 1: Verification Audit Worksheet for Part I ................................................................................. 1-64
Standard 1: Verification Audit Worksheet for Part II ................................................................................ 1-69
Standard 1: Verification Audit Worksheet for Part III ............................................................................... 1-73
STANDARD 2: TRAINED REGULATORY STAFF
Standard 2: Trained Regulatory Staff........................................................................................................... 2-1
Standard 2: Self-Assessment and Verification Audit Form ....................................................................... 2-11
Standard 2: Self-Assessment Instructions and Worksheet ......................................................................... 2-17
Standard 2: Verification Audit Instructions and Worksheet ...................................................................... 2-21
Appendix B-1: Curriculum for Retail Food Safety Inspection Officers .................................................... 2-26
Appendix B-2: CFP Field Training Manual............................................................................................... 2-29
Appendix B-3: Retail Food Establishment Categories .............................................................................. 2-30
STANDARD 3: INSPECTION PROGRAM BASED ON HACCP PRINCIPLES
Standard 3: Inspection Program Based on HACCP Principles .................................................................... 3-1
Standard 3: Self-Assessment and Verification Audit Form ......................................................................... 3-4
STANDARD 4: UNIFORM INSPECTION PROGRAM
Standard 4: Uniform Inspection Program .................................................................................................... 4-1
Standard 4: Self-Assessment and Verification Audit Form ......................................................................... 4-5
Standard 4: Self-Assessment Instructions and Worksheet ......................................................................... 4-15

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 5: FOODBORNE ILLNESS AND FOOD DEFENSE PREPAREDNESS AND
RESPONSE
Standard 5: Foodborne Illness and Food Defense Preparedness and Response .......................................... 5-1
Standard 5: Self-Assessment and Verification Audit Form ......................................................................... 5-6
STANDARD 6: COMPLIANCE AND ENFORCEMENT
Standard 6: Compliance and Enforcement ................................................................................................... 6-1
Standard 6: Self-Assessment and Verification Audit Form ......................................................................... 6-4
Standard 6: Self-Assessment Instructions and Worksheet ........................................................................... 6-9
Standard 6: Verification Audit Instructions and Worksheet ...................................................................... 6-27
Standard 6: Explanation of Statistical Model ............................................................................................. 6-36
Standard 6: Standardized Key Crosswalk to the 2017 Food Code ............................................................ 6-37
STANDARD 7: INDUSTRY AND COMMUNITY RELATIONS
Standard 7: Industry and Community Relations .......................................................................................... 7-1
Standard 7: Self-Assessment and Verification Audit Form ......................................................................... 7-4
Standard 7: Self-Assessment Instructions and Worksheet ........................................................................... 7-9
STANDARD 8: PROGRAM SUPPORT AND RESOURCES
Standard 8: Program Support and Resources ............................................................................................... 8-1
Standard 8: Self-Assessment and Verification Audit Form ......................................................................... 8-5
Standard 8: Self-Assessment Instructions and Worksheet ......................................................................... 8-12
STANDARD 9: PROGRAM ASSESSMENT
Standard 9: Program Assessment ................................................................................................................. 9-1
Standard 9: Self-Assessment and Verification Audit Form ......................................................................... 9-5
APPENDIX 1: SUMMARY OF CHANGES

Voluntary National Retail Food Regulatory Program Standards – January 2022

INTRODUCTION TO THE STANDARDS
INTRODUCTION
Achieving national uniformity among regulatory programs responsible for retail food protection in the
United States has long been a subject of debate among the industry, regulators, and consumers.
Adoption of the FDA Food Code at the state, local and tribal level has been a keystone in the effort to
promote greater uniformity. However, a missing piece has been a set of widely recognized standards for
regulatory programs that administer the Food Code. To meet this need FDA has developed the
“Voluntary National Retail Food Regulatory Program Standards” (Retail Program Standards) through
ideas and input from federal, state, and local regulatory officials, industry, trade and professional
associations, academia, and consumers on what constitutes a highly effective and responsive retail food
regulatory program.
In March of 1996, the FDA hosted a meeting to explore ways in which its retail food protection program
could be improved. Participants in the meeting included FDA Retail Food Specialists, FDA headquarters
personnel, state, and local regulatory officials from the six FDA regions, the president of the Association
of Food & Drug Officials, and industry representatives. Following that meeting, FDA established a
National Retail Food Team comprised of the Regional Retail Food Specialists, CFSAN personnel and
other FDA personnel directly involved in retail food protection. A Retail Food Program Steering
Committee was established and tasked with leading the team to respond to the direction given by the
participants in the meeting, i.e., providing national leadership, being equal partners, being responsive,
providing communication and promoting uniformity.
The Steering Committee was charged with developing a five-year operational plan for FDA’s retail food
program. The Steering Committee was also charged with ensuring the operational plan was in keeping
with the goals and mission of the President’s Food Safety Initiative. FDA solicited input from the
regulatory community, industry, and consumers in developing the plan. The resulting Operational Plan
charted the future of the National Retail Food Program and prompted a reassessment of the respective
roles of all stakeholders and how best to achieve program uniformity.
From the goals established in that first Operational Plan, two basic principles emerged on which to build
a new foundation for the retail program:
•
•

Promote active managerial control of the risk factors most commonly associated with foodborne
illness in food establishments, and
Establish a recommended framework for retail food regulatory programs within which the active
managerial control of the risk factors can best be realized.

These principles led to the drafting of standards that encourage voluntary participation by the regulatory
agencies at the state, local, and tribal level. The Program Standards were developed with input obtained
through a series of meetings over a two-year period including: the 1996 stakeholders meeting, FDA
Regional Seminars, meetings with state officials hosted by the Retail Food Specialists, and six Grassroots
Meetings held around the country in 1997. Valuable input from industry associations, associations of
regulatory officials, and others was also obtained. The Retail Program Standards were provided to the
Conference for Food Protection for further input and to achieve broad consensus among all stakeholders.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

In developing the Retail Program Standards, FDA recognized that the ultimate goal of all retail food
regulatory programs is to reduce or eliminate the occurrence of illnesses and deaths from food produced
at the retail level and that there are different approaches toward achieving that goal. Federal, state, local,
and tribal agencies continue to employ a variety of mechanisms with differing levels of sophistication in
their attempt to ensure food safety at retail.
While the Retail Program Standards represent the effective, focused food safety program to which we
ultimately aspire, they begin by providing a foundation and system upon which all regulatory programs
can build through a continuous improvement process. The Standards encourage regulatory agencies to
improve and build upon existing programs. Further, the Standards provide a framework designed to
accommodate both traditional and emerging approaches to food safety. The Retail Program Standards
are intended to reinforce proper sanitation (good retail practices) and operational and environmental
prerequisite programs while encouraging regulatory agencies and industry to focus on the factors that
cause and contribute to foodborne illness, with the ultimate goal of reducing the occurrence of those
factors.
PURPOSE
The Retail Program Standards serve as a guide to regulatory retail food program managers in the design
and management of a retail food regulatory program and provide a means of recognition for those
programs that meet these standards. Program managers and administrators may establish additional
requirements to meet individual program needs.
The Retail Program Standards are designed to help food regulatory programs enhance the services they
provide to the public. When applied in the intended manner, the Program Standards should:
•
•
•
•
•
•

Identify program areas where an agency can have the greatest impact on retail food safety
Promote wider application of effective risk-factor intervention strategies
Assist in identifying program areas most in need of additional attention
Provide information needed to justify maintenance or increase in program budgets
Lead to innovations in program implementation and administration
Improve industry and consumer confidence in food protection programs by enhancing uniformity
within and between regulatory agencies

Each Standard has one or more corresponding worksheets, forms, and guidance documents. Regulatory
agencies may use existing, available records or may choose to develop and use alternate forms and
worksheets that capture the same information.
SCOPE
The Retail Program Standards apply to the operation and management of a retail food regulatory
program that is focused on the reduction of risk factors known to cause or contribute to foodborne illness
and to the promotion of active managerial control of these risk factors. The results of a self- assessment

Voluntary National Retail Food Regulatory Program Standards – January 2022

against the Standards may be used to evaluate the effectiveness of food safety interventions implemented
within a jurisdiction. The Standards also provide a procedure for establishing a database on the occurrence
of risk factors that may be used to track the results of regulatory and industry efforts over time.
HISTORY
The Retail Program Standards were pilot tested in each of the five FDA regions in 1999. Each regulatory
participant reported the results at the 2000 Conference for Food Protection. Improvements to the
Standards were incorporated into the January 2001 version based on input from the pilot participants.
Further refinements to the Standards were made in subsequent drafts leading up to the endorsement of the
March 2002 version of the Retail Program Standards by the 2002 Conference for Food Protection.
Subsequent changes and enhancements have been made following concurrence of the stakeholders at the
biennial meetings of the Conference for Food Protection.
In maintaining these standards, FDA intends to allow for and encourage new and innovative approaches
to the reduction of factors that are known to cause foodborne illness. Program managers and other health
professionals participating in this voluntary program who have demonstrated means or methods other
than those described here may submit those to FDA for consideration and inclusion in the Retail Program
Standards. Improvements to future versions of the Standards will be made through a process that
includes the Conference for Food Protection to allow for constant program enhancement and promotion
of national uniformity.
IMPACT ON PROGRAM RESOURCES
During pilot testing of the Retail Program Standards in 1998, some jurisdictions reported that the selfassessment process was time consuming and could significantly impact an agency’s resources.
Collection, analysis, and management of information for the database Occurrence of Risk Factor Studies
were of special concern. However, participating jurisdictions also indicated that the resource
commitment was worthwhile and that the results of the self-assessment were expected to benefit their
retail food protection program. Advance planning is recommended before beginning the data collection
process in order to use resources efficiently. In addition, changes to the Standards now allow
jurisdictions to use routine inspection data for analysis on the occurrence of risk factors, significantly
reducing the resource requirements for separate data collection.
It is further recommended that jurisdictions not attempt to make program enhancements during the selfassessment process. A better approach is to use the self-assessment to identify program needs and then
establish program priorities and plans to address those needs as resources become available.
COMMENTS AND INQUIRIES
To promote uniform and reasonable application of these Standards, interested persons are invited to
submit comments and inquiries to their FDA Retail Food Specialist or to the Retail Food Protection Team
in the FDA Center for Food Safety and Applied Nutrition at: [email protected].

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Voluntary National Retail Food Regulatory Program Standards
DEFINITIONS

The following definitions apply in the interpretation and application of these Standards.
1) Active Managerial Control – The purposeful incorporation of specific actions or procedures by
industry management into the operation of a business to attain control over foodborne illness risk
factors.
2) Auditor – Any authorized city, county, district, state, federal, tribal, or other third-party person who
has no responsibilities for the day-to-day operations of that jurisdiction and is charged with
conducting a verification audit, which confirms the accuracy of the self-assessment.
3) Baseline Survey – See Risk Factor Study.
4) Candidate - A regulatory officer whose duties include the inspection of retail food establishments.
5) Compliance and Enforcement – Compliance includes all voluntary or involuntary conformity with
provisions set forth by the regulatory authority to safeguard public health and ensure that food is safe.
Enforcement includes any legal and/or administrative procedures taken by the regulatory authority to
gain compliance.
6) Confirmed Foodborne Disease Outbreak – means a foodborne disease outbreak in which
laboratory analysis of appropriate specimens identifies a causative agent and epidemiologic analysis
implicates the food as the source of the illness or epidemiological analysis alone implicates the food
as the source of the illness.
7) Direct Regulatory Authority (DRA) – The organizational level of government that is immediately
responsible for the management of the retail program. This may be at the city, county, district, state,
federal, territorial, or tribal level.
8) Enforcement Actions – Actions taken by the regulatory authority such as, but not limited to, warning
letters, revocation or suspension of permit, court actions, monetary fines, hold orders, destruction of
food, etc., to correct a violation found during an inspection.
9) Follow-up Inspection – An inspection conducted after the initial routine inspection to confirm the
correction of a violation(s).
10) Food Code Interventions – the preventive measures to protect consumer health stated below:
1. management's demonstration of knowledge;
2. employee health controls;
3. controlling hands as a vehicle of contamination;
4. time / temperature parameters for controlling pathogens; and
5. consumer advisory.
11) Food-Related Injury – Means an injury from ingesting food containing a physical hazard such as
bone, glass, or wood.
12) Foodborne Disease Outbreak – The occurrence of two or more cases of a similar illness resulting
from the ingestion of a common food.
13) Good Retail Practices (GRP's) – Preventive measures that include practices and procedures to
effectively control the introduction of pathogens, chemicals, and physical objects into food, that are
prerequisites to instituting a HACCP or Risk Control Plan and are not addressed by the FDA Food Code
interventions or risk factors.
14) Hazard – A biological, chemical, or physical property that may cause food to be unsafe for
human consumption.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

15) National Registry of Retail Food Protection Programs (National Registry) – A listing of retail
food safety programs that have voluntarily enrolled as participants in the Voluntary National Retail
Food Regulatory Program Standards.
16) Person in charge (PIC) – The individual present at a food establishment who is responsible for the
operation at the time of inspection.
17) Program Element – One of the program areas for which a National Standard has been established
such as regulations, training, inspection system, quality assurance, foodborne illness investigation,
compliance and enforcement, industry and consumer relations, and program resources.
18) Program Manager – The individual responsible for the oversight and management of a retail food
regulatory program.
19) Quality Records – Documentation of specific elements of program compliance with the National
Standards as specified in each Standard.
20) Risk Control Plan (RCP) – a concisely written management plan developed by the retail or food
service operator with input from the health inspector that describes a management system for
controlling specific out-of-control risk factors.
21) Risk Factors – the improper employee behaviors or improper practices or procedures in retail food
and food service establishments stated below which are most frequently identified by epidemiological
investigation as contributing to foodborne illness or injury:
1. improper holding temperature;
2. inadequate cooking;
3. contaminated equipment;
4. food from unsafe source; and
5. poor personal hygiene.
22) Risk Factor Study (formerly Baseline Survey) – A study on the occurrence of foodborne illness risk
factors within institutional, foodservice, restaurants, and retail food facility types under a
jurisdiction’s regulatory authority. Criteria for a Risk Factor Study are detailed in Standard 9,
including at a minimum:
1. Data Collection, analysis, and a written report;
2. A collection instrument with data items pertaining to the five foodborne illness risk factors;
3. A collection instrument that uses the convention of IN, OUT, NA and NO to document
observations;
4. All facility types identified by FDA’s national study that are under the jurisdiction’s
regulatory authority; and
5. Studies subsequent to the initial study repeated at 5-year intervals.
23) Routine Inspection – A full review and evaluation of a food establishment's operations and facilities
to assess its compliance with Food Safety Law, at a planned frequency determined by the regulatory
authority. This does not include re-inspections and other follow-up or special investigations.
24) Self-Assessment – An internal review by program management to determine whether the existing retail
food safety program meets the Voluntary National Retail Food Regulatory Program Standards.
25) Self-Assessment Update – Comparison of one or more program elements against the Voluntary
National Retail Food Regulatory Program Standards between the required 60-month periodic selfassessment.

Voluntary National Retail Food Regulatory Program Standards – January 2022

26) Standardization Inspection – An inspection used to demonstrate a candidate's knowledge,
communication skills, and ability to identify violations of all regulatory requirements and to
develop a risk control plan for identified, uncontrolled risk factors.
27) Suspect Foodborne Outbreak – Means an incident in which two or more persons experience a
similar illness after ingestion of a common food or eating at a common food
establishment/gathering.
28) Trainer – An individual who has successfully completed the following training elements as
outlined in Steps 1 – 3, Standard 2, and is recognized by the program manager as having the field
experience and communication skills necessary to train new employees.
1. Satisfactory completion of the prerequisite curriculum;
2. Completion of a field training process similar to that contained in Appendix B-2; and
3. Completion of a minimum of 25 independent inspections and satisfactory completion
of the remaining course curriculum.
29) Training Standard – An individual who has successfully completed the following training
elements AND standardization elements in Standard 2 and is recognized by the program manager
as having the field experience and communication skills necessary to train new employees. The
training and standardization elements include:
1. Satisfactory completion of the prerequisite curriculum;
2. Completion of a field training process similar to that contained in Appendix B-2;
3. Completion of a minimum of 25 independent inspections and satisfactory completion
of the remaining course curriculum;
4. Successful completion of a standardization process based on a minimum of eight
inspections that includes development of HACCP flow charts, completion of a risk
control plan, and verification of a HACCP plan, similar to the FDA standardization
procedures;
5. Completion of a minimum of 20 contact hours of continuing education in food safety
every 36 months after the initial training is completed as outlined in Standard 2; and
6. Standardization maintained every three (3) years as outlined in Standard 2.
30) Verification Audit – A systematic, independent examination by an external party to confirm the
accuracy of the Self-Assessment.

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1 REGULATORY FOUNDATION

Table of Contents

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STANDARD 1 REGULATORY FOUNDATION
This standard applies to the regulatory foundation used by a retail food program. Regulatory foundation
includes any statute, regulation, rule, ordinance, or other prevailing set of regulatory requirements that
governs the operation of a retail food establishment.
Requirement Summary
The regulatory foundation includes provisions for:
1. The public health interventions contained in the current published edition of the Food Code
or one of the two most recent previous editions of the Food Code;
2. Control measures for the risk factors known to contribute to foodborne illness;
3. Good Retail Practices (GRP’s) at least as stringent as the Food Code edition as specified in 1
above; and
4. Compliance and enforcement at least as stringent as the selected provisions from Food Code
and Annex 1 of the Food Code edition as specified in 1 above.
Description of Requirement
A. Food Code Interventions and Risk Factor Control Measures
The regulatory foundation contains provisions that are at least as stringent as the public health
interventions and the provisions that control risk factors known to contribute to foodborne illness
contained in the current published edition of the Food Code or one of the two most recent previous
editions of the Food Code. Jurisdictions that meet Standard 1 but who may become noncompliant due
to the release of a new edition of the Food Code are considered to continue meeting the Standard for a
period of two years from the release date of the new Food Code edition in order to complete the
process of updating its regulations.
To meet this element of the Standard, regulations must have a corresponding requirement for the Food
Code sections as listed and summarized in the Standard 1: Self-Assessment Worksheet for Part I, from
#1 “Demonstration of Knowledge” through #11 “Highly Susceptible Populations.” For initial listing,
the regulatory foundation must contain at least 9 of the 11 interventions and risk factor controls. In
order to meet fully the requirements of the Standard, the regulatory foundation must meet all 11 of the
interventions and risk factor controls by the third audit.
B. Good Retail Practices
The regulations contain provisions that address Good Retail Practices that are at least as stringent as
those described in the edition of the Food Code as specified in A. To meet this element of the
Standard, regulations must have a corresponding requirement for 95 percent of the Food Code
sections as listed and summarized in the Standard 1: Self-Assessment Worksheet for Part II, from #12
“Personnel” through #37 “Variance for Smoking.”

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C. Compliance and Enforcement
The regulations contain provisions that address Compliance and Enforcement requirements that are at
least as stringent as those contained in the edition of the Food Code as specified in A. To meet this
element of the Standard, regulations must have a corresponding requirement for each of the Food
Code sections as listed in the Standard 1: Self-Assessment Worksheet for Part III, items 1 through 12;
except item 12 pertaining to “Legal Remedies,” where only one of the sections pertaining to criminal,
injunctive, or civil penalties is required.
Outcome
The desired outcome of this standard is the adoption of a sound, science-based regulatory foundation for
the public health program and the uniform regulation of industry.
Documentation
The quality records needed for this standard include:
1. The statute, regulation, rule, ordinance, or other prevailing set of regulatory requirements that govern
the operation of a retail food establishment; and
2. The completed Standard 1: Program Self-Assessment and Verification Audit Form.
3. The completed Standard 1: Self-Assessment Worksheet for:
• Part I – Food Code Intervention and Risk Factor Controls
• Part II – Good Retail Practices
• Part III – Compliance and Enforcement

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STANDARD 1 - REGULATORY FOUNDATION
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment and Verification Audit Form
The Standard 1: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process. The form is included at the end of
these instructions. Whether one is performing a program self-assessment or conducting a verification audit,
it is recommended that the form be available as a reference to the Standard 1 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of the Regulatory Foundation component must indicate on the
form if each of the listed Standard 1 criteria are met. These responses are recorded under the column
“Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use this form. An equivalent form or process is acceptable provided that
the results of the jurisdiction’s self-assessment for the specific Standard 1 criteria listed on this form are
available for review.
The Standard 1: Program Self-Assessment and Verification Audit Form is divided into four sections:
1. Assessment of the Program's Regulatory Foundation;
2. Food Code Interventions and Risk Factors;
3. Good Retail Practices; and
4. Compliance and Enforcement.
The self-assessor must review each Standard 1 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must place an
“X” in the “YES” box under the “Jurisdiction’s Self-Assessment” column of the Standard 1: Program SelfAssessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 1 criteria are met, the
self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column of the
Standard 1: Program Self-Assessment and Verification Audit Form. The self-assessor may specify why the
criteria are not met in the box provided.
The self-assessor should review the findings on the Standard 1: Program Self-Assessment and Verification
Form to ensure accuracy. The jurisdiction must provide the auditor with their completed Standard 1:
Program Self-Assessment and Verification Audit Form and any worksheets or documents used to support
and demonstrate that the Standard 1 criteria have been met.
Once all the criteria have been reviewed and documented on the form, the self-assessor must complete the
Program Self-Assessment Summary section on page one of the Standard 1: Program Self- Assessment and
Verification Audit Form. The self-assessor must
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Voluntary National Retail Food Regulatory Program Standards – January 2022

• Enter their contact information;
• Document if the jurisdiction met the Standard 1 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 1 criteria.
Documenting the Findings from the Verification Audit
The self-assessor must provide their completed Standard 1: Program Self-Assessment and Verification
Audit Form to the auditor for review. The auditor must indicate on the Standard 1: Program SelfAssessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “NO” box under the “Auditor’s
Verification” column on the form. The verification auditor must specify why the criterion is not met in the
box provided. Supplemental pages may be used to explain findings.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the on-site visit. In particular, any
Standard 1 criteria for which the auditor cannot confirm through a review of the self-assessment should be
thoroughly discussed. Ample time should be allotted to ensure that there is a clear understanding of the
reasons for the “non-conforming” finding. The auditor should be prepared to identify the elements required
for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on page one of the Standard 1: Program Self-Assessment and Verification Audit
Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 1 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 1 criteria if the auditor does not confirm the self-assessment
findings.

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Standard 1: Regulatory Foundation
Program Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 1 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 1
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 1 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 1 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
1 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 1 is true and correct.
Signature of the Verification Auditor:

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Standard 1: Regulatory Foundation
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: _________________________________________________________________________________________________________
Criteria

1. Assessment
of the
Program’s
Regulatory
Foundation

1-7

Element
a) The jurisdiction has
documentation that it has
performed a side-by-side
comparison of its prevailing
statutes, regulations, rules, and
other pertinent requirements
against the current published
edition of the FDA Food Code
or one of the two most recent
previous editions of the FDA
Food Code.
b) The jurisdiction’s side-byside comparison includes an
assessment of major Food
Code Interventions and Risk
Factors, Good Retail Practices,
and Compliance/ Enforcement
Administrative requirements.

Jurisdiction’s
SelfAssessment
YES

Jurisdiction’s
SelfAssessment
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
Verification
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

1. Assessment
of the
Program’s
Regulatory
Foundation

c) The regulatory foundation
assessment clearly identifies
the jurisdiction's
corresponding requirement to
the applicable Code section.
The assessment provides a
determination as to whether a
specific provision in the
jurisdiction's regulation
meets the intent of the
corresponding FDA Food
Code section.

2. Food Code
Interventions
and Risk
Factors

a) The jurisdiction’s initial Food
Code assessment indicates that
the agency's regulatory
requirements contain at least 9
of the 11 FDA Food Code
intervention and risk factor
controls. By the third
verification audit the
jurisdiction's assessment
indicates that the agency's
regulatory requirements contain
all 11 of the FDA Food Code
intervention and risk factor
controls.

Part I - Self-Assessment
Worksheet
Part I - Verification Audit
Worksheet

1-8

Jurisdiction’s
SelfAssessment
YES

Jurisdiction’s
SelfAssessment
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
Verification
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

2. Food Code
Interventions
and Risk
Factors

3. Good
Retail
Practices

1-9

Element
b) The jurisdiction’s Food
Code assessment indicates
that the agency has a
corresponding requirement
for ALL (9/11 or 11/11) FDA
Food Code provisions related
to the interventions and risk
factor controls.
NOTE: Auditor's random
selection of Food Code
Intervention and Risk Factor
Control Sections confirms the
jurisdiction's assessment that
a corresponding requirement
is contained in the agency's
rules, regulations,
ordinances, code, or statutes.
a) The jurisdiction's Food
Code assessment indicates
that regulatory requirements
contain at least 95 percent of
the FDA Food Code Good
Retail Practices Sections.
NOTE: Auditor's random
selection of Good Retail
Practices Code Sections
confirms the jurisdiction's
assessment that a
corresponding requirement is
contained in the agency's
code or statutes.
Documentation from:
Part II - Self-Assessment
Worksheet
Part II - Verification Audit
Worksheet

Jurisdiction’s
SelfAssessment
YES

Jurisdiction’s
SelfAssessment
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
Verification
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element
a) The jurisdiction's Food
Code assessment indicates
that regulatory requirements
contain ALL the FDA Food
Code Compliance and
Enforcement Sections
identified in the Standard.

4. Compliance
and
Enforcement

1-10

Jurisdiction’s
SelfAssessment
YES

Jurisdiction’s
SelfAssessment
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
Verification
NO

NOTE: Auditor's random
selection of Compliance and
Enforcement Code Sections
confirms the jurisdiction's
assessment that a
corresponding requirement is
contained in the agency's
code or statutes.
Documentation from:
Part III - Self Assessment
Worksheet
Part III - Verification Audit
Worksheet
GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1 - REGULATORY FOUNDATION
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELFASSESSMENT
Part I – Food Code Interventions and Risk Factor Controls
STEP 1 – Review Food Code Interventions and Risk Factor Controls
The jurisdiction’s regulatory foundation must contain requirements that are at least as stringent as the
public health interventions/risk factor provisions contained in the FDA Food Code. Part I of the
Standard 1: Self-Assessment Worksheet, included at the end of these instructions, contains 11 public
health interventions and risk factor controls:
1. Demonstration of Knowledge
2. Employee Health
3. Consumer Advisory
4. Approved Source
5. Time/Temperature
6. Protection from Contamination
7. Control of Hands as a Vehicle of Contamination
8. Good Hygienic Practices
9. Chemical
10. Conformance with Approved Procedures
11. Highly Susceptible Populations
To meet any one of the 11 elements described above, the self-assessment must indicate that the
jurisdiction’s regulatory requirements address each Food Code section listed under that element.
STEP 2 - Conduct the Self-Assessment for Part I
The self-assessor must compare the jurisdiction’s code, regulation or ordinance with the Food Code
sections grouped under each of the 11 public health interventions and risk factor control measures listed in
Part I of the Standard 1: Self-Assessment Worksheet. For each Food Code section, the self-assessor must:
•

Record the corresponding jurisdiction requirement; and

Document his/her determination:
- If Full Intent of the Food Code section is met, place an "X" in the appropriate column.
- If Partial Intent of the Food Code section is met, identify language that is not included
with the jurisdiction's requirement. Indicate whether the language is addressed in another
jurisdiction statute, ordinance, or regulatory requirement.
• If No corresponding regulation exists, indicate "No Compliance" in the appropriate column and
provide any information that may explain why it is not part of the jurisdiction's current requirements.
•

1-11

Voluntary National Retail Food Regulatory Program Standards – January 2022

STEP 3 – Document the Self-Assessment Results for Part I
A summary table is provided in Part I of the Standard 1: Self-Assessment Worksheet to document the
results of the self-assessment for each of the 11 public health intervention and risk factor control
measures. For each public health intervention and risk factor control measure, the self-assessor must
record the findings from the self-assessment. If each Food Code section listed under an Intervention/ Risk
Factor has a check in the “Full Intent is Met” column, the Standard criteria is met. Place an “X” in the
Self-Assessment Results “YES” column.
If any of the Food Code sections are missing, or the jurisdiction's regulatory requirements only partially
meet the intent of the language, place an “X” in the Self-Assessment Results “NO”
column for that intervention/risk factor control measure.
At the bottom of Part I of the Standard 1: Self-Assessment Worksheet, the self-assessor must record the
jurisdiction’s name and the number of interventions/risk factors that are met. For initial participation and
listing purposes, the jurisdiction’s self-assessment must indicate conformance with at least 9 of the 11
intervention/risk factor categories. By the third verification audit, the jurisdiction must meet 11 of the 11
intervention/risk factor control categories in order to meet the Standard 1 criteria.
Examples of documents that may be reviewed:
 The jurisdiction’s statute, regulation, rule, ordinance, or other prevailing set of regulatory
requirements that govern the operation of its food establishments
 Version of the Food Code that was used for the self-assessment
 Completed Standard 1: Self-Assessment Worksheet
* Part I – Food Code Interventions and Risk Factor Controls
 If applicable, documents discussing or comparing code provisions excepted if adoption was made by
reference with exceptions.

1-12

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation
Self-Assessment Worksheet
PART I – 2017 Food Code: Interventions and Risk Factor Controls
SECTION 1 – DEMONSTRATION OF KNOWLEDGE

Food Code Section

2-101.11 – Assignment

2-102.11 – Demonstration

2-102.12 – Certified Food
Protection Manager

2-103.11 – Person in Charge

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent
is Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

YES
Full Intent
is Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

SECTION 2 – EMPLOYEE HEALTH
Food Code Section
5.

2-201.11 – Responsibility of
Permit Holder, Person in
Charge, and Conditional
Employees

1-13

Jurisdiction's
Corresponding Code
Section, Rule, etc.

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

2-201.12 – Exclusions and
Restrictions

2-201.13 – Removal,
Adjustment, or Retention of
Exclusions and Restrictions

2-501.11– Clean-up of
Vomiting and Diarrheal
Events

Jurisdiction's
YES
Corresponding Code Full Intent is
Section, Rule, etc.
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

SECTION 3 – CONSUMER ADVISORY
Food Code Section

3-603.11 – Consumption of
Animal Foods that are Raw,
Undercooked, or Not Otherwise
Processed to Eliminate
Pathogens

1-14

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 4 – APPROVED SOURCE

Food Code Section

10. 3-201.11 – Compliance with
Food Law
11. 3-201.12 – Food in a
Hermetically Sealed
Container
12. 3-201.13 – Fluid Milk and Milk
Products
13. 3-202.13 – Eggs
14. 3-202.14 – Eggs and Milk
Products, Pasteurized
15. 5-101.13 – Bottled Drinking
Water
16. 3-201.14 – Fish
17. 3-201.15 – Molluscan Shellfish

18. 3-201.16 – Wild Mushrooms

19. 3-201.17 – Game Animals

1-15

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

20. 3-101.11 – Safe,
Unadulterated, and
Honestly Presented
21. 3-202.11 – Temperature

22. 3-202.15 – Package Integrity

23. 3-202.18 – Shellstock
Identification
24. 3-203.12 – Shellstock,
Maintaining Identification

25. 3-402.11 – Parasite Destruction

26. 3-402.12 – Records, Creation,
and Retention

27. 3-202.110 – Juice Treated

1-16

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 5 – TIME/TEMPERATURE

Food Code Section

28. 3-401.11 – Raw Animal Foods
29. 3-401.12 – Microwave
Cooking
30. 3-401.14 – Non-Continuous
Cooking of Raw Animal Foods
31. 3-403.11 – Reheating for Hot
Holding
32. 3-501.14 – Cooling
33. 3-501.15 – Cooling Method
34. 3-501.16 – Time/Temperature
Control for Safety Food, Hot
and Cold Holding
35. 3-501.17 – Ready-to-Eat,
Time/Temperature Control for
Safety Food, Date Marking
36. 3-501.18 – Ready-to-Eat,
Time/Temperature Control for
Safety Food, Disposition
37. 3-501.19 – Time as a Public
Health Control

1-17

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 6 – PROTECTION FROM CONTAMINATION

Food Code Section

38. 3-301.12 – Preventing
Contamination When Tasting
39. 3-302.11 –
Packaged/Unpackaged Food –
Separation, Packaging, and
Segregation
40. 3-304.11 – Food Contact with
Equipment and Utensils
41. 3-306.14 – Returned Food and
Re-Service of Food
42. 3-701.11 – Discarding or
Reconditioning Unsafe,
Adulterated, or Contaminated
Food
43. 4-201.12 – Food Temperature
Measuring Devices
44. 4-501.111 – Manual
Warewashing Equipment, Hot
Water Sanitization
Temperatures
45. 4-501.112 – Mechanical
Warewashing Equipment, Hot
Water Sanitization
Temperatures
46. 4-501.113 – Mechanical
Warewashing Equipment,
Sanitization Pressure

1-18

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section
47. 4-501.114 – Manual and
Mechanical Warewashing
Equipment, Chemical
Sanitization – Temperature,
pH, Concentration, and
Hardness
48. 4-501.115 – Manual
Warewashing Equipment,
Chemical Sanitization Using
Detergent-Sanitizers
49. 4-601.11 – Equipment, FoodContact Surfaces, Non-FoodContact Surfaces, and
Utensils
50. 4-602.11 - Equipment FoodContact Surfaces and Utensils
51. 4-602.12 – Cooking and
Baking Equipment
52. 4-702.11 – Before Use After
Cleaning
53. 4-703.11 – Hot Water and
Chemical

1-19

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 7 – CONTROL OF HANDS AS A VEHICLE OF CONTAMINATION

Food Code Section

54. 2-301.11 – Clean Condition

55. 2-301.12 – Cleaning Procedure
56. 2-301.14 – When to Wash
57. 2-301.15 – Where to Wash

58. 2-301.16 – Hand Antiseptics
59. 3-301.11 – Preventing
Contamination from Hands
60. 5-203.11 – Handwashing Sinks
(Numbers/ Capacities)
61. 5-204.11 – Handwashing Sinks
(Location/ Placement)
62. 5-205.11 – Using a
Handwashing Sink
63. 6-301.11 – Handwashing
Cleanser, Availability

1-20

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

64. 6-301.12 – Hand Drying
Provision
65. 6-301.13 – Handwashing Aids
and Devices, Use Restrictions
66. 6-501.18 – Cleaning of
Plumbing Fixtures

SECTION 8 – GOOD HYGIENIC PRACTICES

Food Code Section

67. 2-401.11 - Eating, Drinking, or
Using Tobacco
68. 2-401.12 – Discharges from the
Eyes, Nose, and Mouth
69. 2-401.13 - Bandage, Finger Cot,
Stall

1-21

Jurisdiction's
Corresponding Code
Section, Rule, etc.

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 9 – CHEMICAL

Food Code Section

70. 3-202.12 – Additives
71. 3-302.14 – Protection from
Unapproved Additives
72. 7-207.11 – Restriction and
Storage
73. 7-207.12 – Refrigerated
Medicines, Storage
74. 7-208.11 – Storage (First Aid
Supplies)
75. 7-209.11 – Storage (Personal
Care Items)
76. 7-101.11 – Identifying
Information, Prominence
77. 7-102.11 – Common Name
78. 7-201.11 – Separation
79. 7-202.11 – Restriction
80. 7-202.12 – Conditions of Use

1-22

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

81. 7-203.11 – Poisonous or Toxic
Material Containers
82. 7-204.11 – Sanitizers, Criteria
83. 7-204.12 – Chemicals for
Washing, Treatment, Storage
and Processing Fruits and
Vegetables, Criteria
84. 7-204.13 – Boiler Water
Additives, Criteria
85. 7-204.14 – Drying Agents,
Criteria
86. 7-205.11 – Incidental Food
Contact, Criteria
87. 7-206.11 – Restricted Use
Pesticides, Criteria
88. 7-206.12 – Rodent Bait Stations
89. 7-206.13 – Tracking Powders,
Pest Control and Monitoring
90. 7-301.11 – Separation (Retail
Sale)

1-23

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 10 – CONFORMANCE WITH APPROVED PROCEDURES

Food Code Section

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

91. 3-404.11 – Treating Juice
92. 3-502.11 – Variance
Requirement
93. 3-502.12 – Reduced Oxygen
Packaging Without a
Variance, Criteria

SECTION 11 – HIGHLY SUSCEPTIBLE POPULATIONS

Food Code Section

94. 3-801.11 – Pasteurized
Foods, Prohibited Reservice,
and Prohibited Foods

1-24

Jurisdiction's
Corresponding Code
Section, Rule, etc.

YES
Full Intent is
Met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation Self-Assessment Worksheet
Part I – 2017 Food Code: Interventions and Risk Factor Controls Self-Assessment Results
YES
NO
Standard Standard
Food Code Section and Description
Criteria Criteria
Met
Not Met
1.

Demonstration of Knowledge

Employee Health

Consumer Advisory

Approved Sources

Time/Temperature

Protection from Contamination

Control of Hands as a Vehicle of
Contamination

Good Hygienic Practices

Chemical

Self-Assessor's General Comments

10. Conformance with Approve
Procedures
11. Highly Susceptible Populations

Assessment of
Categories
1-25

(regulatory agency)

indicates conformance with

(# Met)

out of the 11 Intervention/Risk Factor

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1 - REGULATORY FOUNDATION
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELFASSESSMENT
Part II – Good Retail Practices
STEP 1 – Review Good Retail Practices
The jurisdiction’s regulatory foundation must have corresponding requirements for 95 percent of the
FDA Food Code sections listed in Part II – Good Retail Practices of the Standard 1: Self-Assessment
Worksheet. This worksheet is included at the end of these instructions. Part II of the Standard 1: SelfAssessment Worksheet contains several categories, beginning with #12 “Personnel” through #36
“Presence of Insects / Rodents Minimized, Outer Openings Protected, etc.”
STEP 2 - Conduct the Self-Assessment for Part II
The self-assessor must compare the jurisdiction’s code, regulation, or ordinance with the corresponding
Food Code section for each of the Good Retail Practices (GRPs) provision listed in Part II of the
Standard 1: Self-Assessment Worksheet. For each Food Code section:
• Record the corresponding jurisdiction requirement; and
• Document his/her determination:
- If Full Intent of the Food Code section is met, place an "X" in the appropriate column.
- If Partial Intent of the Food Code section is met, identify language that is not included
with the jurisdiction's requirement. Indicate whether the language is addressed in another
jurisdiction statute, ordinance, or regulatory requirement.
- If No corresponding regulation exists, indicate "No Compliance" in the appropriate
column and provide any information that may explain why it is not part of the
jurisdiction's current requirements.
STEP 3 – Document the Self-Assessment Results for Part II
The summary table is provided at the end of Part II on the Standard 1: Self-Assessment Worksheet to
document the results of the self-assessment for the Good Retail Practices Food Code provisions. For
each Good Retail Practice category, the self-assessor will record the total number of Food Code
sections for which the jurisdiction’s regulations have a corresponding requirement. This number is
obtained from the totals documented at the end of each of the Good Retail Practice categories.
At the bottom of Part II of the Standard 1: Self-Assessment Worksheet, record the number of Good Retail
Practices that are met. Divide the total number of provisions met (last line of table) by 246 and multiple by
100 to determine the percentage of the Good Retail Practices provisions contained in the jurisdiction’s code
or regulation. A percentage equal to or greater than 95% meets the Regulatory Foundation for Sections 12 –
36.

1-26

Voluntary National Retail Food Regulatory Program Standards – January 2022

Examples of documents that may be reviewed
 The jurisdiction’s statute, regulation, rule, ordinance, or other prevailing set of regulatory
requirements that govern the operation of its food establishments
 Version of the FDA Food Code that was used for the self-assessment
 Completed Standard 1: Self-Assessment Worksheet
* Part II – Good Retail Practices
 If applicable, documents discussing or comparing code provisions excepted if adoption was made by
reference with exceptions.

1-27

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation
Self-Assessment Worksheet
Part II – 2017 Food Code: Good Retail Practices
SECTION 12 – PERSONNEL

Food Code Section

2-302.11 - Maintenance

2-303.11 - Prohibition

2-301.11 - Clean Condition

2-402.11 - Effectiveness

6-301.14 - Handwashing
Signage

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

TOTAL NUMBER OF SECTION 12 PROVISIONS MARKED “YES ____________ (Section 12 has a total of 5 provisions)

1-28

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 13 – FOOD & FOOD PROTECTION

Food Code Section

3-202.16 - Ice

3-202.17 - Shucked Shellfish,
Packaging and Identification

3-202.19 - Shellstock, Condition

3-203.11 - Molluscan Shellfish,
Original Container

10. 3-302.12 - Food Storage
Containers, Identified with
Common Name of Food
11. 3-302.13 - Pasteurized Eggs,
Substitute for Raw Shell Eggs
for Certain Recipes
12. 3-305.13 - Vended
Time/Temperature Control for
Safety Food, Original
Container
13. 3-601.11 - Standards of Identity

1-29

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code section
is NOT Met (Indicate the Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code section
is NOT Met (Indicate the Situation)

14. 3-601.12 - Honestly Presented
15. 3-602.11 - Food Labels
16. 3-602.12 - Other Forms of
Information
17. 6-404.11 - Segregation and
Location

TOTAL NUMBER OF SECTION 13 PROVISIONS MARKED “YES ____________ (Section 13 has a total of 12 provisions)

SECTION 14 – PLANT FOOD COOKING FOR HOT HOLDING

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code section
is NOT Met (Indicate the Situation)

18. 3-401.13 - Plant Food Cooking
for Hot Holding

TOTAL NUMBER OF SECTION 14 PROVISIONS MARKED “YES __________ (Section 14 has a total of 1 provisions)

1-30

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 15 – PROTECTION FROM CONTAMINATION

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code section
is NOT Met (Indicate the Situation)

19. 3-302.15 - Washing Fruits and
Vegetables
20. 3-303.11 - Ice Used as Exterior
Coolant, Prohibited as
Ingredient
21. 3-302.12 - Storage or Display
of Food in Contact with
Water and Ice
22. 3-304.11 - Food Contact with
Equipment and Utensils
23. 3-305.11 - Food Storage
24. 3-305.12 - Food Storage,
Prohibited Areas
25. 3-305.14 - Food Preparation
26. 3-306.11 - Food Display
27. 3-306.12 - Condiments,
Protection
28. 3-306.13 - Consumer SelfService Operations
29. 3-307.11 - Miscellaneous
Sources of Contamination

TOTAL NUMBER OF SECTION 15 PROVISIONS MARKED “YES __________ (Section 15 has a total of 11 provisions)
1-31

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 16 – FACILITIES / METHODS TO CONTROL PRODUCT TEMPERATURE

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

30. 3-501.11 - Frozen Food

31. 4-301.11 - Cooling, Heating,
and Holding Capacities

TOTAL NUMBER OF SECTION 16 PROVISIONS MARKED “YES __________ (Section 16 has a total of 2 provisions)

SECTION 17 – TIME / TEMPERATURE CONTROL FOR SAFETY FOOD - PROPERLY THAWED

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

32. 3-501.12 - Time / Temperature
Control for Safety Food,
Slacking
33. 3-501.13 - Thawing

TOTAL NUMBER OF SECTION 17 PROVISIONS MARKED “YES __________ (Section 17 has a total of 2 provisions)

1-32

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 18 – DISPENSING OF FOOD / UTENSILS PROPERLY STORED

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

34. 3-304.12 - In-Use Utensils,
Between-use Storage
35. 4-204.13 - Dispensing
equipment, Protection of
Equipment and Food
36. 4-204.14 - Vending Machine
Vending Stage Closure

TOTAL NUMBER OF SECTION 18 PROVISIONS MARKED “YES __________ (Section 18 has a total of 3 provisions)

SECTION 19 – THERMOMETERS PROVIDED AND CONSPICUOUS

Food Code Section

37. 4-203.11 - Temperature
Measuring Devices
38. 4-203.12 - Temperature
Measuring Devices, Ambient
Air and Water

1-33

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

39. 4-204.112 - Temperature
Measuring Devices

40. 4-302.12 - Food Temperature
Measuring Devices

TOTAL NUMBER OF SECTION 19 PROVISIONS MARKED “YES __________ (Section 19 has a total of 4 provisions)

SECTION 20 – FOOD AND NONFOOD CONTACT SURFACES: DESIGNED, CONSTRUCTED, MAINTAINED, INSTALLED,
LOCATED, OPERATED, CLEANABLE

Food Code Section

41. 3-304.16 - Using Clean
Tableware for Second Portions
and Refills
42. 3-304.17 - Refilling Returnables
43. 4-101.11 - Characteristics
44. 4-101.12 - Cast Iron, Use
Limitation

1-34

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section
45. 4-101.13 – Lead, Use
Limitation (In Ceramic, China,
and Crystal)
46. 4-101.14 - Copper, Use
Limitation
47. 4-101.15 - Galvanized Metal,
Use Limitation
48. 4-101.17 - Wood, Use Limitation
49. 4-101.18 - Nonstick Coatings,
Use Limitation
50. 4-101.19 - Nonfood-Contact
Surfaces
51. 4-102.11 - Characteristics
52. 4-201.11 - Equipment and
Utensils
53. 4-202.11 - Food-Contact
Surfaces
54. 4-202.12 - CIP Equipment
55. 4-202.13 - "V" Threads, Use
Limitation
56. 4-202.14 - Hot Oil Filtering
Equipment
57. 4-202.15 - Can Openers

1-35

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

58. 4-202.16 - Nonfood-Contact
Surfaces
59. 4-202.17 - Kick Plates,
Removable
60. 4-204.12 - Equipment Openings,
Closures, and Deflectors
61. 4-204.15 - Bearings and Gear
Boxes, Leakproof
62. 4-204.16 - Beverage Tubing,
Separation
63. 4-204.17 - Ice Units, Separation
of Drains
64. 4-204.18 - Condenser Unit,
Separation
65. 4-204.19 - Can Openers on
Vending Machines
66. 4-204.110 - Molluscan Shellfish
Tanks
67. 4-204.111 - Vending Machines,
Automatic Shutoff
68. 4-204.121 - Vending Machines,
Liquid Waste Products
69. 4-204.122 - Case Lot Handling
Equipment, Moveability

1-36

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

70. 4-204.123 - Vending Doors and
Openings
71. 4-302.11 - Utensils, Consumer
Self-Service
72. 4-401.11 - Equipment, Clothes
Washers and Dryers and
Storage Cabinets,
Contamination Prevention
73. 4-402.11 - Fixed Equipment,
Spacing or Sealing
74. 4-402.12 - Fixed Equipment,
Elevation or Sealing
75. 4-501.11 - Good Repair and
Proper Adjustment
76. 4-501.12 - Cutting Surfaces
77. 4-501.13 - Microwave Ovens
78. 4-502.11 - Good Repair and
Calibration
79. 4-601.11(B - C) - Equipment,
Food-Contact Surfaces,
Nonfood-Contact Surfaces,
Utensils
80. 4-602.13 - Nonfood-Contact
Surfaces

1-37

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

81. 4-603.11 - Dry Cleaning
82. 4-902.11 - Food-Contact
Surfaces
83. 4-902.12 - Equipment

TOTAL NUMBER OF SECTION 20 PROVISIONS MARKED “YES __________ (Section 20 has a total of 43 provisions)

SECTION 21 – WAREWASHING FACILITY: DESIGNED CONSTRUCTED, INSTALLED, LOCATED, OPERATED,
CLEANABLE, USED

Food Code Section

84. 4-303.11 - Cleaning Agents
and Sanitizer, Availability
85. 4-203.13 - Pressure Measuring
Devices, Mechanical
Warewashing Equipment
86. 4-204.113 - Warewashing
Machine, Data Plate Operating
Specifications
87. 4-204.114 - Warewashing
Machines, Internal Baffles

1-38

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

88. 4-204.115 - Warewashing
Machines, Temperature,
Measuring Devices
89. 4-204.116 - Manual
Warewashing Equipment,
Heaters and Baskets
90. 4-204.117 - Warewashing
Machines, Automatic
Dispensing of Detergents and
Sanitizers
91. 4-204.118 - Warewashing
Machines, Flow Pressure Device
92. 4-204.119 - Warewashing Sinks
and Drainboards, Self-Draining
93. 4-204.120 - Equipment
Compartments, Drainage
94. 4-301.12 - Manual
Warewashing, Sink
Compartment Requirements
95. 4-301.13 - Drainboards
96. 4-302.13 - Temperature
Measuring Devices, Manual
Warewashing
97. 4-302.14 - Sanitizing Solutions,
Testing Devices
98. 4-501.14 - Warewashing
Equipment, Cleaning
Frequency

1-39

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

99. 4-501.15 - Warewashing
Machines, Manufacturer's
Operating Instructions
100. 4-501.16 - Warewashing
Sinks, Use Limitation
101. 4-501.17 - Warewashing
Equipment, Cleaning Agents
102. 4-501.18 - Warewashing
Equipment, Clean Solutions
103. 4-501.19 - Manual
Warewashing Equipment,
Wash Solution Temperature
104. 4-501.110 - Mechanical
Warewashing Equipment,
Wash Solution Temperature
105. 4-501.116 - Warewashing
Equipment, Determining
Chemical Sanitizer
Concentration
106. 4-603.12 - Precleaning
107. 4-603.13 - Loading of Soiled
Items, Warewashing
Machines
108. 4-603.14 - Wet Cleaning
109. 4-603.15 - Washing,
Procedures for Alternative
Manual Warewashing
Equipment

1-40

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

110. 4-603.16 - Rinsing Procedures
111. 4-04.14 - Rinsing Equipment
and Utensils After Cleaning
and Sanitizing

TOTAL NUMBER OF SECTION 21 PROVISIONS MARKED “YES __________ (Section 21 has a total of 28 provisions)

SECTION 22 – WIPING CLOTHS, LINENS, NAPKINS, GLOVES, SPONGES: PROPERLY USED, STORED

Food Code Section

112. 3-304.13 - Linens and
Napkins, Use Limitation
113. 3-304.14 - Wiping Cloths, Use
Limitation
114. 3-304.15 - Gloves, Use
Limitation
115. 4-101.16 - Sponges, Use
Limitation
116. 4-801.11 - Clean Linens
117. 4-802.11 - Specifications

1-41

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

118. 4-803.11 - Storage of Soiled
Linens
119. 4-803.12 - Mechanical
Washing
120. 4-901.12 - Wiping Cloths, Air
Drying Locations
121. 4-902.12 - Equipment

TOTAL NUMBER OF SECTION 22 PROVISIONS MARKED “YES __________ (Section 22 has a total of 10 provisions)

SECTION 23 – STORAGE, HANDLING OF CLEAN EQUIPMENT, UTENSILS

Food Code Section
122. 4-901.11 - Equipment and
Utensils, Air- Drying
Required
123. 4-903.11 - Equipment,
Utensils, Linens, and SingleService and Single-Use
Articles
124. 4-903.12 - Prohibitions

1-42

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

125. 4-904.11 - Kitchenware and
Tableware
126. 4-904.12 - Soiled and Clean
Tableware
127. 4-904.13 - Preset Tableware

TOTAL NUMBER OF SECTION 23 PROVISIONS MARKED “YES __________ (Section 23 has a total of 6 provisions)

SECTION 24 – SINGLE-SERVICE / SINGLE-USE ARTICLES: STORAGE, DISPENSING, USE, NO REUSE

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

128. 4-502.12 - Single-Service and
Single-Use Articles, Required
Use
129. 4-502.13 - Single-Service and
Single-Use Articles, Use
Limitation
130. 4-502.14 - Shells, Use
Limitation

TOTAL NUMBER OF SECTION 24 PROVISIONS MARKED “YES __________ (Section 24 has a total of 3 provisions)
1-43

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 25 – SAFE WATER SOURCE, HOT AND COLD UNDER PRESSURE, ADEQUATE QUANTITY

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

131. 5-101.11 - Approved System
132. 5-102.11 - Standards
133. 5-102.12 - Nondrinking Water
134. 5-102.13 - Sampling
135. 5-102.14 - Sample Report
136. 5-103.11 - Capacity
137. 5-103.12 - Pressure
138. 5-104.11 - System
139. 5-104.12 - Alternative Water
Supply

TOTAL NUMBER OF SECTION 25 PROVISIONS MARKED “YES __________ (Section 25 has a total of 9 provisions)

1-44

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 26 – PLUMBING: INSTALLED, MAINTAINED

Food Code Section

140. 5-101.12 - System Flushing
and Disinfection
141. 5-201.11 - Approved
142. 5-202.11 - Approved System
and Cleanable Fixtures
143. 5-202.12 - Handwashing
Facility, Installation
144. 5-202.15 - Conditioning
Device, Location
145. 5-203.13 - Service Sink
146. 5-204.13 - Conditioning
Device, Location
147. 5-205.13 - Scheduling
Inspection and Service for a
Water System Device
148. 5-205.14 - Water Reservoir of
Fogging Devices, Cleaning
149. 5-205.15 - System Maintained
in Good Repair
150. 5-301.11 - Approved

1-45

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

151. 5-302.11 - Enclosed System,
Sloped to Drain
152. 5-302.12 - Inspection and
Cleaning Port, Protected and
Secured
153. 5-302.13 - "V" Type Threads,
Use Limitation
154. 5-302.14 - Tank Vent,
Protected
155. 5-302.15 - Inlet and Outlet,
Sloped to Drain
156. 5-302.16 - Hose, Construction
and Identification
157. 5-303.11 - Filter, Compressed
Air
158. 5-303.12 - Protective Cover or
Device
159. 5-303.13 - Mobile Food
Establishment Tank Inlet
160. 5-304.11 - System Flushing
and Disinfection
161. 5-304.12 - Using a Pump and
Hoses, Backflow Prevention
162. 5-304.13 - Protecting Inlet,
Outlet, and Hose Fitting

1-46

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

163. 5-304.14 - Tank, Pump, and
Hoses, Dedication

TOTAL NUMBER OF SECTION 26 PROVISIONS MARKED “YES __________ (Section 26 has a total of 24 provisions)

SECTION 27 – CROSS CONNECTION, BACK SIPHONAGE, BACKFLOW PREVENTION

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

164. 5-202.13 - Backflow
Prevention, Air Gap
165. 5-202.14 - Backflow
Prevention Device, Design
Standard
166. 5-203.14 - Backflow
Prevention Device, When
Required
167. 5-203.15 - Backflow
Prevention Device,
Carbonator
168. 5-204.12 - Backflow
Prevention Device, Location
169. 5-205.12 - Prohibiting a Cross
Connection

TOTAL NUMBER OF SECTION 27 PROVISIONS MARKED “YES __________ (Section 27 has a total of 6 provisions)
1-47

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 28 – TOILET FACILITIES: CONVENIENT, ACCESSIBLE, DESIGNED, INSTALLED

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

170. 5-203.12 - Toilets and Urinals
171. 6-402.11 - Convenience and
Accessibility

TOTAL NUMBER OF SECTION 28 PROVISIONS MARKED “YES __________ (Section 28 has a total of 2 provisions)

SECTION 29 – TOILET ROOMS ENCLOSED, SELF-CLOSING DOORS; FIXTURES GOOD REPAIR, CLEAN PROPER
WASTE RECEPTACLES

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

172. 5-501.17 - Toilet Room
Receptacle, Covered
173. 6-202.14 - Toilet Rooms,
Enclosed
174. 6-302.11 - Toilet Tissue
Availability
175. 6-501.19 - Closing Toilet
Room Doors

TOTAL NUMBER OF SECTION 29 PROVISIONS MARKED “YES __________ (Section 29 has a total of 4 provisions)
1-48

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 30 – SEWAGE AND WATER WASTE DISPOSAL

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

176. 5-401.11 - Capacity and
Drainage
177. 5-402.11 - Backflow
Prevention
178. 5-402.12 - Grease Trap
179. 5-402.13 - Conveying Sewage
180. 5-402.14 - Removing Mobile
Food Establishment Wastes
181. 4-502.15 - Flushing a Waste
Retention Tank
182. 5-403.11 - Approved Sewage
Disposal System
183. 5-403.12 - Other Liquid
Wastes and Rainwater

TOTAL NUMBER OF SECTION 30 PROVISIONS MARKED “YES __________ (Section 30 has a total of 8 provisions)

1-49

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 31 – GARBAGE AND REFUSE DISPOSAL – CONTAINERS OR RECEPTACLES: COVERED, ADEQAUTE
NUMBER, INSECT / RODENT PROOF, FREQUENCY OF REMOVAL, CLEAN, AREA PROPERLY CONSTRUCTED,
NECCESSARY IMPLEMENTS, SUPPLIES

Food Code Section

184. 5-501.11 - Outdoor Storage
Surface
185. 5-501.12 - Outdoor Enclosure
186. 5-501.13 – Receptacles
187. 5-501.14 – Receptacles in
Vending Machines
188. 5-501.15 – Outside
Receptacles
189. 5-501.16 – Storage Areas,
Rooms, and Receptacles,
Capacity and Availability
190. 5-501.18 – Cleaning
Implements and Supplies
191. 5-501.19 – Storage Areas,
Redeeming Machines,
Receptacles and Waste
Handling Units Location
192. 5-501.110 – Storing Refuse,
Recyclables, and Returnables
193. 5-501.111 – Areas, Enclosures,
and Receptacles, Good Repair

1-50

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

194. 5-501.112 –Outside Storage
Prohibitions
195. 5-501.113 –Covering
Receptacles
196. 5-501.114 – Using Drain Plugs
197. 5-501.115 – Maintaining
Refuse Areas and Enclosures
198. 5-501.116 – Cleaning
Receptacles
199. 5-502.11 – Frequency
200. 5-502.12 – Receptacles or
Vehicles
201. 5-503.11 – Community or
Individual Facility
202. 6-202.110 - Outside Refuse
Areas, Curbed and Graded to
Drain

TOTAL NUMBER OF SECTION 31 PROVISIONS MARKED “YES __________ (Section 31 has a total of 19 provisions)

1-51

Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 32 – PHYSICAL FACILITY, FLOORS, WALLS, CEILINGS: DESIGNED, CONSTRUCTED, MAINTAINED, CLEAN

Food Code Section

203. 6-101.11 - Surface
Characteristics
204. 6-102.11 - Surface
Characteristics
205. 6-201.11 - Floors, Walls, and
Ceilings
206. 6-201.12 - Floors, Walls, and
Ceilings, Utility Lines
207. 6-201.13 - Floors and Wall
Junctures, Coved, and
Enclosed or Sealed
208. 6-201.14 - Floor Carpeting,
Restrictions and Installation
209. 6-201.15 - Floor Covering,
Mats and Duckboards
210. 6-201.16 - Wall and Ceiling
Coverings and Coatings
211. 6-201.17 - Walls and Ceilings,
Attachments
212. 6-201.18 - Walls and Ceilings,
Studs, Joists, and Rafters
213. 6-202.17 - Outdoor Food
Vending Areas, Overhead
Protection

1-52

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

214. 6-202.18 - Outdoor Servicing
Areas, Overhead Protection
215. 6-501.11 - Repairing
216. 6-501.12 - Cleaning,
Frequency and Restrictions
217. 6-501.13 - Cleaning Floors,
Dustless Methods
218. 6-501.17 - Absorbent
Materials on Floors, Use
Limitation

TOTAL NUMBER OF SECTION 32 PROVISIONS MARKED “YES __________ (Section 32 has a total of 16 provisions)

SECTION 33 – LIGHTING, VENTILATION, DRESSING ROOMS / DESIGNATED AREAS MAINTAINED

Food Code Section

219. 4-202.18 - Ventilation Hood
Systems, Filters
220. 4-204.11 - Ventilation Hood
Systems, Drip Preventions
221. 4-301.14 - Ventilation Hood
Systems, Adequacy

1-53

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

222. 6-202.12 - Heating,
Ventilating, Air Conditioning
System Vents
223. 6-303.11 - Intensity
224. 6-304.11 - Mechanical
225. 6-305.11 - Designation
226. 6-403.11 - Designated Areas
227. 6-501.14 - Cleaning
Ventilation Systems, Nuisance
and Discharge Prohibition
228. 6-501.110 - Using Dressing
Rooms and Lockers
229. 6-202.12 - Heating,
Ventilating, Air Conditioning
System Vents

TOTAL NUMBER OF SECTION 33 PROVISIONS MARKED “YES __________ (Section 33 has a total of 11 provisions)

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Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 34 – PREMISES MAINTAINED FREE OF LITTER, UNNECESSARY ARTICLES, CLEANING AND
MAINTENANCE EQUIPMENT PROPERLY STORED
Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

230. 6-202.19 - Outdoor Walking
and Driving Surfaces, Graded
to Drain
231. 6-501.15 - Cleaning
Maintenance Tools,
Preventing Contamination
232. 6-501.16 - Drying Mops
233. 6-501.113 - Storing
Maintenance Tools
234. 6-501.114 - Maintaining
Premises, Unnecessary Items
and Litter

TOTAL NUMBER OF SECTION 34 PROVISIONS MARKED “YES __________ (Section 34 has a total of 5 provisions)

SECTION 35 – COMPLETE SEPARATION FROM LIVING / SLEEPING QUARTERS; LAUNDRY
Food Code Section

235. 4-301.15 - Clothes Washers
and Dryers
236. 4-401.11 - Equipment Clothes
Washers and Dryers, and
Storage Cabinets,
Contamination Prevention

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Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations
and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

237. 4-803.13 - Use of Laundry
Facilities
238. 6-202.111 - Private Homes
and Living or Sleeping
Quarters, Use Prohibition
239. 6-202.112 - Living or Sleeping
Quarters, Separation

TOTAL NUMBER OF SECTION 35 PROVISIONS MARKED “YES __________ (Section 35 has a total of 5 provisions)

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Voluntary National Retail Food Regulatory Program Standards – January 2022

SECTION 36 – PRESENCE OF INSECTS / RODENTS MINIMIZED, OUTER OPENINGS PROTECTED, ANIMALS AS
ALLOWED

Food Code Section

Jurisdiction's
Corresponding
Code Section, Rule,
etc.

YES
Full Intent is
Met

Partial Compliance
List what is not covered (Additional
sheets can be used for explanations and
comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

240. 2-403.11 - Handling
Prohibition
241. 6-202.13 - Insect Control
Device, Design and
Installation
242. 6-202.15 - Outer Openings
Protected
243. 6-202.16 - Exterior Walls and
Roofs, Protective Barrier
244. 6-501.111 - Controlling Pests
245. 6-501.112 - Removing Dead or
Trapped Birds, Insects,
Rodents, and other Pests
246. 6-501.115 - Prohibiting
Animals

TOTAL NUMBER OF SECTION 36 PROVISIONS MARKED “YES __________ (Section 36 has a total of 7 provisions)

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1: REGULATORY FOUNDATION SELF-ASSESMENT WORKSHEET
PART II – 2017 Food Code: Good Retail Practices
SELF-ASSESSMENT RESULTS
Section
Number

Number of
Provisions Met
(Identified as "YES"
on worksheet)

Section Description

Personnel

Food and Food Protection

Plant Cooking for Hot Holding

Protection from Contamination

Facilities / Methods to Control Product Temperature

Time/Temperature Control for Safety Food Properly Thawed

Dispensing Food / Utensils Properly Stored

Food Equipment

Food and Nonfood-Contact Surfaces

Warewashing Facilities; Designed, Constructed, Installed, Located, Operated, etc.

Wiping Cloths, Linens, Napkins, Gloves, Sponges: Properly Used, Stored

Storage, Handling of Clean Equipment, Utensils

Single-Service / Single Use Articles: Storage, Dispensing, Use, no Reuse

Safe Water Source, Hot and Cold Under Pressure, Adequate Quantity

Plumbing: Installed, Maintained

Cross Connection, Back Siphonage, Backflow Prevention

Number, Convenient, Accessible, Designed, Installed

Toilet Rooms Enclosed, Self-Closing Doors; Fixtures, Good Repair, Clean, etc.

Sewage and Wastewater Disposal

Garbage and Refuse Disposal - Containers or Receptacles: Covered, etc.

32
33

Physical Facility - Floors, Walls, Ceiling: Designed, Constructed, Maintained,
t
Lighting, Ventilation, Dressing Rooms / Designated Areas Maintained

Premises Maintained Free of Litter, Unnecessary Articles

Complete Separation from Living / Sleeping Quarters; Laundry

Presence of Insects / Rodents Minimized, Outer Openings Protected, etc.,

TOTAL NUMBER OF PROVISIONS MET (Add Column 2): __________
Divide the total number of provisions met (last line of table) by 246 and multiply by 100 to determine
the percentage of the Good Retail Practices provisions contained in your code regulation. __________%
A percentage equal to or greater than 95% meets the Regulatory Foundation for Sections 12 thru 36.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1 - REGULATORY FOUNDATION
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELFASSESSMENT
Part III – Compliance and Enforcement
STEP 1 – Review Compliance and Enforcement Administrative Provisions
Part III of the Standard 1: Self-Assessment Worksheet contains 12 Compliance and Enforcement areas
within a regulatory retail food program. This worksheet is included at the end of these instructions. To
meet this element of Standard 1, the jurisdiction’s regulatory requirements must have a corresponding
requirement for the Food Code sections listed in Items 1 through 11. For Item 12 pertaining to “Legal
Remedies,” a jurisdiction need only demonstrate that its regulatory foundation provides the authority to
implement one of the legal remedies pertaining to criminal, injunctive, or civil penalties.
STEP 2 - Conduct the Self-Assessment for Part III

The self-assessor must compare the jurisdiction’s code, regulation, or ordinance against with the FDA Food Code
Compliance and Enforcement provisions listed on the self-assessment worksheets. For each Food Code section:

•
•

Record the corresponding jurisdiction requirement; and
Document his/her determination:
- If Full Intent of the Food Code section is met, place an "X" in the appropriate column.
- If Partial Intent of the Food Code section is met, identify language that is not included
with the jurisdiction's requirement. Indicate whether the language is addressed in another
jurisdiction statute, ordinance, or regulatory requirement.
- If No corresponding regulation exists, indicate "No Compliance" in the appropriate
column and provide any information that may explain why it is not part of the
jurisdiction's current requirements.

STEP 3 – Document the Self-Assessment Results for Part III
A summary table is provided at the end of Part III on the Standard 1: Self-Assessment Worksheet to
document the results of the regulatory foundation self-assessment for the Compliance and Enforcement
Food Code provisions. At the bottom of Part III on the Standard 1: Self-Assessment Worksheet, record
the number of Compliance and Enforcement categories that are met. To meet the Standard 1, Part III
criteria, the jurisdiction must have a “YES” response for all 12 of the listed Compliance and
Enforcement categories.
Examples of documents that may be reviewed
 The jurisdiction’s statute, regulation, rule, ordinance, or other prevailing set of regulatory
requirements that govern the operation of its food establishments
 Version of the FDA Food Code that was used for the self-assessment
 Completed Standard 1: Self-Assessment Worksheet
* Part III – Compliance and Enforcement
 If applicable, documents discussing or comparing code provisions excepted if adoption was made by
reference with exceptions.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation
Self-Assessment Worksheet

Part III – 2017 Food Code: Compliance and Enforcement Summary

Food Code Section
1a. Hold orders, Embargo, and Destruction of
Food
8-901.10 – Conditions Warranting Remedy
1b. Hold orders, Embargo, and Destruction of
Food
8-903.10 – Hold Order, Justifying Conditions and
Removal of Food
1c. Hold orders, Embargo, and Destruction of
Food
8-903.30 – Hold Order, Contents
2a. Permit/License Required; Right to Deny
8-301.11 – Prerequisite for Operation
2b. Permit/License Required; Right to Deny
8-304.20 – Permits Not Transferable
3. Plan Review/Pre-operational inspections
8-201.11 – When Plans are Required
4. Inspection Authority / Right to Access
8-402.20 – Refusal, Notification of Right to Access,
and Final Request for Access
5a. Information Authority; Restriction/Exclusion
of Employees
8-501.10 – Obtaining Information: Personal History of
Illness, Medical Examination, and Specimen Analysis

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Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent
is Met

Partial Compliance
List what is not covered
(Additional sheets can be used
for explanations and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section
5b. Information Authority; Restriction/Exclusion of
Employees
8-501.20 – Restriction or Exclusion of Food Employee,
or Summary Suspension of Permit
5c. Information Authority; Restriction/Exclusion
of Employees
8-501.30 – Restriction or Exclusion Order: Warning or
Hearing Not Required, Information Required
in Order
6. Authority to Require HACCP Plans
8-201.13 – When a HACCP Plan is Required
7a. Granting of Variances
8-103.10 – Modifications and Waivers
7b. Granting of Variances
8-103.11 – Documentation of Proposed Variance and
Justification
7c. Granting of Variances
8-103.12 – Conformance with Approved Procedures
7d. Jurisdiction Does NOT Issue Variances
(Variances Prohibited)
Variances Prohibited
8a. Timely Correction of Critical Violations
8-405.11 – Timely Correction
8b. Timely Correction of Critical Violations
8-405.20 – Verification and Documentation of
Correction
8c. Timely Correction of Critical Violations
8-406.11 – Time Frame for Correction

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Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent
is Met

Partial Compliance
List what is not covered
(Additional sheets can be used
for explanations and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Food Code Section

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full Intent
is Met

Partial Compliance
List what is not covered
(Additional sheets can be used
for explanations and comments)

NO
Compliance with the Food Code
section is NOT Met (Indicate the
Situation)

9a. Imminent Health Hazard (Summary of
Suspension)
8-404.12 – Resumption of Operations
9b. Imminent Health Hazard (Summary of
Suspension)
8-904.10 – Conditions Warranting Action
10a. License Suspension / Revocation
8-905.10 – Response to Notice of Hearing or Request
for Hearing, Basis and Time Frame
10b. License Suspension / Revocation
8-905.20 - Response to Notice of Hearing or Request
for Hearing, Required Form and Contents
11a. Institution of Proceedings
8-910.10 - Institution of Proceedings
12a. Criminal Penalties
8-911.10 - Authorities, Methods, Fines and Sentences
12b. 8-912.10 - Petitions for Injunction
12c. Civil Penalties Provided
8-913.10 - Petitions, Penalties and Continuing
Violations
NOTE:
1. Meeting the Standard #1 criteria for the “Compliance and Enforcement” component requires a “Yes” for all Food Code Sections listed in Items 1 through 11.
2. For Item 12 pertaining to legal remedies, the jurisdiction needs to demonstrate a corresponding regulatory requirement for only one of
the sections pertaining to criminal, injunctive, or civil penalties.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Compliance and Enforcement Area and Description

Hold Orders, Embargo, and Destruction of Food

Permit / License Required; Right to Deny

Plan Review / Pre-operational Inspections

Inspection Authority / Right to Access

Information Authority; Restriction / Exclusion of
Employees

Authority to Require HACCP Plans

Granting of Variances / Variances Prohibited

Timely Correction of Critical Violations

Imminent Health Hazard (Summary of Suspension)

YES
Full Intent
is Met

NO
Standard
Criteria is
not Met

Self-Assessor’s General Comments

10. License Suspension / Revocation
11. Highly Susceptible Populations
12. Legal Remedies

Assessment of _________________________ indicates conformance with ______ out of the 12 Compliance and Enforcement Categories
(Regulatory Agency)

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(# Met)

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1 - REGULATORY FOUNDATION
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A VERIFICATION
AUDIT
Part I – Food Code Interventions and Risk Factor Controls
STEP 1 – Confirm Completion of the Self-Assessment for the Program’s Regulatory Foundation
The jurisdiction’s review of its food code against the Food Code should include documentation that a
that a side-by-side comparison of its prevailing statutes, regulations, rules, and other pertinent
requirements was completed. If a jurisdiction adopted the current published edition or one of the two
most recent editions of the Food Code by reference, a side-by-side comparison of the language is not
necessary. Adoption by reference meets the criteria of the Standard.
The jurisdiction’s side-by-side comparison must include an assessment of the following items:
1. The major Food Code Public Health Intervention and Risk Factor control measures;
2. Good Retail Practices;
3. Compliance and Enforcement administrative requirements.
The side-by-side comparison should clearly identify the jurisdiction's corresponding requirements to the
applicable Food Code section.
STEP 2 – Determine Food Code Interventions and Risk Factor Controls Sections to Review
The verification auditor must randomly select Food Code sections to review. The auditor should only
review public health interventions and risk factor control categories that the jurisdiction reported as
meeting on Part I of their Standard 1: Self-Assessment Worksheet. Part I of the jurisdiction's Standard 1:
Self-Assessment Worksheet contains 94 Food Code sections pertaining to Public Health Interventions and
Risk Factor Controls. Each of these Food Code sections has been assigned a number from 1 to 94.
For Part I, the verification auditor must randomly select 15 Food Code sections for the review. A list of
random numbers can be obtained from the following web link: www.randomizer.org. Using the
jurisdiction's Standard 1: Self-Assessment Worksheet, the verification auditor must identify the Food
Code sections that correspond to the randomly selected numbers recorded on the verification audit
worksheet. This worksheet is included at the end of these instructions.
The auditor should only review those Food Code sections that the jurisdiction indicates were met. If a
Public Health Intervention or Risk Factor Control Food Code section is selected that the jurisdiction
indicated was not met, the verification auditor should select a substitute Food Code section to review.
STEP 3 – Confirm Findings for Food Code Interventions and Risk Factor Controls
The auditor must review the randomly selected regulatory requirements. The auditor must compare the
language in each of the selected jurisdiction code sections to verify that it is at least as stringent

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Voluntary National Retail Food Regulatory Program Standards – January 2022

as the corresponding Food Code section language. The language may be more stringent, but not less
stringent. Record an "X" in the appropriate box on the Standard 1: Verification Audit Worksheet based
on the determination.
Yes - Full Intent is Met or
No - Full Intent is not Met
In instances where the verification auditor has determined that the jurisdiction’s language does not
meet the criterion, an explanation must be provided on the Standard 1: Verification Audit Worksheet.
Record the explanation under the column “If No, Auditor is to specify why the criterion is not met.”
STEP 4 – Document the Verification Audit Results for Part I
Part I of the Standard 1: Self-Assessment Worksheet, included at the end of these instructions, contains
11 public health interventions and risk factor controls:
1. Demonstration of Knowledge
2. Employee Health
3. Consumer Advisory
4. Approved Source
5. Time/Temperature
6. Protection from Contamination
7. Control of Hands as a Vehicle of Contamination
8. Good Hygienic Practices
9. Chemical
10. Conformance with Approved Procedures
11. Highly Susceptible Population
To meet any one of the 11 public health intervention and risk factor controls identified under the
self-assessment process, the self-assessment must indicate that the jurisdiction’s regulatory
requirements address all Food Code sections listed for that area. For initial listing, the jurisdiction's
regulatory foundation must contain at least 9 of the 11 public health interventions and risk factor
controls. In order to fully meet the requirement of the Standard, the regulatory foundation must meet
all 11 of the interventions and risk factor controls by the third verification audit cycle.
If four or more of the 15 selected code sections reviewed during the audit process do not meet the
stringency of language criteria, the Standard 1, Part I element fails to meet the criteria, and no further
sampling is necessary. If one, two or three of the 15 selected code sections do not meet the stringency of
the language criteria but the jurisdiction continues to meet the required number of interventions and risk
factor controls to meet the Standard, then randomly select an additional 15 Food Code sections. No more
than three total disagreements are acceptable in the thirty (30) Code sections drawn for comparison in
order for the audit to confirm the Part I element of Standard 1 as met. In addition, at least 9 out of the 11
interventions and risk factor controls must still be met at the end of the first audit after the disagreements
are taken into account, and the jurisdiction must meet 11 out of the 11 interventions and risk factor
controls by the third regular audit in order to meet the Standard 1 criteria.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Examples of documents that may be reviewed:
 The jurisdiction’s statute, regulation, rule, ordinance, or other prevailing set of regulatory
requirements that govern the operation of its food establishments
 Version of the FDA Food Code that was used for the self-assessment
 Completed Standard 1: Self-Assessment Worksheet, Part I – Food Code Interventions and
Risk Factor Controls
 If applicable, documents discussing or comparing code provisions excepted if adoption was
made by reference with exceptions.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation
Verification Audit Worksheet
Part I – Food Code Interventions and Risk Factor Control
Part I – Interventions and Risk Factors
Number of
Sections
Reviewed

Randomly
Selected
Number

Corresponding Food Code
Chapter from Part I
Interventions and Risk
Factors Self-Assessment
Worksheet

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full
Intent
is Met

NO
Full
Intent is
not Met

If no, auditor must specify why criterion is not met

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

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NOTES
1. If there is Agreement that ALL 15 selected code sections meet the stringency of the language criteria in the FDA Food Code, proceed to Part II.
2. If one, two or three of the 15 selected code sections do not meet the stringency of the language criteria in the FDA Food Code, then complete
the Supplemental Part I Section of the Worksheet by randomly selecting another 15 Interventions and Risk Factor code sections to review.
3. If four or more of the 15 selected code sections do not meet the stringency of the language criteria in the FDA Food Code, then the jurisdiction
does not meet the Standard 1 criteria for Food Code Interventions and Risk Factors.

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation
Verification Audit Worksheet
Supplement to Part I – Food Code Interventions and Risk Factor Control
Part I – Interventions and Risk Factors
Number of
Sections
Reviewed

Randomly
Selected
Number

Corresponding Food Code
Chapter from Part I
Interventions and Risk
Factors Self-Assessment
Worksheet

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full
Intent
is Met

NO
Full
Intent is
not Met

If no, auditor must specify why criterion is not met

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
NOTES
1. If more than three of the 30 total selected code sections do not meet the stringency of the language criteria in the FDA Food Code, then the
jurisdiction does not meet the Standard 1 criteria for Food Code Interventions and Risk Factors.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1 - REGULATORY FOUNDATION
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A VERIFICATION
AUDIT
Part II – Good Retail Practices
STEP 1 – Review the Self-Assessment conducted for Good Retail Practices
To meet the Standard 1 criteria for Good Retail Practices, a jurisdiction’s regulations must have a
corresponding requirement for 95 percent of the Food Code sections listed in Part II of the SelfAssessment Worksheet. The auditor must examine the jurisdiction’s Standard 1: Self-Assessment
Worksheet to verify that an assessment has been made for each of the 246 Good Retail Food Practices
Food Code sections. The auditor must determine if the jurisdiction identified at least 234 Food Code
sections (95%) that meet the criteria for stringency of language compared to the Food Code.
STEP 2 – Determine Good Retail Practices Sections to Review
The verification auditor must randomly select 13 Food Code sections as part of the Part II review process
for Good Retail Practices. A list of random numbers can be obtained from the "Randomizer" web link:
www.randomizer.org. Using the jurisdiction's self-assessment worksheet, the verification auditor must
identify the Food Code sections that correspond to the randomly selected numbers recorded on the Part II Good Retail Practices Verification Audit Worksheet. The worksheet is included at the end of the
instructions.
The auditor should only review those Food Code sections that the jurisdiction indicated were met. If a
Good Retail Practice Food Code section is selected that the jurisdiction indicated was not met, the
verification auditor should select a substitute Food Code section to review.
STEP 3 – Confirm Findings for Good Retail Practices
The auditor must review the randomly selected Food Code sections. The auditor must compare the
language in each of the selected jurisdiction food code sections to verify that it is at least as stringent as the
corresponding FDA Food Code section language. The language may be more stringent, but not less
stringent. Record an “X” in the appropriate box based on the determination.
Yes - Full Intent is Met or
No - Full Intent is not Met
In instances where the verification auditor determined that the jurisdiction’s language does not meet the
criterion, an explanation must be provided on the Verification Audit Worksheet. The auditor must record
the explanation under the column “If No, Auditor is to specify why the criterion is not met.”
STEP 4 – Document the Verification Audit Results for Part I
To meet the Part II – Good Retail Practices element of Standard 1, the jurisdiction’s regulatory
requirements must have a corresponding requirement for 95 percent of the FDA Food Code sections listed
in Part II of the Standard 1: Self-Assessment Worksheet.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

If four or more of the 13 selected Food Code sections do not meet the stringency of language criteria,
the Part II element fails to meet the criteria, and no further sampling is necessary. If one, two or three
of the 13 selected food code sections do not meet the stringency of the language criteria, then the
auditor must randomly select an additional 13 Food Code sections. No more than three total
disagreements are acceptable in the twenty-six (26) food code sections drawn for comparison in order
for the audit to confirm that the Part II element of Standard 1 was met.
Examples of documents that may be reviewed:
 The jurisdiction’s statute, regulation, rule, ordinance, or other prevailing set of regulatory
requirements that govern the operation of its food establishments
 Version of the Food Code that was used for the self-assessment
 Completed Standard 1: Self-Assessment Worksheet
* Part II – Good Retail Practices
 If applicable, documents discussing or comparing code provisions excepted if adoption was
made by reference with exceptions.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation
Verification Audit Worksheet
Part II – Good Retail Practices

Number of
Sections
Reviewed

Randomly
Selected
Number

Corresponding Food Code
Chapter from Part II Good
Retail Practices SelfAssessment Worksheet

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full
Intent
is Met

NO
Full
Intent is
not Met

If no, auditor must specify why criterion is not met

1
2
3
4
5
6
7
8
9
10
11
12
13
NOTES
1. If there is agreement that ALL 13 selected code sections meet the stringency of the language criteria in the FDA Food Code, proceed to Part III.
2. If one, two or three of the 13 selected code sections do not meet the stringency of the language criteria in the FDA Food Code, then complete the Supplemental Part II
section of the worksheet by randomly selecting another 13 Good Retail Food Practices code sections to review.

3. If four or more of the 13 selected code sections do not meet the stringency of the language criteria in the Food Code, then the jurisdiction does not meet the Standard 1
criteria for Part II Good Retail Food Practices.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 1: Regulatory Foundation
Verification Audit Worksheet
Supplement to Part II – Good Retail Practices
Number of
Sections
Reviewed

Randomly
Selected
Number

Corresponding Food Code
Chapter from Part II Good
Retail Practices SelfAssessment Worksheet

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full
Intent
is Met

NO
Full
Intent is
not Met

If no, auditor must specify why criterion is not met

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
NOTES
1. If more than three of the 26 total selected code sections do not meet the stringency of the language criteria in the Food Code, then the jurisdiction does not meet the
Standard 1 criteria for Good Retail Practices.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 1 - REGULATORY FOUNDATION
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A VERIFICATION
AUDIT
Part III – Compliance and Enforcement
STEP 1 – Review the Self-Assessment conducted for Compliance and Enforcement Food Code
provisions
The jurisdiction’s self-assessment of their Compliance and Enforcement provisions must indicate that
it has a corresponding regulatory requirement for the Food Code sections listed in Items 1 through 12 on
Part III of the Standard 1: Self-Assessment Worksheet. For Items 1 through 11, a jurisdiction must
demonstrate its regulations have a corresponding provision or language for all the Food Code sections
listed. For Item 12, a jurisdiction need only demonstrate that its regulatory foundation provides the
authority to implement one of the following three Food Code legal remedies pertaining to criminal,
injunctive, or civil penalties:
8-911.10 – Authorities, Methods, Fines and Sentences
8-912.10 – Petitions for Injunction
8-913.10 – Petitions, Penalties and Continuing Violations
STEP 2 – Determine Food Code Compliance and Enforcement Sections to Review
The verification auditor must randomly select five Compliance and Enforcement areas for the review
process. A list of random numbers can be obtained from the “Randomizer” web link: www.randomizer.
org. Using Part III of the jurisdiction’s Standard 1: Self-Assessment Worksheet, the verification auditor
will identify the Food Code sections that correspond to the randomly selected number recorded on Part
III of the Standard 1: Verification Audit Worksheet. This worksheet is included at the end of these
instructions.
When conducting a verification audit, the auditor will randomly select 5 of the 11 compliance and
enforcement areas to review. For each selected area, the jurisdiction must demonstrate its regulations
have a corresponding provision(s) or language for each Food Code section listed under that area.
In the case of Item 12, pertaining to "Legal Remedies", three Food Code sections comprise this
Compliance and Enforcement area. A jurisdiction must demonstrate a corresponding regulatory
requirement for one of the Food Code sections pertaining to criminal, injunctive, or civil penalties.
STEP 3 – Confirm Findings for Food Code Compliance and Enforcement Sections
The auditor must review the randomly selected Food Code sections. The auditor must compare the
language in each of the selected jurisdiction code sections to verify that it is at least as stringent as the
corresponding Food Code section language. The language may be more stringent, but not less stringent.
Record an “X” in the appropriate box based on the determination.
Yes - Full Intent is Met
or
No - Full Intent is not Met
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Voluntary National Retail Food Regulatory Program Standards – January 2022

In instances where the verification auditor determined that the jurisdiction’s language does not meet the
criterion, an explanation must be provided on the Verification Audit Worksheet. The auditor must record
the explanation under the column “If No, Auditor is to specify why the criterion is not met.”
Examples of documents that may be reviewed:
 The jurisdiction’s statute, regulation, rule, ordinance, or other prevailing set of regulatory
requirements that govern the operation of its food establishments
 Version of the FDA Food Code that was used for the self-assessment
 Completed Standard 1: Self-Assessment Worksheet, Part III – Compliance and Enforcement
 If applicable, documents discussing or comparing code provisions excepted if adoption was
made by reference with exceptions.
Summary for the Standard 1 – Regulatory Foundation Verification Audit
At the conclusion of the verification audit process, the jurisdiction’s Verification Audit Worksheet must
indicate that it meets the criteria in all three Parts of the Standard in order to fully meet the Standard I
requirement.
Part 1: Control of Foodborne Illness Public Health Interventions and Risk Factor Controls
Part II: Good Retail Practices
Part III: Compliance and Enforcement Administrative Provisions

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Standard 1: Regulatory Foundation
Verification Audit Worksheet
Part III – Compliance and Enforcement
Number of
Sections
Reviewed

Randomly
Selected
Number

Corresponding Food Code
Chapter from Part II Good
Retail Practices SelfAssessment Worksheet

Jurisdiction's
Corresponding
Code Section,
Rule, etc.

YES
Full
Intent
is Met

NO
Full
Intent is
not Met

If no, auditor must specify why criterion is not met

5
NOTES
1. Some Compliance and Enforcement Areas contain multiple Food Code Sections.
List all the pertinent Food Code Sections listed on the Self-Assessment
Worksheet for each of the Compliance and Enforcement areas that are randomly selected.
2. Meeting the Standard 1 criteria for the "Compliance and Enforcement" component requires a "Yes" for all Food Code sections listed in Items 1 through 11. For
Item 12 pertaining to legal remedies, the jurisdiction needs to demonstrate a corresponding regulatory requirement for only one of the sections pertaining to
criminal, injunctive, or civil penalties.
3. If there is agreement that ALL code sections within the 5 selected "Compliance and Enforcement" components meet the stringency of the language criteria in the
FDA Food Code, the Standard 1 criteria is met for Part III.
4. If one or more of the code sections within the 5 selected "Compliance and Enforcement" components do not meet the stringency of the language criteria
in the FDA Food Code, the jurisdiction does not meet the Standard 1 criteria for Part III.

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STANDARD 2 TRAINED REGULATORY STAFF
Table of Contents

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 2 TRAINED REGULATORY STAFF
This Standard applies to the essential elements of a training program for regulatory staff.
Requirement Summary
The regulatory retail food program inspection staff (Food Safety Inspection Officers - FSIO) shall have
the knowledge, skills, and ability to adequately perform their required duties. The following is a
schematic of a 5-step training and standardization process to achieve the required level of competency.
STEP 1
Completion of curriculum courses designated as “Pre” in Appendix B-1 prior to conducting and
independent routine inspections.
STEP 2
Completion of the following:
• A minimum of 25 joint field training inspections (or a sufficient number of joint inspections
determined by the trainer and verified through written documentation that the FSIO has
demonstrated all performance elements and competencies to conduct independent inspections of
retail food establishments); and
• Successful completion of the jurisdiction’s FSIO Field Training Plan similar to the process
outlined in Appendix B-2: Conference for Food Protection (CFP) Field Training Manual.
STEP 3
Completion of the following:
• A minimum of 25 independent inspections; and
• Remaining course curriculum (designated as “post” courses) outlined in Appendix B-1:
Curriculum for Retail Food Safety Inspection Officers.
STEP 4
Completion of a standardization process similar to the FDA standardization procedures.
STEP 5
Completion of 20 contact hours of continuing food safety education every 36 months after the initial
training is completed.
Description of Requirement
Ninety percent (90 %) of the regulatory retail food program inspection staff (Food Safety Inspection
Officers - FSIO) shall have successfully completed the required elements of the 5-step training and
standardization process:
• Steps 1 through 4 within 24 months of hire or assignment to the retail food regulatory program.
• Step 5 every 36 months after the initial 24 months of training.

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Step 1: Pre-Inspection Curriculum
Prior to conducting any type of independent field inspections in retail food establishments, the FSIO must
satisfactorily complete training in pre-requisite courses designated with a “Pre” in Appendix B-1, for the
following curriculum areas:
1. Prevailing statutes, regulations, ordinances (specific laws and regulations to be addressed by each
jurisdiction);
2. Public Health Principles;
3. Food Microbiology; and
4. Communication Skills.
There are two options for demonstrating successful completion of the pre-inspection curriculum.
OPTION 1: Completion of the pre-inspection curriculum may be demonstrated by successful completion
of the following:
• FDA ORA U pre-requisite courses identified as “Pre” in Appendix B-1; and
• Training on the jurisdiction’s prevailing statutes, regulations, and/or ordinances.
Note: The estimated contact time for completion of the FDA ORA U pre-requisite (“Pre”) courses is 42
hours.
OPTION 2: Completion of the pre-inspection curriculum may be demonstrated by successful completion
of the following:
• Successful completion of courses deemed by the regulatory jurisdiction’s food program supervisor
or training officer to be equivalent to the FDA ORA U pre- requisite (Pre”) courses; and
• Training on the jurisdiction’s prevailing statutes, regulations, and/or ordinances; and
• Successful passing of one of the four written examination options (described later in this Standard)
for determining if a FSIO has a basic level of food safety knowledge.
A course is deemed equivalent if it can be demonstrated that it covers at least 80% of the learning
objectives of the comparable ORA U course AND verification of successful completion is provided. The
learning objectives for each of the listed ORA U courses are available from the web site link at:
https://www.fda.gov/training-and-continuing-education/office-training-education-and-developmentoted/state-local-tribal-and-territorial-regulatory-partners
Note: While certificates issued by course sponsors are the ideal proof of attendance, other official
documentation can serve as satisfactory verification of attendance. The key to a document’s
acceptability is that someone with responsibility, such as a trainer/food program manager who has
first-hand knowledge of employee attendance at the session, keeps the records according to an
established protocol. An established protocol can include such items as:
• Logs/records that are completed based on sign-in sheets; or
• Information validated from the certificate at the time-of-issuance; or
• A college transcript with a passing grade or other indication of successful completion of the
course; or
• Automated attendance records, such as those currently kept by some professional associations
and state agencies, or
• Other accurate verification of actual attendance.
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Regulatory retail food inspection staff submitting documentation of courses equivalent to the FDA ORAU
courses – OPTION 2 – must also demonstrate a basic level of food safety knowledge by successfully
passing one examination from the four written examination categories specified herein.
1. The Certified Food Safety Professional examination offered by the National Environmental Health
Association; or
2. A state sponsored food safety examination that is based on the current version of the FDA Food
Code (and supplement) and is developed using methods that are psychometrically valid and
reliable; or
3. A food manager certification examination provided by an ANSI/CFP accredited certification
organization; or
4. A Registered Environmental Health Specialist or Registered Sanitarian examination offered by the
National Environmental Health Association or a State Registration Board.
Note: Written examinations are part of a training process, not a standardization/certification process.
The examinations listed are not to be considered equivalent to each other. They are to be considered
as training tools and have been incorporated as part of the Standard because each instrument will
provide a method of assessing whether a FSIO has attained a basic level of food safety knowledge. Any
jurisdiction has the option and latitude to mandate a particular examination based on the laws and
rules of that jurisdiction.
Step 2: Initial Field Training and Experience
The regulatory staff conducting inspections of retail food establishments must conduct a minimum of 25
joint field inspections with a trainer who has successfully completed all training elements (Steps 1 – 3)
of this Standard. The 25 joint field inspections are to be comprised of both “demonstration” (trainer led) and
“training” (trainee led) inspections and include a variety of retail food establishment types available within
the jurisdiction.
If the trainer determines that the FSIO has successfully demonstrated the required performance elements
and competencies, a lower minimum number of joint field training inspections can be established for that
FSIO provided there is written documentation, such as the completion of the CFP Field Training Plan in
Appendix B-2, to support the exception.
Note: The CFP Field Training Manual is available for the Conference for Food Protection web site:
http://www.foodprotect.org/ and is located under the icon titled “Conference Developed Guides and
Documents.”
Demonstration inspections are those in which the jurisdiction’s trainer takes the lead and the candidate
observes the inspection process. Training inspections are those in which the candidate takes the lead, and
their inspection performance is assessed and critiqued by the trainer. The jurisdiction’s trainer is

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Voluntary National Retail Food Regulatory Program Standards – January 2022

responsible for determining the appropriate combination of demonstration and training inspections based
on the candidate’s food safety knowledge and performance during the joint field inspections.
The joint field inspections must be conducted using a field training process and forms similar to ones
presented in the CFP Field Training Manual included as Appendix B-2. The CFP Field Training Manual
consists of a training plan and log, trainer’s worksheets, and procedures that may be incorporated into any
jurisdiction’s retail food training program. It is a national model upon which jurisdictions can design
basic field training and provides a method for FSIOs to demonstrate competencies needed to conduct
independent inspections of retail food, restaurant, and institutional foodservice establishments.
Jurisdictions are not required to use the forms or worksheets provided in the CFP Field Training Manual.
Equivalent forms or training processes can be developed. To meet the intent of the Standard,
documentation must be maintained that confirms FSIOs are trained on, and have demonstrated, the
performance element competencies needed to conduct independent inspections of retail food and/or
foodservice establishments.
Note: The CFP Field Training Manual is designed as a training approach providing a structure for
continuous feedback between the FSIO and trainer on specific knowledge, skills, and abilities that are
important elements of effective retail food, restaurant, and institutional foodservice inspections.
• The CFP Field Training Manual is NOT intended to be used for certification or licensure
purposes.
• The CFP Field Training Manual is NOT intended to be used by regulatory jurisdictions for
administrative purposes such as job classifications, promotions, or disciplinary actions.
FSIOs must successfully complete a joint field training process, similar to that presented in the CFP Field
Training Manual, prior to conducting independent inspections and re-inspections of retail food
establishments in risk categories 2, 3, and 4 as presented in Appendix B-3 (taken from Annex 5, Table 1
of the 2013 FDA Food Code). The jurisdiction’s trainer/food program manager can determine if the FSIO
is ready to conduct independent inspections of risk category 1 establishments (as defined in Appendix B3) at any time during the training process.
Note: The criterion for conducting a minimum of 25 joint field training inspections is intended for new
employees or employees new to the food safety program. In order to accommodate an experienced
FSIO, the supervisor/training officer can in lieu of the 25 joint field inspections:
• Include a signed statement or affidavit in the employee’s training file explaining the
background or experience that justifies a waiver of this requirement; and
• The supervisor/training officer must observe experienced FSIOs conduct inspections to
determine any areas in need of improvement. An individual corrective action plan should be
developed outlining how any training deficiencies will be corrected and the date when
correction will be achieved.

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Step 3: Independent Inspections and Completion of ALL Curriculum Elements
Within 24 months of hire or assignment to the regulatory retail food program, Food Safety Inspection
Officers must complete a minimum of 25 independent inspections of retail food, restaurant, and/or
institutional foodservice establishments.
• If the jurisdiction’s establishment inventory contains a sufficient number of facilities, the FSIO must
complete 25 independent inspections of food establishments in risk categories 3 and 4 as described
in Appendix B-3.
• For those jurisdictions that have a limited number of establishments which would meet the risk
category 3 and/or 4 criteria, the FSIO must complete 25 independent inspections in food
establishments that are representative of the highest risk categories within their assigned
geographic region or training area.
In addition, all coursework identified in Appendix B-1, for the following eight curricula areas, must be
completed within this 24-month time frame.
1. Prevailing statutes, regulations, ordinances (all courses for this element are part of the prerequisite curriculum outlined in Step 1);
2. Public health principles (all courses for this element are part of the pre-requisite curriculum
outlined in Step 1);
3. Communication skills (Step 1);
4. Food microbiology (some of the courses for this element are part of the pre-requisite curriculum
outlined in Step 1);
5. Epidemiology;
6. Hazard Analysis Critical Control Points (HACCP);
7. Allergen Management
8. Emergency Management
All courses for each of the curriculum areas must be successfully completed within 24 months of hire or
assignment to the regulatory retail food program in order for FSIOs to be eligible for the Field
Standardization Assessment.
Note: The estimated contact time for completion of the FDA ORA U “post” courses is 26 hours. The
term “post” refers to those courses in Appendix B-1 that were not included as part of the prerequisite coursework. This includes all the courses in Appendix B-1 that do not have the designation
“Pre” associated with them. All courses in Appendix B-1 must be successfully completed prior to
conducting field standardizations.
As with the pre-requisite inspection courses, the coursework pertaining to the above six curriculum areas
can be successfully achieved by completing the ORA U courses listed under each curriculum area OR
by completing courses, deemed by the regulatory jurisdiction’s food program supervisor or training
officer to be equivalent to the comparable FDA ORA U courses.
A course is deemed equivalent if it can be demonstrated that it covers at least 80% of the learning
objectives of the comparable ORA U course AND verification of successful completion can be provided.
The learning objectives for each of the listed ORA U courses are available from the FDA website:
https://www.fda.gov/training-and-continuing-education/office-training-education-and-developmentoted/state-local-tribal-and-territorial-regulatory-partners.
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Step 4: Food Safety Inspection Officer – Field Standardization
Within 24 months of employment or assignment to the retail food program, staff conducting inspections
of retail food establishments must satisfactorily complete four joint inspections with a “training standard”
using a process similar to the “FDA Standardization Procedures.” The jurisdiction’s “training standard”
must have met all the requirements for conducting field standardizations as presented in the definition
section of these Standards. The standardization procedures shall determine the inspector’s ability to apply
the knowledge and skills obtained from the training curriculum, and address the five following
performance areas:
1.
2.
3.
4.
5.

Risk-based inspections focusing on the factors that contribute to foodborne illness;
Good Retail Practices;
Application of HACCP;
Inspection equipment; and
Communication.

Continuing standardization (re-standardization) shall be maintained by performing four joint inspections
with the "training standard" every three years.
Note: The field standardization and continuing standardization (re-standardization) criteria
described in Step 4 is intended to provide a jurisdiction the flexibility to use their own regulation or
ordinance. In addition, the reference to using standardization procedures similar to the FDA
Procedures for Standardization of Retail Food Inspection Training Officers, is intended to allow the
jurisdiction the option to develop its own written protocol to ensure that personnel are trained and
prepared to competently conduct inspections. Any written standardization protocol must include the
five performance areas outlined above in Step 4.
It is highly beneficial to use the FDA Food Code, standardization forms and procedures even when a
jurisdiction has adopted modifications to the Food Code. Usually, regulatory differences can be
noted and discussed during the exercises, thereby enhancing the knowledge, and understanding of the
candidate. The scoring and assessment tools presented in the FDA standardization procedures can
be used without modification regardless of the Food Code enforced in a jurisdiction. The scoring
and assessment tools are, however, specifically tied to the standardization inspection form and other
assessment forms that are a part of the FDA procedures for standardizations.
FDA’s standardization procedures are based on a minimum of 8 inspections. However, to meet
Standard 2, a minimum of 4 standardization inspections must be conducted.
Jurisdictions that modify the limits of the standardization process by reducing the minimum number
of inspections from 8 to 4 are cautioned that a redesign of the scoring assessment of the candidate’s
performance on the field inspections is required. This sometimes proves to be a very difficult task. A
jurisdiction must consider both the food safety expertise of its staff, as well as the availability of
personnel versed in statistical analysis before it decides to modify the minimum number of
standardization inspections. The jurisdiction’s standardization procedures need to reflect a credible
process and the scoring assessment should facilitate

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consistent evaluation of all candidates.
The five performance areas target the behavioral elements of an inspection. The behavioral elements
of an inspection are defined as the manner, approach and focus which targets the most important
public health risk factors and communicates vital information about the inspection in a way that can
be received, understood, and acted upon by retail food management. The goal of standardization is
to assess not only technical knowledge but also an inspector’s ability to apply his or her knowledge in
a way that ensures the time and resources spent within a facility offer maximum benefit to both the
regulatory agency and the consuming public. Any customized standardization procedure must
continue to meet these stated targets and goals.
Should a jurisdiction fall short of having 90% of its retail food program inspection staff successfully
complete the Program Standard 2 criteria within the 24- month time frame, a written protocol must be
established to provide a remedy so that the Standard can be met. This protocol would include a corrective
action plan outlining how the situation will be corrected and the date when the correction will be
achieved.
Step 5: Continuing Education and Training
A FSIO must accumulate 20 contact hours of continuing education in food safety every 36 months after
the initial training (24 months) is completed. Within the scope of this standard, the goal of continuing
education and training is to enhance the FSIO’s knowledge, skills, and ability to perform retail food and
foodservice inspections. The objective is to build upon the FSIO’s knowledge base. Repeated coursework
should be avoided unless justification is provided to, and approved by, the food program manager and/or
training officer.
Training on any changes in the regulatory agency’s prevailing statutes, laws and/or ordinances must be
included as part of the continuing education (CE) hours within six months of the regulatory change.
Documentation of the regulatory change date and date of training must be included as part of the
individual’s training record.
The candidate qualifies for one contact hour of continuing education for each clock hour of participation
in any of the following nine activities that are related specifically to food safety or food inspectional
work:
1.
2.
3.
4.
5.

Attendance at FDA Regional seminars / technical conferences;
Professional symposiums / college courses;
Food-related training provided by government agencies (e.g., USDA, State, local);
Food safety related conferences and workshops; and
Distance learning opportunities that pertain to food safety, such as:
• Web based or online training courses (e.g., additional food safety courses offered though ORA
U, industry associations, universities); and
• Satellite Broadcasts.

A maximum of ten (10) contact hours may be accrued from the following activities:

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Voluntary National Retail Food Regulatory Program Standards – January 2022

1. Delivering presentations at professional conferences;
2. Providing classroom and/or field training to newly hired FSIOs, or being a course instructor in
food safety; or
3. Publishing an original article in a peer-reviewed professional or trade association
journal/periodical.
Contact hours for a specified presentation, course, or training activity will be recognized only one time
within a 3-year continuing education period1.
Note: Time needed to prepare an original presentation, course, or article may be included as part of the
continuing education hours. If the FSIO delivers a presentation or course that has been previously
prepared, only the actual time of the presentation may be considered for continuing education credit.
A maximum of four (4) contact hours may be accrued for:
1. Reading technical publications related to food safety.
Documentation must accompany each activity submitted for continuing education credit. Examples of
acceptable documentation include:
• certificates of completion indicating the course date(s) and number of hours attended or CE
credits granted;
• transcripts from a college or university;
• a letter from the administrator of the continuing education program attended;
• a copy of the peer-reviewed article or presentation made at a professional conference; or
• documentation to verify technical publications related to food safety have been read including
completion of self-assessment quizzes that accompany journal articles, written summaries of key
points/findings presented in technical publications, and/or written book reports.
Note: The key to a document’s acceptability is that someone with responsibility, such as a training
officer or supervisor, who has first-hand knowledge of employee’s continuing education activities,
maintains the training records according to an established protocol similar to that presented in Step
1 for assessing equivalent courses.
Outcome
The desired outcome of this Standard is a trained regulatory staff with the skills and knowledge
necessary to conduct quality inspections.
Documentation
The quality records needed for this standard include:
1. Certificates or proof of attendance from the successful completion of all the course elements
identified in the Program Standard curriculum (Steps 1 and 3);

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Voluntary National Retail Food Regulatory Program Standards – January 2022

2. Documentation of field inspection reports for twenty-five each joint and independent inspections
(Steps 2 and 3);
3. Certificates or other documentation of successful completion of a field training process similar to
that presented in Appendix B-2. NOTE: The CFP Field Training Manual is available for the
Conference for Food Protection web site: http://www.foodprotect.org/ and is located under the
icon titled “Conference Developed Guides and Documents.”
4. Certificates or other records showing proof of satisfactory standardization (Step 4);
5. Contact hour certificates or other records for continuing education (Step 5);
6. Signed documentation from the regulatory jurisdiction’s food program supervisor or training
officer that food inspection personnel attended and successful completed the training and
education steps outlined in this Standard.
7. Date of hire records or assignment to the retail food program; and
8. Summary record of employees’ compliance with the Standard.
The Standard 2: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process for Standard 2.

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STANDARD 2 – TRAINED REGULATORY STAFF
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment & Verification Audit Form
The Standard 2: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process for Standard 2. The form is included
at the end of these instructions. Whether one is performing a program self-assessment or conducting a
verification audit, it is recommended that the form be available as a reference to the Standards 2 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of the “Trained Regulatory Staff” component of their retail
food protection program must indicate on the form if each of the Standard 2 criterion is met. These
responses are recorded under the column, “Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use the form. An equivalent form or process is acceptable provided
that the results of the jurisdiction’s self-assessment for the specific Standard 2 criteria listed are
available for review.
The self-assessor will review each Standard 2 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must place
an “X” in the “YES” box under the “Jurisdiction’s Self-Assessment “column of the Standard 2: Program
Self-Assessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 2 criteria are met,
the self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column
of the Standard 2: Program Self-Assessment and Verification Audit Form. The self-assessor may specify
why the criteria are not met in the box provided.
The self-assessor should review the findings on the Standard 2: Program Self-Assessment and
Verification Form to ensure accuracy. The jurisdiction will be required to provide the auditor with their
completed Program Self-Assessment and Verification Audit Form and any documents used to support
and demonstrate that the Standard 2 criteria have been met.
Once all the Standard 2 criteria have been reviewed and staff training records documented on the form,
the self-assessor must complete the Program Self-Assessment Summary section on page one of the
Standard 2: Program Self-Assessment and Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 2 criteria in the appropriate boxes; and
• Sign the form where indicated.

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It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 2 criteria.
Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 2: Program SelfAssessment and Verification Audit Form to the auditor for review. Auditors must indicate on the Standard
2: Program Self-Assessment and Verification Audit Form if each of the criterion were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion
that the Standard criteria are met, the verification auditor places an “X” in the “NO” box under the
“Auditor’s Verification” column of the form. The verification auditor must specify why the
criterion is not met in the box provided. Supplemental pages may be used to explain findings.
To meet the Standard criteria, the jurisdiction must have demonstrated that 90% of their staff
assigned responsibilities for retail food and/or foodservice inspections successfully completed
the training curriculum, field training, field standardization, and continuing education requirements.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the on-site visit. In particular,
any Standard 2 criteria for which the auditor cannot confirm through a review of the self-assessment
should be thoroughly discussed. Ample time should be allotted to ensure that there is a clear
understanding of the reasons for the “non-conforming” finding. The auditor should be prepared to
identify the elements required for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on the first page of the Standard 2: Program Self-Assessment and Verification
Audit Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 2 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 2 criteria if the auditor does not confirm the selfassessment findings.

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Standard 2: Program Assessment
Program Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
FAX:
E-mail:
Date the Standard 2 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard
2 criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 2 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
FAX:
E-mail:
Date the Verification Audit of Standard 2 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the
Standard 2 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 2 is true and correct.
Signature of the Verification Auditor:

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 2: Program Assessment
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: ________________________________________________________________________________________________________
Criteria

1. Employee
Training
Records

2. Initial Field
Training

2-14

Element
a) The jurisdiction maintains a
written training record for each
employee that includes the date
of hire or assignment to the
agency's retail food protection
program.
b) The jurisdiction’s written
training record provides
documentation that each
employee has completed the
Standard 2 prerequisite ("Pre")
training curriculum PRIOR to
conducting independent retail
food or foodservice inspections.
a) The jurisdiction maintains a
written training record that
provides confirmation that each
employee completed a minimum
of 25 joint field training
inspections of retail food and/or
foodservice establishments (if
less than 25 joint field training
inspections are performed,
written documentation on file
that FSIO has successfully
demonstrated all required
inspection competencies) PRIOR
to conducting retail food or
foodservice inspections.

Jurisdiction’s
SelfAssessment
YES

Jurisdiction’s
SelfAssessment
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
Verification
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

2. Initial Field
Training

3.
Independent
Inspections /
Completion of
ALL
Curriculum
Requirements
3.
Independent
Inspections /
Completion of
ALL
Curriculum
Requirements

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Element
b) The jurisdiction maintains a
written training record that
provides confirmation that each
employee successfully
completed a field training
process similar to that contained
in the CFP Field Training
Manual provided in Appendix
B-2, Standard 2, PRIOR to
conducting independent
inspections of retail food and/or
foodservice establishments.
a) The jurisdiction maintains a
written training record that
provides confirmation that each
employee completed a
minimum of 25 independent
retail food and/or foodservice
inspections PRIOR to field
standardization.
b) The jurisdiction's written
training record provides
documentation that each
employee has completed ALL
aspects of the Standard #2
training curriculum ("Pre") and
("Post") courses prior to field
standardization.

Jurisdiction’s
SelfAssessment
YES

Jurisdiction’s
SelfAssessment
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
Verification
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

4. Field
Standardization

5. Continuing
Education and
Training

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Element

Jurisdiction’s
SelfAssessment
YES

Jurisdiction’s
SelfAssessment
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
Verification
NO

a) The jurisdiction maintains
a written training record that
provides documentation that
each employee successfully
completed a Standardization
process similar to the FDA
Procedures for
Standardization within 24
months of hire or assignment
to the retail food protection
program.
b) The jurisdiction maintains
a written training record that
provides documentation that
each standardized employee
has maintained their
standardization by performing
a minimum of 4 joint
inspections with a "training
standard" every 3 years.
a) The jurisdiction maintains
a written training record that
provides documentation that
each employee conducting
retail food and/or foodservice
inspections has accumulated
20 hours of continuing
education every 36 months
after the initial training (24)
months is completed.
GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 2 – TRAINED REGULATORY STAFF
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELFASSESSMENT
STEP 1 – Document Employee Training Records
The jurisdiction should document and retain a training record for each employee. The training record
must include the date of hire or assignment to the retail food program. The Standard 2: Self-Assessment
Worksheet may be used by the jurisdiction as a training record. The worksheet is included at the end of
these instructions. In lieu of the Standard 2 Self-Assessment Worksheet, other manual forms or
automated records may be used by the jurisdiction to retain training records related to the selfassessment as long as the information required in the Standard 2 criteria is documented in some manner.
STEP 2 – Document Employees Completion of Pre-Requisite “Pre” Training Curriculum
Standard 2 requires the FSIO to complete the pre-requisite coursework listed in Appendix B-1 prior to
conducting independent inspections of retail food establishments. The program areas covered in the
pre-requisite coursework include training on prevailing statutes, regulations, ordinances; public health
principles; communication skills, and microbiology. The date each employee fully completed the
Standard 2 pre-requisite curriculum must be recorded on the Standard 2 Self-Assessment Worksheet.
STEP 3 – Document Employees Completion of Initial Field Training
Standard 2 requires a minimum of 25 joint field training inspections to be conducted with a trainer who
has successfully completed all the Standard 2 training elements (Steps 1 – 3). The joint field training
inspections must be completed prior to conducting independent inspections of retail food establishments.
The joint field inspections must be conducted using a field training process, established by the
jurisdiction, similar to the one presented in the CFP Field Training Manual. The CFP Field Training
Manual is included as Appendix B-2. The date each employee completed the Standard 2 field training
requirement must be recorded on the Standard 2 Self-Assessment Worksheet.
STEP 4 – Document Employees Completion of Independent Inspections / All Curriculum
Requirements
Standard 2 requires a minimum of 25 independent retail food establishment inspections to be conducted
by employees in various establishment types. These independent inspections must be completed prior to
field standardization. In addition, all “Post” curriculum courses identified in Appendix B-1 must be
successfully completed for FSIOs to be eligible for the Field Standardization Assessment. The date each
employee completed 25 independent inspections AND the Standard 2 “Post” curriculum training
requirement must be recorded on the Standard 2 Self-Assessment Worksheet.
STEP 5 – Document Employees Completion of Field Standardization
Within 24 months of employment or assignment to the retail food program, staff conducting inspections
of retail food establishments must satisfactorily complete four joint inspections

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Voluntary National Retail Food Regulatory Program Standards – January 2022

with a “training standard” using a process similar to the “FDA Standardization Procedures.” The
procedure used for standardization does not have to be identical to the FDA Procedures for
Standardization of Retail Food Inspection/Training Officers. However, it must include a determination of
the following:
1. The inspector’s ability to apply the knowledge and skills obtained from the training
curriculum; and
2. The inspector’s ability in the following five performance areas:
 Conducting risk-based inspections (i.e., primary focus on the risk factors that contribute
to foodborne illness),
 Recognizing good retail practice requirements,
 Applying HACCP principles to the inspection process,
 Demonstrating knowledge and use of essential inspection equipment, and
 Communicating in an effective manner.
NOTE: For new hires or employees newly assigned to the retail food protection program, the date
recorded in the “Completion of Field Standardization” column must be within 24 months of the date
recorded in the “Date of Hire or Assignment to the Retail Food Protection Program.”
For experienced employees, however, the completion date for standardization may be in excess of 24
months of their date of hire. This is because the jurisdiction may not have been standardizing their retail
food protection program staff prior to enrollment in the Program Standards. Keep in mind that the
Standard 2 language was written to establish a training and standardization process for new employees.
As long as the experienced FSIO has successfully completed standardization at the time of the selfassessment the Standard 2 criteria is met.
The date each employee successfully completes field standardization must be recorded on the
Standard 2: Self-Assessment Worksheet.
STEP 6 – Document Employee Continuing Education and Training
Each employee must accumulate 20 contact hours of continuing education training every 36 months. For
employees newly hired or newly reassigned to the retail food program, the 36-month period does not
begin until after the first 24 months of training. For existing employees, the 36-month period does not
begin until a jurisdiction enrolls as a participant in the Standards. The date each employee accumulated 20
contact hours of continuing education within the 36 months of their most current standardization/restandardization cycle must be recorded on the Standard 2 Self-Assessment Worksheet.
STEP 7 – Document the Self-Assessment Results
The self-assessor must document if each of the listed employees met the Standard 2 criteria. The
self-assessor’s response should be recorded in the Self-Assessment Worksheet under the column “Meets
the Standard 2 Criteria YES or NO.” A jurisdiction meets the Standard 2 criteria if ninety percent (90%)
of the retail food program inspection staff fulfilled all the training and standardization requirements
within the specified time frames.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 2: Trained Regulatory Staff
Self-Assessment Worksheet Training Record for Each Employee
(*indicates completion date required)

Employee Name

No.

Completion of
Training PreDate of Hire or
Assignment to the requisite (“Pre”)
Curriculum* (Prior
Retail Food
to conducting
Program
independent
inspections)

Completion of a Minimum
Completion of a
Completion of Field
of 25 Joint Field Training
Minimum 25
Standardization*
Inspections*
Independent
(within 24 months
AND
Inspections* AND
of hire or
Successful completion of
“Post” Curriculum
assignment
to the
a field training process
Courses* (within 24
Retail Food
similar to the CFP Field
months of hire or
Program)
Training Manual in
assignment to the Retail
Appendix B-2
Food Program

Number of
Meets the
Education
Standard
Contact Hours
2 Criteria
(Minimum of 20
Contact Hours
YES or No
Every 3 Years)

1
2
3
4
5
6
7
8
9
10
11
12

NOTE:
1. Ninety percent (90% of the staff must meet each training element for the Jurisdiction to meet Standard 2-Trained Regulatory Staff.
2. Based on the documentation from this worksheet, record your finding for each of the items on the Standard 2: Program Self-Assessment and
Verification Audit Form.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

ADDITIONAL STANDARD 2 VERIFICATION AUDIT WORKSHEET (if needed)

Standard 2: Trained Regulatory Staff
Self-Assessment Worksheet Training Record for Each Employee
(*indicates completion date required)

Employee Name

No.

Completion of
Training PreDate of Hire or
Assignment to the requisite (“Pre”)
Curriculum* (Prior
Retail Food
to conducting
Program
independent
inspections)

Completion of a Minimum
Completion of a
of 25 Joint Field Training
Minimum 25
Completion of Field
Number of
Meets the
Inspections*
Independent Inspections Standardization*
Education
Standard
AND
AND
(within 24 months of Contact Hours
2 Criteria
Successful completion of
“Post” Curriculum
hire or assignment (Minimum of 20
a field training process
Courses* (within 24
to the Retail Food
Contact Hours
YES or No
similar to the CFP Field
months of hire or
Program)
Every 3 Years)
Training Manual in
assignment to the Retail
Appendix B-2
Food Program

1
2
3
4
5
6
7
8
9
10
11
12

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 2-TRAINED REGULATORY STAFF
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A VERIFICATION
AUDIT
STEP 1 – Verify Employees Training Records
The jurisdiction should document and retain a training record for each employee. The training record must
include the date of hire or assignment to the retail food program. The Standard 2 Self-Assessment
Worksheet may be used by the jurisdiction as a training record. The worksheet is included at the end of
these instructions. In lieu of the Standard 2 Self-Assessment Worksheet, other manual forms or automated
records may be used by the jurisdiction to retain training records related to the self- assessment as long as
the information required in the Standard 2 criteria is documented in some manner.
STEP 2 – Verify Jurisdiction’s Worksheet Percentage Calculation
Review the jurisdiction’s Standard 2 Self-Assessment Worksheet, or equivalent documentation, to
determine if the results of the jurisdiction’s self-assessment indicate that ninety percent (90%) of the retail
food program staff successfully completed all the Standard 2 training and standardization elements within
the required time frames. If audit calculations result in a percentage that is less than 90%, the auditor can
conclude that the jurisdiction does not meet the Standard 2 criteria. If this conclusion is reached, the audit
process for Standard 2 is completed. There is no need to randomly select and review individual employee
training records.
STEP 3 – Determine the Number of Employee Training Records to Review
If the jurisdiction used the Standard 2: Self-Assessment Worksheet, the employees will be
listed in numerical order. The verification auditor must use a random selection method to determine which
employees’ training records will be reviewed. Employees should be substituted during the random
selection process if they meet one of the following criteria:
1. The employee has been employed or worked in the retail food program for less than 24 months; or
2. The employee is no longer assigned to the retail food program; or
3. The self-assessor indicated on the Self-Assessment Worksheet that the employee did not meet each
Standard 2 element.
The number of training records that must be randomly selected is based on the number of employees
conducting retail food establishment inspections. Use the chart below to determine the number of
employee training records to review.
Number of Employees Number of Files to Select
5 or less
All
20 or less
5
21 or more
25 percent

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STEP 4 – Obtain Random Numbers
A list of random numbers can be obtained from the following web site: www.randomizer.org
Record the random numbers generated from the web site (or from an alternate random number selection
process) on the Standard 2 Verification Audit Worksheet. The worksheet is included at the end of these
instructions.
STEP 5 – Select Employee Training Records to Review
Using the jurisdiction’s Standard 2 Self-Assessment Worksheet, or equivalent documentation, the
verification auditor must identify the employee training records that correspond to the randomly
selected numbers recorded on the Standard 2 Verification Audit Worksheet. Record the employee’s
name adjacent to the corresponding random number on the Standard 2 Verification Audit Worksheet.
Only those employees’ training records that the jurisdiction reports as meeting all the Standard 2
training and standardization elements are to be reviewed. If an employee is randomly selected but the
jurisdiction indicated that employee does not meet the Standard 2 criteria, the verification auditor
should randomly select a substitute employee training record to review.
STEP 6 – Verify Documentation of the Completion of the Standard Training Criteria
The verification auditor must review the training file for each of the randomly selected employees to
confirm completion of the following items:
 coursework related to the Standard 2 Pre-requisite (“Pre”) curriculum;
 a minimum of 25 joint field training inspection, including documentation that confirms
Food Safety Inspection Officers (FSIOs) are trained on, and have demonstrated, the
performance element competencies needed to conduct independent inspections of retail food
and/or foodservice establishments;
 a minimum of 25 independent inspections and ALL the Standard 2 (“Post”) curriculum
requirements;
 field standardization within 18 months of hire or re-standardization every three years after
initial standardization, and
 20 hours of food safety related continuing education every three years
NOTE: For new hires or employees newly assigned to the retail food protection program, the date
recorded in the “Completion of Field Standardization” column must be within 18
months of the date recorded in the “Date of Hire or Assignment to the Retail Food Protection
Program.”
For experienced employees, however, the completion date for standardization may be in excess of 18
months of their date of hire. This is because the jurisdiction may not have been standardizing their retail
food protection program staff prior to enrollment in the Program Standards. Keep in mind that the
Standard 2 language was written to establish a training and standardization process for new employees.
As long as the experienced FSIO has successfully completed standardization at the time of the selfassessment the Standard 2 criteria is met.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STEP 7 – Making a Determination Based on the Results of the Audit
For each employee training file reviewed, the verification auditor must mark the appropriate box on
the Standard 2 Verification Audit Worksheet. The auditor must indicate “YES –Standard 2 criteria
are met” or “NO” – Standard 2 criteria is not met.” If the verification auditor determines an
employee training record did not meet the Standard 2 criteria, an explanation must be provided noting
any deficiencies. A jurisdiction meets the Standard 2 criteria if ninety percent (90%) of the retail food
program inspection staff fulfilled all the training and standardization requirements within the specified
time frames.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 2: Trained Regulatory Staff
Verification Audit Worksheet

No.

Randomly
Selected
Number

Employee Name

Yes
Standard 2
Criteria are Met

No
Standard 2
Criteria are
Not Met

If NO, auditor is to specify why criterion is not met

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
NOTE:
1. All randomly selected employee training records must contain documentation that the Standard 2 training and standardization elements
have been successfully completed.
2. Based on the documentation from this worksheet, record your determination for each of the items on the jurisdiction’s Standard 2:
Program Self-Assessment and Verification Audit Form.

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Voluntary National Retail Food Regulatory Program Standards – January 2022
ADDITIONAL STANDARD 2 VERIFICATION AUDIT WORKSHEET (if needed)

Standard 2: Trained Regulatory Staff
Verification Audit Worksheet

No.

Randomly
Selected
Number

Employee Name

Yes
Standard 2
Criteria are Met

No
Standard 2
Criteria are
Not Met

If NO, auditor is to specify why criterion is not met

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
NOTE:
1. All randomly selected employee training records must contain documentation that the Standard 2 training and standardization
elements have been successfully completed.
2. Based on the documentation from this worksheet, record your determination for each of the items on the jurisdiction’s Standard
2: Program Self-Assessment and Verification Audit Form.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 2: Trained Regulatory Staff
APPENDIX B-1: Curriculum for Retail Food Safety Inspection Officers
NOTE about course information: The courses listed below are updated and moved across different
learning management systems over time. The latest information will be posted on the FDA Program
Standards Landing Page at https://www.fda.gov/food/voluntary-national-retail-food-regulatoryprogram-standards/voluntary-national-retail-food-regulatory-program-standards-november-2019
For state, local, tribal, & territorial (SLTT) regulators to register on-line for free access to web
courses, go to: https://www.fda.gov/training-and-continuing-education/office-training-education-anddevelopment-oted/state-local-tribal-and-territorial-regulatory-partners
Pre-requisite (“Pre”) Curriculum Courses
(To be completed during the 25 joint inspection period AND prior to conducting any independent
inspections)
PUBLIC HEALTH PRINCIPLES
Courses
1-Public Health Principles

Courses
1-Overview of Microbiology
2A-Gram Negative Rods
2B-Gram-Positive Rods & Cocci
3- Foodborne Viruses
4- Foodborne Parasites
Mid-Series Exam
5- Controlling Growth Factors
6-Control by Refrigeration & Freezing
7A-Control by Thermal Processing
7B- Control by Pasteurization
10- Aseptic Sampling
12-Cleaning & Sanitizing

Course Number

FDA36 (90)

MICROBIOLOGY

Course Number

MIC01 (60)
MIC02 (60)
MIC03 (90)
MIC04 (60)
MIC05 (90)
MIC16 (30)
MIC06 (90)
MIC07 (60)
MIC08 (90)
MIC09 (90)
MIC13 (90)
MIC15 (90)

PREVAILING STATUTES, REGULATIONS, ORDINANCES

Courses
1. Basic Food Law for State Regulators
2. Basics of Inspection: Beginning an Inspection
3. Basics of Inspection: Issues & Observations

4. An Introduction to Food Security Awareness

2-26

Course Number

FDA35 (60)
FDA38 (90)
FDA39 (90)
FD251 (60) A PDF/READABLE VERSION at
(https://www.fda.gov/training-and- continuingeducation/office-training-education-anddevelopment-oted/introduction-food-securityawareness) Note: Required exam is available via
www.compliancewire.com.

Voluntary National Retail Food Regulatory Program Standards – January 2022

5. FDA Food Code: Specific SLTT laws and
regulations to be addressed by each jurisdiction.

Note: Some jurisdictions may require the FDA
Food Code Course in addition to SLTT food code
training.

COMMUNICATION SKILLS
Courses
1. Communication
Skills

Course Number
CC8030W NOTE: Course must be accessed through LearnEd at:
https://fdaoted.csod.com/

Curriculum (“Post”) Courses
(To be completed any time prior to Food Code Standardization AND within 24 months of hire or
assignment to the regulatory retail food program)
Courses

MICROBIOLOGY

7C-Control by Retorting
8-Technology-Based Food Processes
9-Natural Toxins

HACCP

Courses
1. Overview of HACCP
2. Prerequisite Programs & Preliminary Steps
3. The Principles

Courses
1. Allergens

Course Number

FDA16 (60)
FDA17 (60)
FDA18 (60)

ALLERGEN MANAGEMENT
Course Number
CC8029W NOTE: Course must be accessed through LearnEd at:
https://fdaoted.csod.com/

Courses
1. Collecting Surveillance Data
2. Beginning the Investigation
3. Expanding the Investigation
4. Conducting a Food Hazard Review
5. Epidemiological Statistics
6. Final Report

2-27

Course Number

MIC10 (90)
MIC11 (120)
MIC12 (90)

EPIDEMIOLOGY
FI01 (90)
FI02 (90)
FI03 (90)
FI04 (90)
FI05 (90)
FI06 (30)

Course Number

Voluntary National Retail Food Regulatory Program Standards – January 2022

EMERGENCY MANAGEMENT – FEMA
Incident Command System and National Incident Management System: Course available from FEMA
web link http://training.fema.gov/IS/NIMS.asp
Courses
Course Number
IS-100.C, Introduction to the Incident
1. Introduction to Incident Command System
Command System, (180) ICS-100 for FDA
2. Basic Incident Command System for Initial
IS-200.C, Basic Incident Command System
Response
for Initial Response (180)
IS 700.B, An Introduction to NIMS, (180)
3. An Introduction to NIMS
ICS-700

( ) Average time in minutes required to take the course, 60 minutes equals .1 CEU, 90-120 minutes
equals .2 CEUs
Estimated total hours for “Pre” courses are 42 hours.
Estimated total hours for “Post” courses are 26 hours.
Estimated total hours for completion of all Program Standard #2 coursework are 68 hours

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 2: Trained Regulatory Staff
APPENDIX B-2: CFP Field Training Manual
Background

The Conference for Food Protection (CFP) has progressed through multiple stages in the development of a nationally
recognized model for training and standardizing regulatory Food Safety Inspection Officers (FSIO) responsible for
conducting food safety inspections. Research conducted by CFP revealed that existing training and standardization
programs were nearly as varied as the number of regulatory jurisdictions throughout the country. In response, a model
multi-tiered approach for training and standardizing FSIOs was developed using the FDA Voluntary National Retail
Food Regulatory Program Standards, Standard 2 – Trained Regulatory Staff.
This Field Training Manual focuses on two components of this multi-tiered approach contained in Standard 2 – the
pre-requisite coursework and the field training model for preparing newly hired FSIOs or individuals newly assigned
to the regulatory retail food protection program to conduct independent food safety inspections. The instructions and
worksheets provided in this manual constitute a training process, not a certification or audit process.
The model developed through the CFP process, consists of a training plan, trainer’s worksheets, and procedures that
may be used by any regulatory retail food protection program. Jurisdictions do not have to be enrolled in the FDA
Voluntary National Retail Food Regulatory Program Standards to use, and benefit from, this training structure for
preparing FSIOs to conduct independent food safety inspections. This manual was developed to assist jurisdictions
that do not have the available staff resources and funding necessary to develop a comprehensive training process. The
training model presented in this manual can be readily integrated into existing regulatory retail food protection
programs.
The work within this document represents the culmination of years of research and review by subject matter experts
comprised of psychometricians and representatives from state and local regulatory retail food protection programs;
industry trade associations; retail food and foodservice operations; academia; and the FDA’s Office of Regulatory
Affairs University (ORA U). The coursework and training process are the basis for much of the criteria that is
contained in Steps 1 and 2 of Standard 2 – Trained Regulatory Staff, FDA Voluntary National Retail Food Regulatory
Program Standards. This manual is a working document and improvements will be made through the CFP Committee
process.

Overview of the Field Training Manual

All new employees or individuals new to the regulatory retail food protection program should complete pre-requisite
coursework and a field training process similar to that presented in this document. The national research conducted by
CFP has been used to identify the minimum performance element competencies needed to conduct effective regulatory
retail food safety inspections. The CFP Training Plan and Log along with the Field Training Worksheets provided in
this manual are based on these minimum performance element competencies.
Flexibility has been built into the process to allow regulatory jurisdictions the opportunity to customize training
content and methods to represent a jurisdiction’s own administrative policies, procedures, and inspection protocol. As
you read through this manual, it is important to keep in mind that jurisdictions are not obligated to use the forms;
equivalent forms or training processes can be developed. The ultimate objective is to ensure FSIOs are trained on, and
provided an opportunity to successfully demonstrate, the performance element competencies that are a vital part of
their job responsibilities.

Where to Access the Field Training Manual

A copy of the CFP Field Training Manual can be accessed from the Conference for Food Protection’s website
(http://www.foodprotect.org/).

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 2: Trained Regulatory Staff
APPENDIX B-3: Retail Food Establishment Categories
2017 FDA Food Code – Annex 5, Conducting Risk-based Inspections
Table 1

2-30

Risk
Category

Description

Frequency
#/Year

Examples include most convenience store operations, hot dog carts, and coffee
shops. Establishments that serve or sell only pre-packaged, non-time/
temperature control for safety (TCS) foods. Establishments that prepare only
non-TCS foods. Establishments that heat only commercially processed TCS
foods for hot holding. No cooling of TCS foods. Establishments that would
otherwise be grouped in Category 2 but have shown through historical
documentation to have achieved active managerial control of foodborne illness
risk factors.

Examples may include retail food store operations, schools not serving a
highly susceptible population, and quick service operations. Most products are
prepared/cooked and served immediately. May involve hot and cold holding
of TCS foods after preparation or cooking. Complex preparation of TCS foods
requiring cooking, cooling, and reheating for hot holding is limited to only a
few TCS foods. Establishments that would otherwise be grouped in Category
3 but have shown through historical documentation to have achieved active
managerial control of foodborne illness risk factors. Newly permitted
establishments that would otherwise be grouped in Category 1 until history of
active managerial control of foodborne illness risk factors is achieved and
documented.

An example is a full-service restaurant. Extensive menu and handling of
raw ingredients. Complex preparation including cooking, cooling, and
reheating for hot holding involves many TCS foods. Variety of processes
require hot and cold holding of TCS food. Establishments that would
otherwise be grouped in Category 4 but have shown through historical
documentation to have achieved active managerial control of foodborne
illness risk factors. Newly permitted establishments that would otherwise
be grouped in Category 2 until history of active managerial control of
foodborne illness risk factors is achieved and documented.

Examples include preschools, hospitals, nursing homes, and establishments
conducting processing at retail. Includes establishments serving a highly
susceptible population or that conduct specialized processes (i.e., smoking and
curing, reduced oxygen packaging for extended shelf-life).

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 3
INSPECTION PROGRAM BASED ON HACCP PRINCIPLES

Table of Contents

3-1

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 3
INSPECTION PROGRAM BASED ON HACCP PRINCIPLES
This standard applies to the utilization of HACCP principles to control risk factors in a retail food
inspection program.

Requirement Summary
An inspection program that focuses on the status of risk factors, determines, and documents compliance,
and targets immediate- and long-term correction of out-of-control risk factors through active managerial
control.

Description of Requirement
Program management:
1. Implements the use of an inspection form that is designed for:
a) The identification of risk factors and interventions.
b) Documentation of the compliance status of each risk factor and intervention (i.e., a form with
notations indicating IN compliance, OUT of compliance, Not Observed, or Not Applicable for
risk factors)
c) Documentation of all compliance and enforcement activities and
d) Requires the selection of IN, OUT, NO, or NA for each risk factor.
2. Develops and uses a process that groups food establishments into at least three categories based
on potential and inherent food safety risks.
3. Assigns the inspection frequency based on the risk categories to focus program resources on food
operations with the greatest food safety risk.
4. Develops and implements a program policy ***that requires:
a) On-site corrective actions* as appropriate to the type of violation.
b) Discussion of long-term control** of risk factor options, and
c) Follow-up activities.
5. Establishes and implements written policies addressing code variance requests related to risk factors
and interventions.
6. Establishes written policies regarding the verification and validation of HACCP plans when a plan is
required by the code.

Outcome
The desired outcome of this standard is 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.

Documentation
The quality records needed for this standard include:
1. Inspection form that requires the selection of IN, OUT, NO, or NA,
2. Written process used for grouping establishments based on food safety risk and the inspection
frequency assigned to each category,
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Voluntary National Retail Food Regulatory Program Standards – January 2022

3.
4.
5.
6.

Policy for on-site correction and follow-up activities,
Policy for addressing code variance requests related to risk factors and interventions,
Policy for verification and validation of HACCP plans required by code, and
Policy requiring the discussion of food safety control systems with management when out of control
risk factors are recorded on subsequent inspections.

*Note: On-site corrective action as appropriate to the violation would include such things as:
a. Destruction of foods that have experienced extreme temperature abuse,
b. Embargo or destruction of foods from unapproved sources,
c. Accelerated cooling of foods when cooling time limits can still be met,
d. Reheating when small deviations from hot holding have occurred,
e. Continued cooking when proper cooking temperatures have not been met.
f. Initiated use of gloves, tongs, or utensils to prevent hand contact with ready-to-eat foods, or
g. Required hand washing when potential contamination is observed.
**Note: Long-term control of risk factors requires a commitment by managers of food establishments to
develop effective monitoring and control measures or system changes to address those risk factors most
often responsible for foodborne illness. Risk control plans, standard operating procedures, buyer
specifications, menu modification, HACCP plans and equipment or facility modification may be discussed
as options to achieve the long-term control of risk factors.
***Note: Consideration of the elements outlined in Standard 4 will ensure a strong foundation for a
quality and uniform inspection program.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 3 – INSPECTION PROGRAM BASED ON HACCP PRINCIPLES
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment & Verification Audit Form
The Standard 3: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process for Standard 3. The form is
included at the end of these instructions. Whether one is performing a program self-assessment or
conducting a verification audit, it is recommended that the form be available as a reference to the
Standards 3 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of Standard 3 must indicate on the form if each of the listed
criteria is met. These responses are recorded under the column “Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use this form. An equivalent form or process is acceptable provided that
the results of the jurisdiction’s self-assessment for the specific Standard 3 criteria listed on this form are
available for review.
The Standard 3: Program Self-Assessment and Verification Audit Form is the only form a jurisdiction
needs to use to record the results of their self-assessment. Standard 3 requires inspection policies to be
established, written, and implemented. A policy without documentation of implementation does not
meet the Standard 3 criteria.
The Standard 3: Program Self-Assessment and Verification Audit Form divides the Standard 3 criteria
into six steps:
1. Inspection Form Design
a. The jurisdiction's inspection form identifies foodborne illness risk factors and Food Code
interventions.
b. The jurisdiction's inspection form documents actual observations using the convention IN,
OUT, NA, and NO.
c. The jurisdiction's inspection form documents compliance and enforcement activities.
2. Risk Assessment Categories
a. A risk assessment is used to group food establishments into at least 3 categories based on
their potential and inherent food safety risks.
3. Inspection Frequency
a. The jurisdiction's inspection frequency is based on assigned risk categories.
4. Corrective Action Policy
a. The jurisdiction has a written and implemented policy that requires on-site corrective action
for foodborne illness risk factors observed to be out of compliance.
b. The jurisdiction has a written and implemented policy that requires discussion for long- term
control of foodborne illness risk factors.
c. The jurisdiction has a written and implemented policy that requires follow-up activities on
foodborne illness risk factor violations.
5. Variance Request Policy
a. The jurisdiction has a written and implemented policy on variance requests related to
foodborne illness risk factors and Food Code interventions.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

6. Verification and Validation of HACCP Plan Policy
a. The jurisdiction has a written and implemented policy for the verification and validation of
HACCP plans, when a HACCP plan is required by the Food Code.

The self-assessor must review each Standard 3 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must place
an “X” in the “YES” box under the “Jurisdiction’s Self-Assessment” column of the Standard 3: Program
Self-Assessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 3 criteria are met,
the self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column
of the Standard 3: Program Self-Assessment and Verification Audit Form. The self-assessor may specify
why the criteria are not met in the box provided.
The self-assessor should review the findings on the Standard 3: Program Self-Assessment and
Verification Form to ensure accuracy. The jurisdiction will be required to provide the auditor with their
completed Standard 3: Program Self-Assessment and Verification Audit Form and any documents used to
support and demonstrate that the Standard 3 criteria have been met.
Once all the criteria have been reviewed and documented on the form, the self-assessor must complete
the Program Self-Assessment Summary section on page one of the Standard 3: Program SelfAssessment and Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 3 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 3 criteria.
Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 3: Program SelfAssessment and Verification Audit Form to the auditor for review. The auditor must indicate on the
Standard 3: Program Self-Assessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that the
Standard criteria are met, the verification auditor places and “X” in the “NO” box under the “Auditor’s
Verification” column of the form. The verification auditor must specify why the criterion is not met in the
box provided. Supplemental pages may be used to explain findings.
The jurisdiction must meet all six program performance criteria outlined in Standard 3.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the on-site visit. In particular, any
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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 3 criteria for which the auditor cannot confirm through a review of the self-assessment should be
thoroughly discussed. Ample time should be allotted to ensure that there is a clear understanding of the
reasons for the “non-conforming” finding. The auditor should be prepared to identify the elements
required for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on the first page of the Standard 3: Program Self-Assessment and Verification
Audit Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 3 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 3 criteria if the auditor does not confirm the self-assessment
findings.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 3: Inspection Program based on HACCP Principles
Program Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 3 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 3
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 3 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 3 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
3 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 3 is true and correct.
Signature of the Verification Auditor:

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 3: Inspection Program based on HACCP Principles
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: __________________________________________________________________________________________________________
Criteria

Element

1. Inspection
Form Design

a) The jurisdiction’s
inspection form identifies
foodborne illness risk factors
and Food Code interventions

1. Inspection
Form Design

b) The jurisdiction’s
inspection form documents
actual observations using the
convention (IN, OUT, NO,
and NA).

1. Inspection
Form Design

c) The jurisdiction’s
inspection form documents
compliance and enforcement
activities.

2. Risk
Assignment
Categories

a) A risk assessment is used
to group food establishments
into at least 3 categories
based on their potential and
inherent food safety risks.

3. Inspection
Frequency

a) The jurisdiction’s
inspection frequency is
based on the assigned risk
categories.

3-8

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
If NO, Auditor is to
Verification specify why criterion is not
NO
met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

a) The jurisdiction has a
written and implemented
4. Written and
policy that requires on-site
Implemented
corrective actions for
Corrective
foodborne illness risk factors
Action Policy
observed to be out of
compliance.
b) The jurisdiction has a
4. Written and
written and implemented
Implemented
policy that requires
Corrective
discussion for long-term
Action Policy
control of foodborne illness
risk factors.
4.Written and
Implemented
Corrective
Action Policy

5. Variance
Requests

c) The jurisdiction has a
written and implemented
policy that requires followup activities on foodborne
illness risk factor violations.
a) The jurisdiction has a
written and implemented
policy on variance requests
related to foodborne illness
risk factors and Food Code
interventions.

a) The jurisdiction has a
6. Verification
written and implemented
and Validation
policy for the verification
of HACCP
and validation of HACCP
Plans
plans, when a HACCP plan
is required by the Code.

3-9

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Verification
YES

Auditor’s
If NO, Auditor is to
Verification specify why criterion is not
NO
met

Voluntary National Retail Food Regulatory Program Standards – January 2022

GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 4
UNIFORM INSPECTION PROGRAM
Table of Contents

4-1

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 4
UNIFORM INSPECTION PROGRAM
This standard applies to the jurisdiction’s internal policies and procedures established to ensure
uniformity among regulatory staff in the interpretation of regulatory requirements, program policies and
compliance / enforcement procedures.
Requirement Summary
Program management has established a quality assurance program to ensure uniformity among regulatory
staff in the interpretation and application of laws, regulations, policies, and procedures.
Description of Requirement
1) Program Management implements an on-going quality assurance program that evaluates inspection
uniformity to ensure inspection quality, inspection frequency and uniformity among the regulatory
staff. The quality assurance program shall:
A. The quality assurance program shall assure that each inspector:
1. Has required equipment and forms to conduct the inspection.
2. Reviews the contents of the establishment file, including the previous inspection
report, reported complaints on file, and, if applicable, required HACCP Plans or
documents supporting the issuance of a variance.
3. Verifies that the establishment is in the proper risk category and that the required
inspection frequency is being met. Informs the supervisor when the establishment is not in
the proper risk category or when the required frequency is not met.
4. Provides identification as a regulatory official to the person in charge and states the
purpose of the visit.
5. Interprets and applies the jurisdiction’s laws, rules, policies, procedures, and
regulations required for conducting retail food establishment inspections.
6. Uses a risk-based inspection methodology to conduct the inspection.
7. Accurately determines the compliance status of each risk factor and Food Code
intervention (i.e., IN compliance, OUT of compliance, Not Observed, or Not Applicable).
8. Obtains corrective action for out-of-compliance risk factors and Food Code interventions
in accordance with the jurisdiction’s policies.
9. Discuss options for the long-term control of risk factors with establishment mangers, when
the same out-of-control risk factor occurs on consecutive inspections, in accordance with
the jurisdiction’s policies. Options may include, but are not limited to; risk control plans,
standard operating procedures, equipment and/or facility modification, menu modification,
buyer specifications, remedial training, or HACCP plans.
10. Verifies correction of out-of-compliance observations identified during the previous
inspection. In addition, follows through with compliance and enforcement in accordance
with the jurisdiction’s policies.
11. Conducts an exit interview that explains the out-of-compliance observations,
corrective actions, and timeframes for correction, in accordance with the jurisdiction’s
policies.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

12. Provides the inspection report and, when necessary, cross-referenced documents, to
the person in charge or permit holder, in accordance with the jurisdiction’s policies.
13. Demonstrates proper sanitary practices as expected from a food service employee.
14. Completes the inspection form per the jurisdiction’s policies (i.e., observations, public
health reasons, applicable code reference, compliance dates).
15. Documents the compliance status of each risk factor and intervention (IN, OUT, NA, NO).
16. Cites the proper code provisions for risk factors and Food code interventions, in accordance
with the jurisdiction’s policies.
17. Documents corrective action for out-of-compliance risk factors and Food Code
interventions in accordance with the jurisdiction’s policies.
18. Documents that option for the long-term control of risk factors were discussed with
establishment managers when the same out-of-control risk factor occurs on consecutive
inspections. Options may include, but are not limited to, risk control plans, standard
operating procedures, equipment and/or facility modification, menu modification,
buyer specifications, remedial training, or HACCP Plans.
19. Compliance or regulatory documents (i.e., exhibits, attachments, sample forms) are accurately
completed, appropriately cross-referenced within the inspection report, and included with the
inspection report, in accordance with the jurisdiction’s policies.
20. Files reports and other documentation in a timely manner, in accordance with the
jurisdiction’s policies.
B. The quality assurance program shall describe the actions that will be implemented when the
program analysis identifies deficiencies in quality or consistency in any program element
listed above in 1) (A).
2) The quality assurance program must achieve an overall inspection program performance rating for
each of the twenty measured elements [Items1-20] of at least 75% using the self-assessment
procedure and the appropriate table provided in the Standard 4: Self-Assessment Instructions and
Worksheet.
An assessment review of each inspector’s work shall be made during at least three joint on-site
inspections, with a corresponding file review of at least the three most recent inspection reports of the
same inspected establishments, during every self-assessment period.
[*NOTE: Staff members who are within their initial 24 months of training and have not completed all
prerequisite courses, 25 joint inspections and 25 independent inspections as required in Standard 2, are
exempt from the joint on-site inspections and file reviews used in the performance measurement rating
calculation in the Standard 4 Self-Assessment Worksheet.]

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Outcome
A quality assurance program exists that ensures uniform, high-quality inspections.
Documentation
The quality records needed for this standard include:
1. A written procedure that describes the jurisdiction’s quality assurance program that meets the criteria
under the Description of Requirement section 1) (A), including corrective actions for deficiencies,
and
2. Documentation that the program achieves a 75 percent performance rating on each element using the
self-assessment procedures described above.

4-4

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 4 – UNIFORM INSPECTION PROGRAM
INSTRUCTIONS FOR COMPLETING
THE PROGRAM SELF-ASSESSMENT AND VERIFICATION AUDIT FORM
Program Self-Assessment & Verification Audit Form
The Standard 4: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process. The form is included at the end of
these instructions. Whether one is performing a program self-assessment or conducting a verification
audit, it is recommended that the form be available as a reference to the Standards 4 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of Standard 4 must indicate on the form if each of the listed
criteria is met. These responses are recorded under the column “Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use this form. An equivalent form or process is acceptable provided
that the results of the jurisdiction’s self-assessment for the specific Standard 4 criteria listed on this
form are available for review.
The Standard 4: Self-Assessment and Verification Audit Form is divided into three steps:
1. A quality assurance program that:
a. Is described in a written document and covers all inspection personnel performing food
service or retail food inspections,
b. Is monitored regularly and consistently as described in the written document, and
c. Has determined corrective actions that will be taken whenever quality and consistency
problems are identified,
2. Demonstration of review and monitoring methods for the concepts in the twenty quality
elements, and
3. Demonstration of program effectiveness using the provided statistical method1.
The self-assessor must review each Standard 4 criterion and determine if the jurisdiction's source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must
place an “X” in the “YES” box under the “Jurisdiction's Self-Assessment” column of the Standard 4:
Program Self-Assessment and Verification Audit Form.
If a review of the jurisdiction's source documents does not confirm that the Standard 4 criteria are met,
the self-assessor must place an “X” in the “NO” box under the “Jurisdiction's Self-Assessment” column
of the Standard 4 Program Self-Assessment and Verification Audit Form. The self-assessor may specify
why the criteria are not met in the box provided.

This Standard criterion requires a statistical measure of the program’s effectiveness. Instructions for conducting the
statistical measure of program effectiveness is provided beginning on the Standard 4: Self-Assessment Worksheet

4-5

Voluntary National Retail Food Regulatory Program Standards – January 2022

The self-assessor should review the findings on the Standard 4: Program Self-Assessment and Verification
Form to ensure accuracy. The jurisdiction must provide the auditor with their completed Standard 4:
Program Self-Assessment and Verification Audit Form and any documents used to support and
demonstrate that the Standard 4 criteria have been met.
Once all the criteria have been reviewed and documented on the form, the self-assessor must complete
the Program Self-Assessment Summary section on page one of the Standard 4: Program SelfAssessment and Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Documents if the jurisdiction met the Standard 4 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 4 criteria.
Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 4: Program
Self-Assessment and Verification Audit Form to the auditor for review. The auditor must indicate on the
Standard 4: Program Self-Assessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that the
Standard criteria are met, the verification auditor places and “X” in the “NO” box under the “Auditor’s
Verification” column of the form. The verification auditor must specify why the criterion is not met in the
box provided. Supplemental pages may be used to explain findings.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the verification audit. In particular,
any Standard 4 criteria for which the auditor cannot confirm through a review of the self- assessment
should be thoroughly discussed. Ample time should be allotted to ensure that there is a clear
understanding of the reasons for the “non-conforming” finding. The auditor should be prepared to identify
the elements required for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on the first page of the Standard 4: Program Self-Assessment and Verification
Audit Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 4 criteria in the appropriate box;
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 4 criteria if the auditor does not confirm the self-assessment
findings.
4-6

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 4: Uniform Inspection Program
Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 4 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 4
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 4 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 4 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
4 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 4 is true and correct.
Signature of the Verification Auditor:

4-7

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 4: Program Assessment
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: ________________________________________________________________________________________________________
Criteria

Element

1. Written
Quality
Assurance
Program
Document

a. The jurisdiction has a written
quality assurance program that
covers all regulatory staff that
conducts retail food and/ or
foodservice inspections.

1. Written
Quality
Assurance
Program
Document

b. The jurisdiction periodically
conducts an analysis of the results of
the quality assurance program to
identify quality or consistency
problems among the staff in the
twenty quality elements.

1. Written
Quality
Assurance
Program
Document

2. Twenty
quality
Assurance
Elements
2. Twenty
quality
Assurance
Elements

4-8

c. The jurisdiction’s written quality
assurance program describes
corrective actions to address an
individual retail food program
inspector’s performance quality or
consistency issues when they are
identified.
The jurisdictions quality assurance
program provides a method to review
or monitor, either individually or
programmatically, the concepts in the
twenty quality elements. The twenty
elements follow in I. through XX.
I. The jurisdiction’s quality assurance
program assures that each inspector
has the required equipment and
forms to conduct the inspection.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to
Verification Verification specify why criterion is
YES
NO
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

2. Twenty
quality
Assurance
Elements

4-9

Element
II. The jurisdiction’s quality
assurance program assures that each
inspector reviews the contents of the
establishment file, including the
previous inspection report, reported
complaints on file, and, if applicable,
required HACCP Plans or documents
supporting the issuance of a variance.
III. The jurisdiction’s quality
assurance program assures that each
inspector verifies that the
establishment is in the proper risk
category and that the required
inspection frequency is being met,
Informs the supervisor when the
establishment is not in the proper risk
category or when frequency is not
met.
IV. The jurisdiction’s quality
assurance program assures that each
inspector provides identification as a
regulatory official to the person in
charge and states the purpose of the
visit.
V. The jurisdiction’s quality
assurance program assures that each
inspector interprets and applies the
jurisdiction’s laws, rules, policies,
procedures, and regulations required
for conducting retail food
inspections.
VI. The jurisdiction’s quality
assurance program assures that each
inspector uses a risk-based inspection
methodology to conduct the
inspection.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to
Verification Verification specify why criterion is
YES
NO
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

2. Twenty
quality
Assurance
Elements

4-10

Element
VII. The jurisdiction’s quality
assurance program assures that each
inspector accurately determines the
compliance status of each risk factor
and Food Code intervention (i.e., IN
compliance, OUT of compliance,
Not Observed, or Not Applicable).
VIII. The jurisdiction’s quality
assurance program assures that each
inspector obtains corrective action
for out-of- compliance risk factors
and Food Code interventions in
accordance with the jurisdictions
policies.
IX. The jurisdiction’s quality
assurance program assures that each
inspector discusses options for the
long-term control of risk factors with
establishment managers when the
same out-of-control risk factor
occurs on consecutive inspections, in
accordance with the jurisdiction’s
policies. Options may include, but
are not limited to, risk control plans,
standard operating procedures,
equipment and/or facility
modification, menu modification,
buyer specifications, remedial
training, or HACCP Plans.
X. The jurisdiction’s quality
assurance program assures that each
inspector verifies correction of outof-compliance observations
identified during the previous
inspection. In addition, follows
through with compliance and
enforcement in accordance with
jurisdiction’s policies.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to
Verification Verification specify why criterion is
YES
NO
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

2. Twenty
quality
Assurance
Elements

4-11

Element
XI. The jurisdiction’s quality
assurance program assures that each
inspector conducts an exit interview
that explains the out-of-compliance
observations, corrective actions, and
timeframes for correction, in
accordance with the jurisdiction’s
policies.
XII. The jurisdiction’s quality
assurance program assures that each
inspector provides the inspection
report and, when necessary, crossreferenced documents, to the person
in charge or permit holder, in
accordance with the jurisdiction’s
policies.
XIII. The jurisdiction’s quality
assurance program assures that each
inspector demonstrates proper
sanitary practices as expected from a
food service employee.
XIV. The jurisdiction’s quality
assurance program assures that each
inspector completed the inspection
form per the jurisdiction’s policies
(i.e., observations, public health
reasons, applicable code reference,
compliance dates).
XV. The jurisdiction’s quality
assurance program assures that each
inspector documents the status of
each risk factor and intervention (IN,
OUT, NA, NO).

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to
Verification Verification specify why criterion is
YES
NO
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria
2. Twenty
quality
Assurance
Elements

2. Twenty
quality
Assurance
Elements

4-12

Element
XVI. The jurisdiction’s quality
assurance program assures that each
inspector cites the proper code
provisions for risk factors and Food
Code interventions, in accordance
with the jurisdiction’s policies.
XVII. The jurisdiction’s quality
assurance program assures that each
inspector documents corrective action
for out-of- compliance risk factors
and Food Code interventions in
accordance with the jurisdiction’s
policies.
XVIII. The jurisdiction’s quality
assurance program assures that each
inspector documents that options for
the long-term control of risk factors
were discussed with establishment
managers when the same out-ofcontrol risk factor occurs on
consecutive inspections. Options may
include, but are not limited to, risk
control plans, standard operating
procedures, equipment and/or facility
modification, menu modification,
buyer specifications, remedial
training, or HACCP Plans.
XIX. The jurisdiction’s quality
assurance program assures that each
inspector accurately completes
compliance or regulatory documents
(i.e., exhibits, attachments, sample
forms), appropriately crossreferences them within the inspection
report, and includes them with the
inspection report, in accordance with
the jurisdiction’s policies.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to
Verification Verification specify why criterion is
YES
NO
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria
2. Twenty
quality
Assurance
Elements

Element
XX. The jurisdiction’s quality
assurance program assures that each
inspector files reports and other
documentation in a timely manner, in
accordance with the jurisdiction’s
policies.

a. The program effectiveness
3.Demonstratio measure documents that 3 selfn of Program assessment field reviews were
conducted for each employee
Effectiveness
performing retail food and or
Using the
foodservice inspection work
Statistical
Method in
during the five-year selfStandard 4:
assessment period. [New staff
Selfwho have not completed Steps 1
Assessment
through 3 of Standard 2 are
Worksheet
exempt from this field
measurement.]
3.Demonstratio
n of Program
Effectiveness
Using the
Statistical
Method in
Standard 4:
SelfAssessment
Worksheet

4-13

b. Based on the self-assessment field
reviews using the statistical method
described in Standard 4: SelfAssessment Worksheet, the
jurisdiction’s regulatory staff
achieves a rate of 75% on each
quality element for jurisdictions with
10 or more inspectors. For
jurisdictions with less than 10
inspectors, the achievement rate
meets or exceeds the Table 4-1
calculation.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to
Verification Verification specify why criterion is
YES
NO
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

4-14

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 4 – UNIFORM INSPECTION PROGRAM
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELFASSESSMENT
Using the Standard 4 Self-Assessment Worksheet
Criterion three on the Standard 4: Self-Assessment and Verification Audit Form requires a statistical
measure of the program’s effectiveness. Tables 4-1 and 4-2 on the Standard 4: Self- Assessment
Worksheet, included at the end of these instructions, is designed to assist the jurisdiction in
determining by statistical method the effectiveness of its Uniform Inspection Program and in
documenting its findings. The jurisdictions are not obligated to use the worksheet. Equivalent forms or
processes are acceptable provided that the statistical process and result is available for review.
Step 1 – Conduct three field reviews for each employee performing food service or retail food
inspection work during the five-year self-assessment period.
The jurisdiction must conduct three field reviews with each employee performing food service or retail
food inspection work during the five-year self-assessment period. Staff members who are within their
initial 24 months of training and have not completed all prerequisite courses, 25 joint inspections and
25 independent inspections as required in Standard 2, are exempt from the field reviews and file
reviews used in the performance measurement rating calculation in the Standard 4 Self-Assessment
Worksheet.
Field reviews must be conducted by someone who has competed Steps 1-3 in Standard 2 and is
recognized by the program manager as having the field experience and communication skills necessary
to train new employees.
Some of the performance elements can only be assessed after thorough a review of the establishment
files. Therefore, each field review must be accompanied by a review of the establishment file.
Information from the file review will help the field assessor determine if the FSIO:
• Obtained corrective action for out-of-compliance risk factors and Food Code interventions in
accordance with the jurisdiction’s policies;
• Discussed options for the long-term control of risk factors with establishment managers, when
the same out-of-control risk factor occurs on consecutive inspections, in accordance with the
jurisdiction’s policies; and
• Verified correction of out-of-compliance observations identified during the previous
inspection. In addition, follows through with compliance and enforcement in accordance with
the jurisdiction’s administrative procedures.
The field reviews must be conducted at establishment types that are representative of the employee’s
case load. The jurisdiction should determine a method for selecting appropriate facilities for the field
review process and use that method consistently for all employees.
The field review process (and the accompanying file review) is intended to evaluate the quality and
consistency of the program for each performance element. The following should be taken into
consideration when implementing the field review process:
• This Standard is intended to ensure that inspections are of a satisfactory quality and uniformity
across the entire program.
• When assessing a staff member’s performance during the field review process, perfection is not
4-15

Voluntary National Retail Food Regulatory Program Standards – January 2022

•

required to demonstrate successful achievement of a performance element.
Table 4-2 is intended to document the results of the field review process for the purpose of
determining if a jurisdiction has achieved conformance with Standard 4. Table 4-2 is not
intended as a mechanism for providing feedback to staff on their performance during the field
review process. Therefore, jurisdictions are encouraged to incorporate the performance
elements from Standard 4 into a field review tool so that staff can be provided with meaningful
feedback that improves the quality and uniformity of their inspections.
Jurisdictions may assess additional jurisdiction-specific performance elements during the field
review process. However, for the purposes of determining conformance with Standard 4,
additional jurisdiction-specific performance elements may not be included in the calculation
used for Table 4-1 or 4-2.

Step 2 – Confirm that three field reviews have been conducted for each employee performing
foodservice or retail food inspection work during the five-year self-assessment period.
Table 4-2 of the Standard 4: Self-Assessment Worksheet is used to document the field inspections and
to analyze statistically the program’s overall effectiveness. The jurisdiction conducts at least three field
inspections with each inspector who conducts food service or retail food inspections during each fiveyear self-assessment period.
Table 4-2 must be completed with at least twelve field inspections. Jurisdictions with less than four
inspectors must complete additional field inspections with each inspector in order to reach a total of
twelve inspections. For example, a jurisdiction with three inspectors would need to: Complete four
inspections each inspector.
Step 3 – Use Table 4-2 to enter the results from the three field reviews for each Food Safety
Inspection Officer (FSIO)
 In the first column of Table 4-2, identify each FSIO by name or by a code.
 In the Establishment ID column, identify the three establishments included in the field
reviews for each FSIO.
 In the “DATE” column, record the dates of the field visit and file review.
 Items 1 through 20 are the Standard 4 criteria related to the FSIOs competencies.
The self-assessor must place a check mark in the corresponding column of Table 4-2 when the activity
or competency is verified.
Step 4 – Conduct calculations to Determine Program Effectiveness
JURISDICTIONS WITH TEN OR MORE INSPECTORS
For jurisdictions with ten or more inspectors conducting foodservice or retail food inspections, the
self-assessor must:
1. Add the number of check marks in the column titled “Item 1”;
2. Divide the total number of checks marks from Step 1 by the total number of field inspections
documented in Table 4-2;
3. Multiply the number in Step 2 by 100; and
4. Repeat this process for Item 1 through Item 20.
This results in a percent achievement for each of the twenty quality elements. Each of the twenty
columns must show at least a 75% achievement rate in order for the program to meet the effectiveness
measure. Perform and review the calculations for each of the twenty columns.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

JURISDICTIONS WITH LESS THAN TEN INSPECTORS
For jurisdictions with less than ten inspectors conducting foodservice or retail food inspections, an
adjustment must be made in the statistical method to compensate for the small sample size. The selfassessor must:
1. Add the total number of check marks for Item 1 through Item 20;
2. Refer to Chart 4-1. Column three of Chart 4-1 shows the minimum number of items that must
be marked “IN Compliance” to meet the effectiveness measure for Standard 4.
3. Complete Table 4-1 to determine if the jurisdiction achieves conformance with the
effectiveness measure in Standard 4.
Step 5 – Document Results of the Uniform Program Assessment
Use the worksheet results to mark “YES” or “NO” for criteria list under “3” – Demonstration of Program
Effectiveness Using the Statistical Method in Standard 4 Self-Assessment Worksheet” on the Standard
4: Self-Assessment and Verification Audit Form.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 4: Uniform Inspection Program
Self-Assessment Worksheet
Chart 4-1
Method of Calculation for Jurisdictions with Less Than Ten Inspectors
# of inspectors

# inspections needed

# of items needed to be marked IN compliance in
order to meet Standard 4 criteria

12 minimum

200
(out of 240 possible Items)

4-9

3 per inspector

4 inspectors = 200 (out of 240 possible Items)
5 inspectors = 252 (out of 300 possible Items)
6 inspectors = 303 (out of 360 possible Items)
7 inspectors = 355 (out of 420 possible Items)
8 inspectors = 407 (out of 480 possible Items)
9 inspectors = 459 (out of 540 possible Items)

NOTE:
1.

These minimum inspection program assessment criteria are comparable to the 75% IN Compliance rate
for each of the twenty inspection program areas for jurisdictions with 10 or more inspectors.

Example: For 6 inspectors, there will be 3 field visits per inspector = 18 visits 18 visits X 20 Items per
visit = 360 Total Possible Items

Table 4-1
Calculation of Uniformity for Jurisdictions with Less Than Ten Inspectors
Period from _______________________ to _______________________
1. Number of inspectors in the jurisdiction
2. Number of inspections used in the calculation (minimum of 12)
3. Total number of items marked as correct during joint field visits and
corresponding file reviews and recorded on Table 4-2.
4. Total number of possible items based on the number of inspections
(20 items times the # of inspections – see Chart 4-1, column 3)
Determine conformance (YES or NO) using Chart 4-1, column 3

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 4: Uniform Inspection Program
Self-Assessment Worksheet
Table 4-2: Calculation of Uniformity for Jurisdictions with Ten or More Inspectors
No.

Inspector ID

Establishment ID

Date

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
NOTE: 1. A check mark indicates the inspector complies with the item.

4-19

Item Item Item Item Item Item Item Item Item Item Item Item Item Item Item Item Item Item Item Item
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20)
(1)

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 4: Uniform Inspection Program
Self-Assessment Worksheet
Table 4-3: Calculation of Uniformity for Jurisdictions with Ten or More Inspectors
Measure

1. Number of Check
Marks from Table 4-2
2. Number of Inspections
Reviewed in Table 4-2
3. % IN Compliance (Row
1÷ Row 2)

4-20

Item
(1)

Item
(2)

Item
(3)

Item
(4)

Item
(5)

Item
(6)

Item
(7)

Item
(8)

Item
(9)

Item
(10)

Item
(11)

Item
(12)

Item
(13)

Item
(14)

Item
(15)

Item
(16)

Item
(17)

Item
(18)

Item
(19)

Item
(20)

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 5
FOODBORNE ILLNESS AND FOOD DEFENSE PREPAREDNESS AND
RESPONSE

Table of Contents

REQUIREMENT SUMMARY .......................................................................................................................... 2
DESCRIPTION OF REQUIREMENT ................................................................................................................. 2
1. Investigative Procedures ................................................................................................................... 2
2. Reporting Procedures ........................................................................................................................ 3
3. Laboratory Support Documentation .................................................................................................. 3
4. Trace-back Procedures ...................................................................................................................... 3
5. Recalls ............................................................................................................................................... 3
6. Media Management........................................................................................................................... 4
7. Data Review and Analysis ................................................................................................................ 4
OUTCOME ................................................................................................................................................... 5
DOCUMENTATION ....................................................................................................................................... 5

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 5
FOODBORNE ILLNESS AND FOOD DEFENSE PREPAREDNESS AND
RESPONSE
This standard applies to the surveillance, investigation, response, and subsequent review of alleged foodrelated incidents and emergencies, either unintentional or deliberate, which results in illness, injury, and
outbreaks.
Requirement Summary
The program has an established system to detect, collect, investigate, and respond to complaints and
emergencies that involve foodborne illness, injury, and intentional and unintentional food contamination.
Description of Requirement
1. Investigative Procedures
a. The program has written operating procedures for responding to and /or conducting investigations
of foodborne illness and food-related injury*. The procedures clearly identify the roles, duties, and
responsibilities of program staff and how the program interacts with other relevant departments
and agencies. The procedures may be contained in a single source document or in multiple
documents.
b. The program maintains contact lists for individuals, departments, and agencies that may be
involved in the investigation of foodborne illness, food-related injury* or contamination of food.
c. The program maintains a written operating procedure or a Memorandum of Understanding (MOU)
with the appropriate epidemiological investigation program/department to conduct foodborne
illness investigations and to report findings. The operating procedure or MOU clearly identifies
the roles, duties, and responsibilities of each party.
d. The program maintains logs or databases for all complaints or referral reports from other sources
alleging food-related illness, food-related injury* or intentional food contamination. The final
disposition for each complaint is recorded in the log or database and is filed in or linked to the
establishment record for retrieval purposes.
e. Program procedures describe the disposition, action or follow-up and reporting required for each
type of complaint or referral report.
f. Program procedures require disposition, action or follow-up on each complaint or referral report
alleging food-related illness or injury within 24 hours.
g. The program has established procedures and guidance for collecting information on the suspect
food’s preparation, storage or handling during on-site investigations of food-related illness, foodrelated injury*, or outbreak investigations.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

h. Program procedures provide guidance for immediate notification of appropriate law enforcement
agencies if at any time intentional food contamination is suspected.
i. Program procedures provide guidance for the notification of appropriate state and/or federal
agencies when a complaint involves a product that originated outside the agency’s jurisdiction or
has been shipped interstate.
2. Reporting Procedures
a. Possible contributing factors to the food-related illness, food-related injury* or intentional food
contamination are identified in each on-site investigation report.
b. The program shares final reports of investigations with the state epidemiologist and reports of
confirmed foodborne disease outbreaks* with CDC.
3. Laboratory Support Documentation
a. The program has a letter of understanding, written procedures, contract, or MOU acknowledging,
that a laboratory(s) is willing and able to provide analytical support to the jurisdiction’s food
program. The documentation describes the type of biological, chemical, radiological contaminants
or other food adulterants that can be identified by the laboratory. The laboratory support available
includes the ability to conduct environmental sample analysis, food sample analysis and clinical
sample analysis.
b. The program maintains a list of alternative laboratory contacts from which assistance could be
sought in the event that a food-related emergency exceeds the capability of the primary support
lab(s) listed in paragraph 3.a. This list should also identify potential sources of laboratory support
such as FDA, USDA, CDC, or environmental laboratories for specific analysis that cannot be
performed by the jurisdiction’s primary laboratory(s).
4. Trace-back Procedures
a. Program management has an established procedure to address the trace-back of foods implicated in
an illness, outbreak, or intentional food contamination. The trace-back procedure provides for the
coordinated involvement of all appropriate agencies and identifies a coordinator to guide the
investigation. Trace-back reports are shared with all agencies involved and with CDC.
5. Recalls
a. Program management has an established procedure to address the recall of foods implicated in an
illness, outbreak, or intentional food contamination.
b. When the jurisdiction has the responsibility to request or monitor a product recall, written
procedures equivalent to 21 CFR, Part 7 are followed.

5-3

Voluntary National Retail Food Regulatory Program Standards – January 2022

c. Written policies and procedures exist for verifying the effectiveness of recall actions by firms
(effectiveness checks) when requested by another agency.
6. Media Management
a. The program has a written policy or procedure that defines a protocol for providing information
to the public regarding a foodborne illness outbreak or food safety emergency. The
policy/procedure should address coordination and cooperation with other agencies involved in
the investigation. A media person is designated in the protocol.
7. Data Review and Analysis
a. At least once per year, the program conducts a review of the data in the complaint log or database
and the foodborne illness and food-related injury* investigations to identify trends and possible
contributing factors that are most likely to cause foodborne illness or food-related injury*. These
periodic reviews of foodborne illnesses may suggest a need for further investigations and may
suggest steps for illness prevention.
b. The review is conducted with prevention in mind and focuses on, but is not limited to, the
following:
1) Foodborne Disease Outbreaks*, Suspect Foodborne Outbreaks* and Confirmed Foodborne
Disease Outbreaks* in a single establishment;
2) Foodborne Disease Outbreaks*, Suspect Foodborne Outbreaks* and Confirmed Disease
Outbreaks* in the same establishment type;
3) Foodborne Disease Outbreaks*, Suspect Foodborne Outbreaks* and Confirmed Foodborne
Disease Outbreaks* implicating the same food;
4) Foodborne Disease outbreaks*, Suspect Foodborne Outbreaks* and Confirmed Foodborne
Disease Outbreaks* associated with similar food preparation processes;
5) Number of confirmed foodborne disease outbreaks*;
6) Number of foodborne disease outbreaks* and suspect foodborne disease outbreaks*;
7) Contributing factors most often identified;
8) Number of complaints involving real and alleged threats of intentional food contamination;
and
9) Number of complaints involving the same agent and any complaints involving unusual agents
when agents are identified.
c. In the event that there have been no food-related illness or food-related injury* outbreak
investigations conducted during the twelve months prior to the data review and analysis, program
management will plan and conduct a mock foodborne illness investigation to test program
readiness. The mock investigation should simulate response to an actual confirmed foodborne
disease outbreak* and include on-site inspection, sample collection and analysis. A mock
investigation must be completed at least once per year when no foodborne disease outbreak*
investigations occur.
Note: Regulatory Programs are encouraged to also participate in the CDC National Environmental
Assessment Reporting System (NEARS). NEARS is designed to provide a more
5-4

Voluntary National Retail Food Regulatory Program Standards – January 2022

comprehensive approach to foodborne disease outbreak investigation and response and will provide a data
source to measure the impact of food safety programs to further research and understand foodborne illness
causes and prevention. (The following link provides additional information regarding NEARS:
http://www.cdc.gov/nceh/ehs/nears/index.htm )
Outcome
A food regulatory program has a systematic approach for the detection, investigation, response,
documentation, and analysis of alleged food-related incidents that involve illness, injury, unintentional or
deliberate food contamination.
Documentation
The quality records required to meet this standard include:
1. Logs or databases of alleged food-related illness and food-related injury* complaints maintained
and current.
2. Collection forms specified in the operating procedures.
3. Investigation reports of alleged food-related illness, food-related injury*, or incidents. Reports are
retrievable by implicated establishment name.
4. The written procedures, contracts, or MOUs with the supporting laboratories.
5. The procedure addressing the trace-back of food products implicated in an illness, outbreak, or
contamination event.
6. 21 CFR, Part 7, or written procedures equivalent to 21 CFR, Part 7 for recalls.
7. Completed copies of the annual review and analysis (after 12 months of data).
8. Current written media policy/procedure and contact person.
9. The contact list for communicating with all relevant agencies.
10. Portions of any emergency response relevant to food safety and security.
[*Note: See the Standards Definitions for the meaning of these defined terms.]

5-5

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 5 - FOODBORNE ILLNESS AND FOOD DEFENSE PREPAREDNESS
AND RESPONSE
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment & Verification Audit Form
The Standard 5: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process for Standard 5. The form is included
at the end of these instructions. Whether one is performing a program self-assessment or conducting a
verification audit, it is recommended that the form be available as a reference to the Standard 5 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of Standard 5 must indicate on the form if each of the listed
criteria is met. These responses are recorded under the column “Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use this form. An equivalent form or process is acceptable provided that
the results of the jurisdiction’s self-assessment for the specific Standard 5 criteria listed on this form are
available for review.
The Standard 5: Program Self-Assessment and Verification Audit Form is the only form a jurisdiction
needs to use to record the results of their self-assessment. The Standard 5: Program Self-Assessment and
Verification Audit Form divides the Standard 5 criteria into seven categories:
1. Investigative Procedures;
 Written Operating Procedure; Contact Lists; Cooperative Agreements;
 Documenting and Responding to Reported Complaints/Incidences;
 Complaint/Incident Investigative Procedures;
2. Reporting Procedures;
3. Laboratory Support Documentation;
4. Trace-back Procedures;
5. Recalls;
6. Media Management; and
7. Data Review and Analysis.
The self-assessor must review each Standard 5 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must place
an “X” in the “YES” box under the “Jurisdiction’s Self-Assessment” column of the Standard 5:
Program Self- Assessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 5 criteria are met, the
self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column of the
Standard 5: Program Self-Assessment and Verification Audit Form. The self-assessor may specify why the
criteria are not met in the box provided.

5-6

Voluntary National Retail Food Regulatory Program Standards – January 2022

The self-assessor should review the findings on the Standard 5: Program Self-Assessment and
Verification Form to ensure accuracy. The jurisdiction will be required to provide the auditor with their
completed Standard 5: Program Self-Assessment and Verification Audit Form and any documents used to
support and demonstrate that the Standard 5 criteria have been met.
Once all the criteria have been reviewed and documented on the form, the self-assessor must complete the
Program Self-Assessment Summary section on page one of the Standard 5: Program Self-Assessment and
Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 5 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 5 criteria.
Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 5: Program SelfAssessment and Verification Audit Form to the auditor for review. The auditor must indicate on the
Standard 5: Program Self-Assessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that the
Standard criteria are met, the verification auditor places and “X” in the “NO” box under the “Auditor’s
Verification” column of the form. The verification auditor must specify why the criterion is not met in the
box provided. Supplemental pages may be used to explain findings. The jurisdiction must meet all seven
program performance criteria outlined in Standard 5.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the on-site visit. In particular, any
Standard 5 criteria for which the auditor cannot confirm through a review of the self-assessment should be
thoroughly discussed. Ample time should be allotted to ensure that there is a clear understanding of the
reasons for the “non-conforming” finding. The auditor should be prepared to identify the elements required
for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on the first page of the Standard 5: Program Self-Assessment and Verification
Audit Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 5 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 5 criteria if the auditor does not confirm the self-assessment
findings.
5-7

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 5: Foodborne Illness and Food Defense Preparedness and Response Program
Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 5 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 5
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 5 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 5 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
5 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 5 is true and correct.
Signature of the Verification Auditor:

5-8

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 5: Foodborne Illness and Food Defense Preparedness and Response Program
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: _________________________________________________________________________________________________________
Criteria

Element

a) The program has written
operating procedures for
responding to and/or
conducting investigations of
foodborne illness and foodrelated injury that clearly
identify the roles, duties, and
1. Investigative
responsibilities of program
Procedures
staff and how the program
interacts with other relevant
departments and agencies.
(The procedures may be
contained in a single source
document or in multiple
documents.)
b) The program maintains
contact lists for individuals,
departments, and agencies
1. Investigative that may be involved in the
investigation of foodborne
Procedures
illnesses, food-related
injuries, or contamination of
food.

5-9

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

c) The program maintains a
written operating procedure
or a Memorandum of
Understand (MOU) with
the appropriate
epidemiological
investigation program /
1. Investigative
department to conduct
Procedures
foodborne illness
investigations and to report
findings. The operating
procedure or MOU clearly
identifies the roles, duties,
and responsibilities
of each party.
d) The program maintains
logs or databases for all
complaint or referral reports
from other sources alleging
food-related illness, foodrelated injury, or
1. Investigative unintentional food
Procedures
contamination. The final
disposition for each
complaint is recorded in the
database or log and is filed
in, or linked to, the
establishment record for
retrieval purposes.
e) Program procedures
describe the disposition,
1. Investigative action,
or follow-up and reporting
Procedures
required for each type of
complaint or referral report.

5-10

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

f) Program procedures require
disposition, action or follow1. Investigative up on each complaint or
Procedures
referral report alleging foodrelated illness or injury within
24 hours.
g) The program has
established procedures and
guidance for collecting
1. Investigative information on the suspect
Procedures
foods' preparation, storage
or handling during on-site
illness, food-injury, or
outbreak investigations.
h) Program procedures
provide guidance for
immediate notification of
1. Investigative
appropriate law enforcement
Procedures
agencies if at any time
intentional food
contamination is suspected.
i) Program procedures
provide guidance for the
notification of appropriate
state and/or federal agencies
1. Investigative
when a complaint involves a
Procedures
product that originated
outside the agency's
jurisdiction or has been
shipped interstate.

2. Reporting
Procedures

5-11

a) Possible contributing
factors to the illness, foodrelated injury, or intentional
food contamination are
identified in each on-site
investigation report.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

2. Reporting
Procedures

Element
b) The program shares final
reports of investigations with
the state epidemiologist and
reports of confirmed disease
outbreaks with CDC.

a) The program has a letter of
understanding, written
procedures, contract, or MOU
acknowledging that a
laboratory(s) is willing and
able to provide analytical
support to the jurisdiction's
3. Laboratory food program. The
documentation describes the
Support
type of biological, chemical,
Documentation radiological, contaminants or
other food adulterants that
can be identified by the
laboratory. The laboratory
support available includes
the ability to conduct
environmental, food, and/or
clinical sample analyses.
b) The program maintains a
list of alternative laboratory
contacts from which
assistance could be sought in
the event that a food-related
emergency exceeds the
capability of the primary
3. Laboratory support lab(s) identified in
paragraph 3.a. This list
Support
Documentation should also identify potential
sources of laboratory support
such as FDA, USDA, CDC,
or environmental laboratories
for specific analysis that
cannot be performed by the
jurisdiction's primary
laboratory(s).

5-12

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

4. Trace-Back
Procedures

a) Program management
has an established
procedure to address the
trace-back of foods
implicated in an illness,
outbreak, or intentional
food contamination. The
trace-back provides for the
coordinated involvement of
all appropriate agencies and
identifies a coordinator to
guide the investigation.
Trace-back reports are
shared with all agencies
involved and with CDC.

5. Recalls

a) Program management
has an established
procedure to address the
recall of foods implicated
in an illness, outbreak, or
intentional food
contamination.

5. Recalls

b) When the jurisdiction
has the responsibility to
request or monitor a
product recall, written
procedures equivalent to 21
CFR Part 7 are followed.

5. Recalls

c) Written policies and
procedures exist for
verifying the effectiveness
of recall actions by firms
(effectiveness checks)
when requested by another
agency.

5-13

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

6. Media
Management

a) The program has a
written policy and
procedure that defines a
protocol for providing
information to the public
regarding a foodborne
illness outbreak or food
safety emergency. The
protocol should address
coordination and
cooperation with other
agencies involved in the
investigation. A media
person is designated in the
protocol.

7. Data Review
and Analysis

a) At least once per year,
the program conducts a
review of the data in the
complaint log or database
and the illness and foodrelated injury investigations
to identify trends and
possible contributing
factors that are most likely
to cause illness or injury.
These periodic reviews of
multiple complaints and
contributing factors may
suggest a need for further
investigations may suggest
steps for illness prevention.

5-14

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

b) The review is conducted
with prevention in mind
and focuses on, but is not
7. Data Review
limited to, the following:
and Analysis
1) Multiple complaints
on the same
establishment;
7. Data Review
and Analysis

2) Multiple complaints on
the same establishment
type;

7. Data Review
and Analysis

3) Multiple complaints
implicating the same
food;

7. Data Review
and Analysis

4) Multiple complaints
associated with
similar food
preparation
processes;

7. Data Review
and Analysis

5) Number of confirmed
foodborne disease
outbreaks;

7. Data Review
and Analysis

6) Number of foodborne
disease outbreaks and
suspect foodborne
disease outbreaks;

7. Data Review
and Analysis

7) Contributing factors
most often identified;

7. Data Review
and Analysis

8) Number of
complaints involving
real and alleged
threats of intentional
food contamination.

5-15

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

7. Data Review
and Analysis

9) Number of complaints
involving the same
agent and any
complaints involving
unusual agents when
agents are identified.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

c) In the event that there have
been no illness or food-related injury outbreak
investigations conducted
during the twelve months
prior to the trend analysis,
program management will
plan and conduct a mock
foodborne illness or food
7. Data Review defense investigation to test
and Analysis
program readiness. The mock
investigation should simulate
response to an actual illness
outbreak and include on-site
inspection, sample collection,
and analysis. A mock
investigation must be
completed at least once per
year when no illness outbreak
investigations occur.
GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

A “yes” affirmation to each statement is required to meet Standard 5. If an item contains multiple questions, then all questions must be answered in the affirmative in
order to meet that element of the Standard. The source documents, such as the various policies and procedures, that support this summary record must be maintained
in good order by the regulatory authority and must be made available upon request for purposes of a verification audit.
(NOTE: Item 7c can be marked “not applicable” (NA) if the jurisdiction DID conduct a foodborne illness or food defense investigation within the twelve-month
period since the last trend analysis. If the jurisdiction DID conduct a foodborne illness or food defense investigation within this twelve-month period, then they are
not required to conduct a mock foodborne illness/food defense training exercise.)

5-16

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 6
COMPLIANCE AND ENFORCEMENT

Table of Contents

6-1

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 6
COMPLIANCE AND ENFORCEMENT
This standard applies to all compliance and enforcement activities used by a jurisdiction to achieve
compliance with regulations.
Requirement Summary
Compliance and enforcement activities result in follow-up actions for out-of-control risk factors and
timely correction of code violations.
Description of Requirement
Compliance and enforcement encompass all voluntary and regulatory actions taken to achieve
compliance with regulations. Voluntary corrective action includes, but is not limited to, such activities
as on-site corrections at time of inspection, voluntary destruction of product, risk control plans and
remedial training. Enforcement action includes, but is not limited to, such activities as warning letters,
re-inspection, citations, administrative fines, permit suspension and hearings. Compliance and
enforcement options may vary depending on state and local law.
The program must demonstrate credible follow-up for each violation noted during an inspection, with
particular emphasis being placed on risk factors that most often contribute to foodborne illness and Food
Code interventions intended to prevent foodborne illness. The resolution of out-of-compliance risk
factors and/or Food Code interventions must be documented in each establishment record. The essential
program elements required to meet this standard are:
1. A written step-by-step procedure that describes how compliance and enforcement tools are to
be used to achieve compliance.
2. Inspection report form(s) that records and quantifies the compliance status of risk factors
and interventions (i.e., IN compliance, OUT of compliance, Not Observed, or Not
Applicable).
3. Documentation on the establishment inspection report form or in the establishment file using
the statistical method for file selection in the Supplement to Standard 6, Appendix F, where at
least 80 percent of sampled establishments meet the following conditions:
a) The inspection and enforcement staff takes compliance and enforcement action according to
the procedure (i.e., the staff follow the step-by-step compliance and enforcement procedures
when violations occur), and
b) Resolution was successfully achieved for all out-of-control risk factors or interventions that
were recorded on the selected routine inspection.
Outcome
The desired outcome of this standard is an effective compliance and enforcement program that is
implemented consistently to achieve compliance with regulatory requirements.

6-2

Voluntary National Retail Food Regulatory Program Standards – January 2022

Documentation
The quality records needed for this standard include:
1. A copy of the written step-by-step enforcement procedures.
2. Inspection form that meets the criteria.
3. Documentation that compliance and enforcement action was taken correctly for at least 80
percent of the sampled establishments using the Standard 6: Establishment File Worksheet
and the Standard 6: Self-Assessment Summary Worksheet when out-of-control risk factors or
code interventions are recorded on routine inspections.
4. A reference “Key” which identifies the major risk factors and Food Code interventions on the
jurisdiction's inspection report form. [Note: A jurisdiction will not be penalized under Standard
6 for sections of the Food Code which have not yet been adopted.]
5. A copy of the jurisdiction’s established written procedures, including random sampling
method used to measure the effectiveness of the compliance and enforcement program.
6. Documentation from a statistician of equivalence to the Explanation of the Statistical Model
for Standard 6.

6-3

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 6 – COMPLIANCE AND ENFORCEMENT
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment and Verification Audit Form
The Standard 6: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process for Standard 6. The form is
included at the end of these instructions. Whether one is performing a program self-assessment or
conducting a verification audit, it is recommended that the form be available as a reference to the
Standards 6 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of Standard 6 must indicate on the form if each of the criteria
is met. These responses are recorded under the column “Jurisdiction’s Self-Assessment.”
The self-assessor must review each Standard 6 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must place
an “X” in the “YES” box under the “Jurisdiction’s Self-Assessment” column of the Standard 6: Program
Self-Assessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 6 criteria are met,
the self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column
of the Standard 6: Program Self-Assessment and Verification Audit Form. The self-assessor may specify
why the criteria are not met in the box provided.
The self-assessor should review the findings on the Standard 6: Program Self-Assessment and
Verification Form to ensure accuracy. The jurisdiction will be required to provide the auditor with their
completed Standard 6: Program Self-Assessment and Verification Audit Form and any documents used
to support and demonstrate that the Standard 6 criteria have been met.
Once all the Standard 6 criteria have been reviewed and the findings from the Standard 6: Establishment
File Worksheet and the Standard 6: Self-Assessment Summary Worksheet documented on the form, the
self-assessor must complete the Program Self-Assessment Summary section on page one of the Standard
6: Program Self-Assessment and Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 6 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 6 criteria.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 6: Program SelfAssessment and Verification Audit Form to the auditor for review. The auditor must indicate on the
Standard 6: Program Self-Assessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that
the Standard criteria are met, the verification auditor places and “X” in the “NO” box under the
“Auditor’s Verification” column of the form. The verification auditor must specify why the criterion is
not met in the box provided. Supplemental pages may be used to explain findings.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the verification audit. In particular,
any Standard 6 criteria for which the auditor cannot confirm through a review of the self- assessment
should be thoroughly discussed. Ample time should be allotted to ensure that there is a clear
understanding of the reasons for the “non-conforming” finding. The auditor should be prepared to
identify the elements required for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, audit must complete the Verification Audit Summary
section located on the first page of the Standard 6: Program Self-Assessment and Verification Audit
Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 6 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 6 criteria if the auditor does not confirm the self-assessment
findings.

6-5

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 6: Compliance and Enforcement
Program Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 6 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 6
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 6 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 6 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
6 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 6 is true and correct.
Signature of the Verification Auditor:

6-6

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 6: Compliance and Enforcement
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: ________________________________________________________________________________________________________
Criteria

Element

1. Compliance
and
Enforcement
Procedure

a) The jurisdiction has a
written step-by-step
compliance and enforcement
procedure that describes
what actions and tools (i.e.,
forms, documents,
interventions) are to be used
to achieve compliance.

1. Compliance
and
Enforcement
Procedure

b) The jurisdiction's
inspection form(s) record
and quantify the compliance
status of foodborne illness
risk factors, Food Code
interventions and other
serious code violations.

a) The jurisdiction has
written documentation that
verifies the review of the
effectiveness of the staff's
implementation of the
2. Assessment
program's compliance and
of Effectiveness
enforcement procedure that
includes a selection of
establishment files for
review in accordance with
the Standard criteria.

6-7

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

b) The jurisdiction has
written documentation
verifying that at least 80% of
the sampled files follow the
agency's step-by-step
compliance
and enforcement
2. Assessment
procedures
and
actions were
of Effectiveness
taken to resolve out-ofcompliance risk factors
recorded on the selected
routine inspection in
accordance with the
Standard criteria.

GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

6-8

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 6 – COMPLIANCE AND ENFORCEMENT
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELF-ASSESSMENT
Using the Standard 6 Establishment File Worksheet
The self-assessor should have the Standard 6 self-assessment worksheets available as a reference when
reading through this guidance. The following worksheets are provided at the end of these instructions:
• Standard 6: Self-Assessment Summary Worksheet
• Standard 6: Establishment File Worksheet
The Standard 6: Self-Assessment Summary Worksheet is designed to provide a listing of the establishment
files or routine inspections selected from the jurisdiction’s inventory that were reviewed as part of the selfassessment process. This worksheet provides a summary as to whether or not the inspection file/ records for
each of the randomly selected establishments meet the Standard 6 criteria.
The Standard 6: Establishment File Worksheet provides a systematic way of collecting the compliance and
enforcement history for each of the selected establishments or routine inspections. Jurisdictions
do not have to use this form. However, a jurisdiction must provide documentation of the review process. The
documentation must indicate if appropriate compliance and enforcement actions were taken for out-ofcontrol risk factors and Food Code interventions at each establishment selected for the self-assessment.
STEP 1 – Assess the Elements in the Written Compliance & Enforcement Program
To meet the criteria of Standard 6, the jurisdiction must have written step-by-step procedures outlining its
compliance and enforcement process. The jurisdiction should review its compliance and enforcement
policies and procedures to ensure that there is clear guidance for staff. The policies and procedures should
provide steps and actions to be taken when various categories of violations occur. The policies and
procedures should also provide a progression of steps to be taken when violations are not corrected within
regulatory or administratively established time frames.
In addition, the jurisdiction’s inspection form must use the IN compliance, OUT of compliance, Not
Applicable, and Not Observed conventions to record the compliance status of the foodborne illness risk
factors and the public health interventions identified in the Food Code to meet the requirements of Standard
6.
STEP 2 – File Selection Process
In order to meet the criteria in Standard 6, jurisdictions must select files for review. There are three different
methods that can be utilized for file selection, outlined as option 1, 2 and 3. Jurisdictions must select one of
the three options.
•

Option 1: Review each inspection when an FBI Risk Factor or Public Health intervention was
marked out of compliance;
Part I – All inspection files are selected by the jurisdiction for review

•
6-9

Option 2: Using a selection method as described in this standard set forth in Parts I-II;

Voluntary National Retail Food Regulatory Program Standards – January 2022

Part I - Determine the number of establishment files to review
Jurisdictions with less than 800 total establishments must select at least 40 files for review. If a
jurisdiction has less than 40 establishments in the inventory, then all files will be reviewed.
Jurisdictions with 800 or more establishments must select a sample equal to 5% of the total
establishments (up to a maximum of 70 files). This initial selection of sample files must be the first
files reviewed.
Establishment Inventory

Number of Files to Review

Less than 800

40 establishment files

800 or more

5% of the total number of establishments
(Up to a maximum of 70 files)

Part II - Randomly select establishment files from the jurisdiction’s inventory
Sample selection using a table of random numbers, or a random number generator is preferred. This
can be performed with a card file, ledger, list, or automated data system. The card file, ledger, list, or
automated database must be numbered or ordered in some fixed fashion so that the establishment files
can be associated with the numbers selected by the random number generator.
There are many ways a jurisdiction can produce a listing of all the establishments in its inventory. The
listing can be produced alphabetically; by permit number; permit date, etc. The establishment listing
can be computer generated or it can be produced manually. Any method can be used as long as all the
establishments are included once and only once.
When randomly selecting establishments, the self-assessor must perform the following steps:
1. Record the random numbers in the order they were selected under the column “Randomly
Selected Numbers” on the Standard 6: Self-Assessment Summary Worksheet;
2. Identify the establishment file that corresponds to the randomly selected number recorded on the
Standard 6: Self-Assessment Summary Worksheet; and
3. Record the establishment name or identification number for each of the randomly selected
numbers on the Standard 6: Self-Assessment Summary Worksheet.
•

Option 3: Using a selection method, other than those described in Option 1 and 2 above, established
by the jurisdiction with written procedures that includes supporting documentation and worksheets
that:
Part I – Describe the compliance and enforcement review process;
Part II – Describe and include the random selection of establishment files or routine inspections that
have at least one Foodborne Illness or Public Health Intervention Violation marked OUT of
compliance; and
Part III – Is equivalent to the published Standard 6 statistical model for the number of inspections
reviewed and the method of selection.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Determine the need to review additional randomly selected establishment files.
If using Option 2 or 3, determine the need to review additional files or inspections. Randomly selected
establishment files or routine inspections should be removed from the sample only if:
• The establishment has not been in business long enough to have at least three routine
inspections; or
• Files in which no risk factor or public health intervention violation was documented on the
“start-point” inspection.
When an establishment file is eliminated from the initial random draw, a new establishment file must be
selected using the random selection methodology used for the original sample. The Establishment File
Worksheet contains a specific page for listing the results from the randomly selected substitute
establishment files. If there is a need to identify other substitute establishment files, continue to use the
randomly generated numbers in the order they appear to identify the corresponding establishments from
the jurisdiction's inventory. The file number and the name of the originally selected establishment that
did not qualify for the self-assessment review process must be recorded under the first column of the
“Substitute Establishment” summary worksheet. This provides a direct association between the newly
selected establishment file and the one it is replacing.
STEP 3 - Assess the Effectiveness of the Compliance & Enforcement Program
Each jurisdiction shall measure the effectiveness of their compliance and enforcement program to determine
if the jurisdiction has satisfactorily resolved FBI Risk Factor and Public Health Intervention violations.
The results of the review will be used to assess the success of the compliance and enforcement program.
The following process are methods that jurisdictions can use for Option 1 (all files reviewed) or for Options
2-3 (randomly selected establishment files or routine inspections).
Conduct a review of each selected inspection (Option 1) , or randomly selected establishment file / routine
inspection (Option 2 or 3). When reviewing the compliance and enforcement history for each of the randomly
selected files, the self-assessor should use a form similar to the Standard 6: Establishment File Worksheet to
document their findings. This worksheet is included at the end of these instructions.
For each selected establishment or randomly selected establishment listed on the Standard 6: Self-Assessment
Summary Worksheet, the self-assessor must complete a separate Standard 6: Establishment File Worksheet.
When using Options 1 or 2, the worksheet must document the following information:
 The name of the establishment and the permit number in the upper left-hand corner of the
“Establishment File Worksheet;”
 The “Start Point Inspection Date” under the heading provided. The “start-point” inspection will be the
third oldest routine inspection in the establishment’s file at the time of the review if it shows a
violation of one of the risk factors or public health interventions. If no risk factor or public health
intervention violation is shown on that inspection, then the fourth oldest routine inspection may be
used if it shows a risk factor or public health intervention violation. If no violation of a risk factor or
public health intervention is documented on the third or fourth oldest routine inspection, then no
“start-point” inspection exists for that establishment. Therefore, that establishment’s file “does not
qualify” for the self-assessment review process. If the establishment “does not qualify,” the selfassessor must check the
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Voluntary National Retail Food Regulatory Program Standards – January 2022

D.N.Q (did not qualify) box under the “Status of Reviewed File” and remove it from the review
process. A substitute establishment file must be chosen using the second set of randomly selected
numbers to replace this file.
 The Establishment File Worksheet lists ten foodborne illness risk factor and public health
interventions along the top line. The self-assessor will record item numbers or other identifiers from
its inspection form that correspond with each of the ten listed risk factors and public health
intervention in the spaces provided adjacent the heading Reference to local inspection items.
Note: The self-assessor should use the Standard 1: Self-Assessment Worksheet for Part I Interventions and Risk Factor Controls to identify the jurisdiction's code requirements that
correspond to the Food Code provisions included under each of the ten foodborne illness risk factor
and intervention categories. If there is no corresponding local requirement for a particular foodborne
illness risk factor or Food Code intervention, that item can be marked as "Not Applicable" in the
Reference Key. Jurisdictions are not penalized under Standard 6 for items in the Food Code that have
not been adopted.
 Using the Start Point Inspection Violations row of the worksheet, the self-assessor places an "X"
under the appropriate foodborne illness risk factor or public health intervention headings if a violation
was noted on the “start-point” inspection. The “X” must be entered under the appropriate heading
even if the violations were corrected on site.
When using Option 3, The worksheet must document the following information:
 The number of inspections selected which must be statistically equal to the Option 2 number of
establishment files
 The name of the establishment and the permit number in the upper left-hand corner of the
“Establishment File Worksheet;”
 The “Start Point Inspection Date” under the heading provided. The “start-point” inspection will be
randomly selected and must have at least one out of compliance risk factor or public health
intervention at the time of the review and sufficient time must have passed to evaluate follow up
depending on individual jurisdictional policy, to qualify for the review. For files that do qualify (at
least one out of compliance risk factor or public health intervention and sufficient time to assess
follow up based on the jurisdiction’s policy) the inspection should be reviewed to ensure the
jurisdiction’s compliance and enforcement policy was followed for the inspection. Additional
inspections in the establishment file may need to be reviewed to determine if the policy was followed.
The self-assessor may need to go back several inspections to obtain the violation history or may need
to look forward, at more recent inspections to see if a correction was made.
 Documentation showing that the self-assessor has gone back as far as needed to ensure the policy was
followed.
 If no violation of a risk factor or public health intervention is documented, then no “start-point”
inspection exists for that inspection. Also, if the “start-point” inspection has an out of compliance risk
factor or public health intervention but there has been insufficient time based on the jurisdictional
policy time frames to evaluate if compliance and enforcement protocols have been followed it “does
not qualify” for the self-assessment review process. If the establishment “does not qualify,” the selfassessor must check the D.N.Q (did not qualify) box under the “Status of Reviewed File” and remove
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Voluntary National Retail Food Regulatory Program Standards – January 2022

it from the review process. A substitute inspection file must be chosen using the second set of
randomly selected numbers to replace this file.
 For the purposes of the self-assessment, follow-up actions have been divided into three types:
•

Was on-site corrective action taken? – On-site corrective action that occurs at the time of a
routinely scheduled inspection;

•

Was follow-up corrective action taken? – Follow-up action that occurs after the routine
inspection such as re-inspection, training, risk control plans, and informal conferences;

•

Was enforcement action taken? – Enforcement activities such as fines permit suspension,
hearings, mandated training, restriction of operations, embargo, etc.

Completion of these three items requires a complete review of the selected establishment file. To
facilitate the documentation of the file review, the self-assessor may complete the table provided at
the bottom of the Establishment File Worksheet. The summary table provides a method for defining
the acronyms and notations used on the worksheet to describe the type of compliance and
enforcement action taken. The self-assessor must review all the documentation in the establishment
file from the “start-point” inspection forward to the current date to determine if follow-up action was
taken and documented for each risk factor and public health intervention that was out of compliance
on the “start-point” inspection.
 The self-assessor must review the follow-up actions for each risk factor and public health intervention
violation documented on the “start-point” inspection. The self-assessor must determine if the followup actions complied with the jurisdiction’s written procedures.
•

The self-assessor must place an “X” in the “File Meets the Standard 6 Criteria” box if:
o The completed Worksheet shows at least one follow-up action in each column where a
foodborne illness risk factor or public health intervention violation was marked on the
“start-point” inspection; and

•

o The jurisdiction’s written procedure was followed.

The self-assessor must place an “X” in the “File Does NOT Meet the Standard 6 Criteria box.” if:
o The completed Worksheet shows that one or more of the “start-point” violations do not
have at least one follow-up activity; or
o The jurisdiction’s written procedure was not followed for one or more follow-up activities.

 When the review for each randomly selected establishment file is completed, the self- assessor must
indicate his or her findings on the Self-Assessment Summary Worksheet. Under the “Status of
Reviewed File” column, the self-assessor must check one of the following boxes:
• “YES” – indicating that the reviewed file meets the Standard 6 criteria.
• “NO” – indicating that the reviewed file does not meet the Standard 6 criteria.
• “D.N.Q.” – indicating that the establishment file did not qualify for the assessment and a
substitute file will need to be randomly selected and reviewed.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STEP 4 – Determine if the Standard 6 criteria are met
Standard 6 requires that 80 percent of the reviewed files adhere to the jurisdiction’s written compliance and
enforcement procedures. Files that “did not qualify” (D.N.Q.) for the self-assessment review are not included
in the calculation for this percentage. The self-assessor must determine if 80% of the establishment files
reviewed met the Standard 6 criteria.

6-14

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 6: Compliance and Enforcement
Self-Assessment Summary and Worksheet
Establishment Files
Jurisdiction Name:
Number of
Files Selected
1

6-15

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
8

6-16

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
18

6-17

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
28

6-18

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
38

6-19

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
48

6-20

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
58

6-21

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
68

6-22

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 6: Compliance and Enforcement
Self-Assessment Summary and Worksheet
Substitute Establishment Files
Jurisdiction Name:
Number of
Files Selected
1

6-23

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
8

6-24

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected
18

6-25

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not Qualify

Self-Assessor’s General Comments

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 6: COMPLIANCE AND ENFORCEMENT
ESTABLISHMENT FILE WORKSHEET
File Number: ______________ Establishment Name: _______________________ Permit Number: _____________ Inspection Date (Start Point): ____________
Risk Factor and Food Code Interventions
Unsafe
Sources

Improper
Inadequate
Holding
Temperatures
Cooking
Hot & Cold

Time/ Temperature
Parameters Not Met
(Time as a Control,
date marking, rapid
cooling)

Bare Hand
Contact with
Ready-to-Eat
Food

Poor Personal
Hygiene

Consumer
Advisory (when
required)

Contaminated
Food Contact
Equipment

Demonstration of
Knowledge by PIC

Employee Health
Control System or
Policy Implemented

Reference to local
inspection items
Start Point Inspection
Violations
Was on-site corrective
action taken?
Was follow-up
corrective action taken?
Was enforcement action
taken?

Note:

1. Each column in which a violation is noted must receive a yes response to one of the three questions in order for the file to pass. Additionally, written procedures must have been
followed

Was the Written Procedure Followed? _______ YES _______ NO
Jurisdiction’s definitions of acronyms and notations used to reflect follow-up action
Acronym /Notation

Definitions

Acronym /Notation

Definitions

Acronym/Notation

File Meets the Standard 6 Criteria: _______ YES _______ NO
6-26

Definitions

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 6 – COMPLIANCE AND ENFORCEMENT
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A VERIFICATION
AUDIT
Using the Standard 6: Verification Audit Worksheet
The auditor should have the Standard 6: Verification Audit Worksheets available as a reference when
reading through this guidance. The following worksheet is provided at the end of these instructions:
• Standard 6: Verification Audit Worksheet
The Standard 6: Verification Audit Worksheet is designed to provide a listing of the establishments
randomly selected from the jurisdiction’s inventory that were reviewed as part of the self-assessment
process. This worksheet provides a summary as to whether or not the inspection file/records for each of the
randomly selected establishments meet the Standard 6 criteria.
The Standard 6: Establishment File Worksheet provides a systematic way of collecting the compliance and
enforcement history for each of the randomly selected establishments. Jurisdictions do not have to use this
form. However, a jurisdiction must provide documentation of the review process. The documentation must
indicate if appropriate compliance and enforcement actions were taken for out-of-control risk factors and
Food Code interventions at each establishment randomly selected for the
self-assessment.
STEP 1 – Verify the Elements in the Written Compliance & Enforcement Program
To meet the criteria of Standard 6, the jurisdiction must have written step-by-step procedures outlining its
compliance and enforcement process. The verification auditor should review its compliance and
enforcement policies and procedures to ensure that there is clear guidance for staff. The policies and
procedures should provide steps and actions to be taken when various categories of violations occur. The
policies and procedures should also provide a progression of steps to be taken when violations are not
corrected within regulatory or administratively established time frames.
Standard 6 does not dictate a required compliance process. The jurisdiction is free to determine any actions
to be taken for violations of its regulations and the progression of consequences for repeated violations.
The time frames and triggers for additional actions are also left to the discretion of the jurisdiction.
In addition, to meet the requirements of Standard 6, the jurisdiction’s inspection form must use the IN
compliance, OUT of compliance, Not Applicable, and Not Observed conventions to record the compliance
status of the foodborne illness risk factors and the public health interventions identified in the Food Code.
Jurisdictions that have not adopted all the recommended foodborne illness risk factors and Food Code
interventions are not penalized under Standard 6 for these omissions.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STEP 2 – Verify the Effectiveness of the Compliance & Enforcement Program
Randomly selected establishment files must be reviewed to determine if documented violations were
resolved satisfactorily. The results of the review will be used to assess the success of the compliance and
enforcement program. This section of the self-assessment process has been broken down into the following
four parts:
Part I Verify that the jurisdiction reviewed the appropriate number of files
Part II Randomly select establishment files from the jurisdiction’s Standard 6: Self-Assessment
Summary Worksheet
Part III Verify Self-Assessment findings for each selected establishment file
Part IV Verify that 80% of selected establishment files adhere to the jurisdiction's written
compliance and enforcement procedures
Part I - Verify that the jurisdiction reviewed the appropriate number of files
The number of establishment files a jurisdiction must review as part of the Standard 6 self-assessment
process is based on the size of their establishment inventory. Jurisdictions with less than 800 total
establishments must select at least 40 files for review. If a jurisdiction has less than 40 establishments in
the inventory, then all files will be reviewed. Jurisdictions with 800 or more establishments must select a
sample size equal to 5% of the total establishments up to a maximum of 70 files.
Establishment Inventory

Number of Files to Review for the
Self-Assessment

Less than 800

40 establishment files

800 or more

5% of the total number of establishments
(Up to a maximum of 70 files)

Some of the randomly selected establishment files listed on the Standard 6: Self-Assessment Summary
Worksheet may not qualify for the self-assessment process. Deletion of an establishment from the sample
of files to be reviewed as part of the self-assessment process is limited to those establishments where:
1. The selected establishment has not been in business long enough to have at least three regularly
scheduled routine inspections; or
2. A review of inspection reports in the selected establishment file reveals that there were no risk
factor or Food Code intervention violations documented on the "start-point" inspection
The jurisdiction's self-assessment process must include a listing of the substitute establishment files that
were reviewed as replacements for those that did not qualify. When an establishment does not qualify for
the self-assessment process, the substitute establishment must not be recorded on the Standard 6: SelfAssessment Summary Worksheet, but instead on the Standard 6: Self-Assessment Summary Worksheet
Substitute Establishment Files Worksheet. The auditor should verify this.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Part II - Randomly select establishment files from the jurisdiction’s Standard 6: Self-Assessment
Summary Worksheet
Using a table of random numbers or a random number generator is the preferred method of sample
selection. The random selection will be made from the establishment files listed on the jurisdiction's
Standard 6: Self-Assessment Summary Worksheet. The number of establishment files that must be
selected for review as part of the verification audit process is indicated in the chart below.

Establishment
Inventory
Less than
800
800 or
more

Number of Files to Review for
the Self-Assessment
40 establishment files
5% of the total number of establishments
(Up to a maximum of 70 files)

Number of Files to
Select for the
Verification Audit
5
10

Using the jurisdiction's Standard 6: Self-Assessment Summary Worksheet, the verification auditor will
identify the establishment files that correspond to the randomly selected number recorded on the
Standard 6: Verification Audit Worksheet. The verification auditor must record the establishment name
or identification number for each of the randomly selected numbers on the Standard 6: Verification Audit
Worksheet.
The verification auditor must only review establishment files that the jurisdiction has indicated as
meeting all the elements of their compliance and enforcement procedures. This will require the
verification auditor to eliminate establishment files that are marked “NO” on the jurisdiction's SelfAssessment Summary Worksheet. (An “X” placed in the “NO” box indicates that the self-assessment
review process determined that the inspection history documented in the establishment file did not meet,
or only partially met, the Standard 6 criteria and all the elements in the jurisdiction's written compliance
and enforcement procedures.)
In instances where the verification auditor has randomly selected an establishment file from the
jurisdiction's Standard 6: Self-Assessment Summary Worksheet that did not qualify (D.N.Q.) for the selfassessment review process, the substitute establishment that the jurisdiction selected for that disqualified
establishment should be used.
Note: There are two types of substitutes for the audit process, which are treated differently:
1. If the auditor selects an establishment that was previously failed by the self-assessor, then use the
auditor-generated substitute list of random numbers to select a substitute establishment.
2. If the auditor selects an establishment that “did not qualify” for the original self-assessment, then
use the substituted establishment that was already assigned in the original self- assessment
review.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Part III - Verify Self-Assessment findings for each selected establishment file
Using the jurisdiction's written compliance and enforcement procedures, the verification auditor will
review the Establishment File Worksheet for each of the establishments randomly selected for the
verification audit.
The Standard 6: Establishment File Worksheet provides a systematic way of documenting the
compliance and enforcement history for each of the randomly selected establishments. Jurisdictions do
not have to use this form but must provide documentation of the review process conducted to determine
whether the appropriate compliance and enforcement actions for out-of-control risk factors and Food
Code interventions were taken for each selected establishment.
Review the inspection history in each selected file beginning with the identified “start-point” inspection
and moving forward through two additional inspections. Verify that either on-site corrective action,
follow-up corrective action or enforcement action occurred by the end of the third inspection for each
out-of-compliance risk factor or intervention marked on the start point inspections. In addition, verify
that the actions taken on each violation documented on the “start-point” inspection followed the
jurisdiction's written compliance policy and procedures.
In order for an establishment file to meet the Standard 6 criteria, each column marked with a violation at
the “start-point” inspection must have a subsequent indication that at least one type of follow-up action
was taken, and the jurisdiction's written procedures must have been followed. A single violation on the
“start-point” inspection without a final resolution, either correction or compliance/enforcement activity,
will result in a determination that the establishment file does not meet the Standard 6 criteria. In any
instances where the auditor disagrees with the jurisdiction's self-assessment of a file, the auditor must
meet with the jurisdiction's program manager or representative to gain a full understanding of the
rationale used for the self-assessment determination.
The verification auditor will record his or her findings for each of the establishment files reviewed on
the Standard 6: Verification Audit Worksheet. If the verification audit of the establishment file review
indicates that the full intent of the Standard 6 criteria is met, place an “X” in the “YES” box. If full
intent of the Standard 6 criteria is not met, place an “X” in the “NO” box. If the verification auditor
disagrees with the jurisdiction's self-assessment decision, an explanation must be provided in the last
column of the Standard 6: Verification Audit Worksheet. Additional sheets can be used to document the
need for expanded explanations.
Part IV - Verify that 80% of selected establishment files adhere to the jurisdiction's written compliance
and enforcement procedures
The criteria for Standard 6 requires that 80 percent of the files with an identified violation of a foodborne
illness risk factor or a Food Code intervention on the “start-point” inspection adhere to the jurisdiction's
written compliance and enforcement procedures. Files that “did not qualify” (D.N.Q.) for the selfassessment review are not used in the calculation of the percentage.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Legitimate differences of opinion regarding stringency of language may occur during the verification
audit process. An approximate ten percent (10%) discrepancy allowance is made to accommodate
potential differences in interpretations.
Jurisdictions with less than 800 Establishments - If two or more of the five audited establishment files
rated as passing by the jurisdiction are not verified by the auditor as having met the Standard 6 criteria,
the Part III element fails to meet the criteria, and no further sampling is necessary. Even if no additional
disagreements are found by sampling an additional set of randomly drawn establishment files, the dilution
of agreements to disagreements will be insufficient to meet the approximate ten percent (10%)
disagreement allowance.
Determine the need for supplemental sampling. If only one establishment file from the initial sample is
determined by auditor to have not met the Standard 6 criteria, then randomly select an additional 5
establishment files. Follow the same audit process used to review the first set of establishment files.
The Standard 6: Verification Audit Worksheet for substitute establishment files, provided on a following
page, can be used to record all the information related to the supplemental sampling of establishment
files.
If no additional disagreements in the review of establishment files are noted, then the jurisdiction meets
the Standard 6 criteria. If one or more additional establishment files fails the audit review, then the
Standard 6 criteria are not met, since the dilution of agreements to disagreements will be insufficient to
meet the approximate ten percent (10%) disagreement allowance.
Jurisdictions with more than 800 Establishments - If three or more of the ten audited establishment files
rated as passing by the jurisdiction are not verified by the auditor as having met the Standard 6 criteria, then
the jurisdiction fails to meet Standard 6. Even if no additional disagreements are found by sampling an
additional set of randomly drawn establishment files, the dilution of agreements to disagreements will be
insufficient to meet the approximate ten percent (10%) disagreement allowance.
Determine the need for supplemental sampling. If one or two establishment files from the initial sample are
determined by auditor to have not met the Standard 6 criteria, then randomly select an additional 10
establishment files. Follow the same audit process used to review the first set of establishment files. The
Standard 6: Verification Audit Worksheet for substitute establishment files, provided on a following page,
can be used to record all the information related to the supplemental sampling of establishment files.
No more than a total of two of 20 establishment files drawn can be determined by the auditor as not
meeting the Standard 6 criteria. If more than two establishment files fail the audit review, then the
Standard 6 criteria are not met, since the dilution of agreements to disagreements will be insufficient to
meet the approximate ten percent (10%) disagreement allowance.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 6: Compliance and Enforcement
Verification Audit Worksheet
Establishment Files
Jurisdiction Name: __________________________________________________________________________________________________
Number of
Files Selected

6-32

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not
Qualify

If NO, Auditor is to specify why the establishment
file does not meet all the elements contained in the
jurisdiction’s written compliance and enforcement
procedures

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected

6-33

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not
Qualify

If NO, Auditor is to specify why the establishment
file does not meet all the elements contained in the
jurisdiction’s written compliance and enforcement
procedures

Voluntary National Retail Food Regulatory Program Standards – January 2022

Number of
Files Selected

6-34

Randomly
Selected
Number

Name or ID of Establishment

Yes

Does Not
Qualify

If NO, Auditor is to specify why the establishment
file does not meet all the elements contained in the
jurisdiction’s written compliance and enforcement
procedures

Voluntary National Retail Food Regulatory Program Standards – January 2022

Improper
Inadequate
Holding
Temperatures
Cooking
Hot & Cold

Time/ Temperature
Parameters Not Met
(Time as a Control,
date marking, rapid
cooling)

Bare Hand
Contact with
Ready-to-Eat
Food

Poor Personal
Hygiene

Consumer
Advisory (when
required)

Contaminated
Food Contact
Equipment

Demonstration of
Knowledge by PIC

Employee Health
Control System or
Policy Implemented

Reference to local
inspection items
Start Point Inspection
Violations
Was on-site corrective
action taken?
Was follow-up
corrective action taken?
Was enforcement action
taken?

Note:

1. Each column in which a violation is noted must receive a yes response to one of the three questions in order for the file to pass. Additionally, written procedures must have been
followed

Was the Written Procedure Followed? _______ YES _______ NO
Jurisdiction’s definitions of acronyms and notations used to reflect follow-up action
Acronym /Notation

Definitions

Acronym /Notation

Definitions

Acronym/Notation

File Meets the Standard 6 Criteria: _______ YES _______ NO
6-35

Definitions

Voluntary National Retail Food Regulatory Program Standards – January 2022

EXPLANATION OF THE STATISTICAL MODEL FOR STANDARD 6
In this part of the self-assessment, the self-assessor or auditor will review a randomly selected sample of
establishment files. The review will determine if the establishments were given adequate follow-up for documented
violations. Each file will be scored as passing or failing each of four aspects. In order for the program to pass, each
aspect must be found passing for at least 80 percent of the establishment files reviewed.
If the inventory of establishment files is less than 800, the self-assessor or auditor must randomly select 40 files at a
minimum. If the inventory of establishment files is 800 or more, the self-assessor or auditor must randomly select 5
percent of the inventory (up to a maximum of 70).
At the smallest sample, a 90 percent performing jurisdiction would pass the standard 95.4 percent of the time using
40 files. Using 45 files, the passing rate would increase to 96.4 percent, and using 50 files it raises to 97.2 percent.
Raising the minimum number of files from 20 to 40 would increase the workload by 50 percent. It would reduce the
risk of failure, however, for a 90 percent performer from 12.4 percent to 7.6 percent, a 41percent reduction. To
reduce the change of failing, it is possible that some programs with inventories much less than 800 might still wish
to expand their sampling to 40 files. For purposes of the self-assessment requirements, 40 is the minimum number
of files to be reviewed but a larger minimum is permitted.
The statistical task here was to determine an upper bound on the sample size in order to avoid wasted effort. The
proposition that was used to decide the upper bound was to have a high rate of passage for any program that does
each aspect correctly 90 percent of the time. A further proposition was that we have a low rate of passage for any
program that does each aspect correctly only 70 percent of the time.
Even at the smallest sample of 40 files, a 70 percent performing program would pass the standard only 1.3 percent
of the time; at 30 files the passing percent drops to 0.4 percent. Therefore, the low passing rate for 70 percent
performers will be met easily by any upper bound.
For inventories of 800 or more, the standard calls for sampling 5 percent of the inventory, up to some limit. The
following are the probabilities of passing the Standard for a series of sample sizes, given that the program is a 90
percent performer for each aspect in any particular file review.

Sample
20
25
30
35
40
45
50
55

Probability of passing if
overall performance is 90%
0.876
0.903
0.924
0.941
0.954
0.964
0.972
0.978

Sample
60
65
70
75
80
85
90

Probability of passing if
overall performance is 90%
0.983
0.987
0.990
0.992
0.994
0.995
0.996

At 70 files, a 90 percent performing program has a 99 percent chance of passing this Standard. Going further buys
only tiny increments of improvement. At much higher sample sizes of around 140 files, lower performing programs
significantly increase their chances of passing, a change of fortune that favors the very biggest programs. Therefore,
the upper limit boundary has been set at 70 files for all programs of all sizes.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standardized Key Crosswalk to the 2017 FDA Food Code
This crosswalk is intended to assist jurisdictions in making comparisons with their code against the 2017 FDA Food Code. The Form 3-A Food Inspection Report
Item numbers are based on the model FDA inspection form found in Annex 7 of the 2017 FDA Food Code. Completion of the crosswalk is intended to assist
jurisdictions completing Standard 6 documentation which identifies major risk factors and Food Code interventions on the jurisdiction’s inspection report form.
Annex 5 contains additional information regarding the content of Form 3-A.

FBI Risk Factors
Supervision

Food Establishment
Inspection Report
(Form 3-A) Item
Number

Applicable 2017 FDA Food Code References

PIC

2-101.11, 2-102.11A), (B) and (C)(1), (4)-(16), 2-103.11 (A) (P)

CFPM

2-102.12(A)

Management

2-102.11(C)(2), (3) and (17), 2-103.11(O), 2-201.11(A), (B), (C), and (E)

Restriction and Exclusion

2-201.11(D) and (F), 2-201.12, 2-201.13

Vomit and Diarrheal events

2-501.11

Eating, Tasting and Drinking

2-401.11, 2-301.12

Discharge from eyes, nose, and mouth

2-401.12

Hands Clean and Properly Washed

2-301.11, 2-301.12, 2-301.14, 2-301.15, 2-301.16

No Bare Hand Contact with RTE Foods

3-301.11, 3-801.11(D)

Adequate handwashing sinks

5-202.12, 5-203.11

Employee Health

Good Hygienic Practices

Preventing Contamination by Hands

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Voluntary National Retail Food Regulatory Program Standards – January 2022

FBI Risk Factors
Approved Source

Food Establishment
Inspection Report
(Form 3-A) Item
Number

Applicable 2017 FDA Food Code References

Food obtained from approved source

3-201.11 thru 3-201.17, 3-202.13, 3-202.14, 3-202.110, 5-101.13

Food Received at proper temperature

3-202.11

Food in good condition, safe and unadulterated

3-101.11, 3-202.15

Required records available, shellstock tags, parasite
destruction

3-202.18, 3-203.12, 3-402.11, 3-402.12

Food Separated and Protected

3-302.11, 3-304.11, 3-304.15(A), 3-306.13(A)

Food Contact surfaces; cleaned and sanitized

4-501.111 thru 4-501.115, 4-601.11(A), 4-602.11, 4-602.12, 4-702.11, 4703.11

Proper disposition or returned, previously served,
reconditioned and unsafe food

3-306.14, 3-701.11

Cooking

3-401.11, 3-401.12, 3-401.14

Reheating

3-403.11

Cooling

3-501.14

Hot Holding

3-501.16(A)(1)

Cold Holding

3-501.16(A)(2) and (B)

Date marking

3-501.17, 3-501.18

Time as Public Health Control

3-501.19

Protection from Contamination

Time/Temperature Control for Safety

6-38

Voluntary National Retail Food Regulatory Program Standards – January 2022

FBI Risk Factors
Consumer Advisory
Consumer Advisory provided for raw/undercooked foods

Food Establishment
Inspection Report
(Form 3-A) Item
Number

Applicable 2017 FDA Food Code References

3-603.11

3-801.11(A), (B), (C), (E) and (G)

Food Additives approved and properly used

3-202.12, 3-302.14

Toxic substances identified, stored, and used

7-101.11, 7-102.11, 7-201.11, 7-202.11, 7-202.12, 7-203.11, 7-204.12, 7204.13, 7-204.14, 7-205.11, 7-206.11, 7-206.12, 7-206.13, 7-207.11, 7207.12, 7-208.11, 7-209.11, 7-301.11

3-404.11, 3-502.11, 3-502.12, 4-204.110(B), 8-103.12, 8-201.13, 8-201.14

HSP Populations
Pasteurized foods used; prohibited foods not offered
Food Color Additives and Toxic Substances

Conformance with Approved Procedures
Compliance with variance/specialized process/HACCP

*Item numbers listed in this column refer to the item numbers within FDA's Food Establishment Inspection Report (Form 3-A, found in Annex 7).

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 7
INDUSTRY AND COMMUNITY
RELATIONS

Table of Contents

7-1

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 7
INDUSTRY AND COMMUNITY RELATIONS
This standard applies to industry and community outreach activities used by a retail food regulatory
program to solicit a broad spectrum of input about a retail food regulatory program’s previous, current,
and future activity, communicate sound public health food safety principles, and foster and recognize
community initiatives focused on the reduction of foodborne illness risk factors.
Requirement Summary
The jurisdiction documents participation in forums that foster communication and information exchange
among the regulators, industry, and consumer representatives.
The jurisdiction documents outreach activities that provide educational information on food safety.
Description of Requirement
1. Industry and Consumer Interaction
The jurisdiction sponsors or actively participates in forums with two-way communication such
as food safety task force meetings, advisory boards, advisory committees, customer surveys,
web- based meetings or forums, or other mechanisms. These forums shall present information
on food safety, food safety strategies and interventions to control risk factors. Offers of
participation must be extended to industry and consumer representatives.
2. Educational Outreach
Outreach encompasses industry and consumer groups as well as media and elected officials.
Outreach efforts may include industry recognition programs, web sites, newsletters, FightBAC®
campaigns, food safety month activities, food worker training, school-based activities, use of oral
culture learner materials, or other activities that increase awareness of the foodborne illness risk
factors and control methods to prevent foodborne illness. Outreach activities may also include
posting inspection information on a web site or in the press.
Agency participation in at least one activity in each of the above categories annually is sufficient to meet
this standard.
Outcome
The desired outcome of this standard is enhanced communication with industry and consumers through
forums designed to solicit input to improve the retail food regulatory program. A further outcome is the
reduction of foodborne illness risk factors through educational outreach and cooperative efforts with
stakeholders.

7-2

Voluntary National Retail Food Regulatory Program Standards – January 2022

Documentation
The quality records needed for this standard include:
1. Minutes, agendas, or other records documenting that forums were conducted,
2. For formal, recurring meetings, documents such as by-laws, charters, membership criteria and
lists, frequency of meetings, roles, etc.,
3. Surveys, web feedback links with associated follow-up materials and review documents,
4. Documentation of activities designed with input from industry and consumers to improve the
control of foodborne illness risk factors, or
5. Documentation of food safety educational efforts.
Statements of policies and procedures may suffice if activities are continuous, and documenting multiple
incidents would be cumbersome, (e.g., recognition provided to establishments with exemplary records or
an on-going web site).

7-3

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 7 – INDUSTRY AND COMMUNITY RELATIONS
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment & Verification Audit Form
The Standard 7: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process. The form is included at the end of
these instructions. Whether one is performing a program self-assessment or conducting a verification
audit, it is recommended that the form be available as a reference to the Standards 7 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of Standard 7 must indicate on the form if each of the criteria
is met. The self-assessor must record their findings under the column “Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use the form. An equivalent form or process is acceptable provided that
the results of the jurisdiction’s self-assessment for the specific Standard 7 criteria listed on the form are
available for review.
The self-assessor must review each Standard 7 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must place
an “X” in the “YES” box under the “Jurisdiction’s Self-Assessment” column of the Standard 7 Program
Self-Assessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 7 criteria are met,
the self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column
of the Standard 7: Program Self-Assessment and Verification Audit Form. The self-assessor may specify
why the criteria are not met in the box provided.
The self-assessor should review the findings on the Standard 7: Program Self-Assessment and
Verification Form to ensure accuracy. The jurisdiction will be required to provide the auditor with their
completed Standard 7: Program Self-Assessment and Verification Audit Form and any documents used
to support and demonstrate that the Standard 7 criteria have been met.
Once all the criteria have been reviewed and documented on the form, the self-assessor must complete the
Program Self-Assessment Summary section on page one of the Standard 7: Program Self-Assessment and
Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 7 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 7 criteria.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 7: Program SelfAssessment and Verification Audit Form to the auditor for review. The auditor must indicate on the
Standard 7: Program Self-Assessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor must place an “X” in the “YES” box under the
“Auditor’s Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that the
Standard criteria are met, the verification auditor must place and “X” in the “NO” box under the
“Auditor’s Verification” column of the form. The verification auditor must specify why the criterion is not
met in the box provided. Supplemental pages may be used to explain findings.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the on-site visit. In particular, any
Standard 7 criteria for which the auditor cannot confirm through a review of the self-assessment should be
thoroughly discussed. Ample time should be allotted to ensure that there is a clear understanding of the
reasons for the “non-conforming” finding. The auditor should be prepared to identify the elements
required for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on the first page of the Standard 7: Program Self-Assessment and Verification
Audit Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 7 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 7 criteria if the auditor does not confirm the self-assessment
findings.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 7: Industry and Community Relations
Program Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 7 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 7
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 7 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 7 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
7 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 7 is true and correct.
Signature of the Verification Auditor:

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 7: Industry and Community Relations
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: _______________________________________________________________________________________________________

Criteria

Element

The jurisdiction maintains written
documentation confirming that the
agency has sponsored or actively
participated in at least one
1. Industry
meeting/forum annually, such as food
and Consumer safety task forces, advisory boards /
Interaction
committees, customer surveys, webbased meetings, or forums.
Documentation confirms that offers of
participation have been extended to
industry and consumer representatives.
The jurisdiction maintains written
documentation confirming that the
agency has sponsored or coordinated
at least one educational outreach
activity annually directed at industry,
consumer groups, the media, and/or
elected officials. Educational outreach
2. Educational activities focus on increasing
Outreach
awareness of foodborne illness risk
factors and control methods to prevent
foodborne illness and may include
industry recognition programs, web
sites, newsletters, Fight BAC
campaigns, food safety month
activities, food worker training and
use of oral culture learner materials.

7-7

Jurisdiction’s Jurisdiction’s
SelfSelfAssessment
Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to
Verification Verification specify why criterion is
NO
YES
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 7 – INDUSTRY AND COMMUNITY RELATIONS
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELFASSESSMENT
Using the Standard 7 Self-Assessment Worksheet
The Standard 7: Self-Assessment Worksheet is designed to assist jurisdictions with maintaining
documentation and information required in the Standard 7 criteria. The Standard 7: Self-Assessment
Worksheet is divided in two sections:
1. Industry and Consumer Interaction; and
2. Educational Outreach.
STEP 1 – Confirm Documentation of Industry and Consumer Interaction Forums
The jurisdiction must maintain written documentation confirming that the agency has sponsored or
actively participated in at least one meeting/forum annually. Meetings and forums include, but are not
limited to food safety task forces, advisory boards or advisory committees, customer surveys, and webbased meetings or forums. Documentation also confirms that offers of participation have been extended
to industry and consumers. The jurisdiction must sponsor or participate in activities within its regulated
community. These activities must be documented in Part I on the Standard 7: Self-Assessment Worksheet.
The jurisdiction can use a different form if that document captures the same information.
The worksheet is included at the end of these instructions.
In order to properly document these activities, the self-assessor must:
• Enter the name of the forum/meeting under the “Forum Title” column;
• Document the names of meeting/forum participants. (The appropriate column should be used to
document participants from regulatory agencies, industry, and the public). If industry or
consumers were not present at a meeting, a statement should be entered that conveys that an offer
to participate was extended to these groups. The jurisdiction must maintain records to show that
an effort was made to gain input from the regulated community and the public. Copies of letters
of invitation or email printouts soliciting participation may be retained to substantiate the offer;
• Confirm that the dates of meetings have been recorded because it establishes that the activity took
place at least once annually in the most recent five-year period of the self-assessment. If meetings
are recurring such as held monthly, the jurisdiction may record “monthly” under the date column
and include the inception date of the meeting/forum; and
• Document action items and program items that resulted from the meeting. These should be
documented in the final column titled “Summary of Activities Related to Control of Risk
Factors.”
Examples of documents that may be reviewed as part of the self-assessment process:
 Minutes or agendas from the forum/meeting that describe the topics covered and the participants
present.
 For formal, recurring meetings, documents such as by-laws, charters, membership criteria and lists
that detail the purpose of the meetings, the committee make-up, frequency of meetings, and roles of
participants.
 Brochures that detail the purpose of the meeting and topics that were presented, or illustrate
collaborative food safety efforts by regulatory, industry and/or consumers.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

 Letters or printed email messages that document invitations to consumers and/or industry
representatives to participate in forums/meetings.
STEP 2 – Review Documentation of Educational Outreach
To meet the standard criteria, the jurisdiction must have performed at least one educational outreach
activity per year during the most recent five-year period of the self-assessment. The educational outreach
activity can be focused on industry, the media, consumers and/or elected officials. The methods of outreach
and a summary of the activities should be recorded in Part II of Standard 7: Self-Assessment Worksheet.
In order to properly document the education outreach activities, the self-assessor must:
• Record the date of the educational outreach activity under the “Date” column of the worksheet.
For outreach activities that are on-going such as the quarterly issuance of a food safety bulletin
or a website that posts inspection scores or other food safety information, the jurisdiction need
not record each date. For documentation of this component on the worksheet the information
may be listed as ongoing using a date range such as “January 1 – December 31, 2013” or
“Ongoing since 2008.” The jurisdiction would need to include the date the activity began so it
can be shown that the activities occurred over the most recent five-year period.
• Briefly describe the educational outreach initiative that was conducted on the recorded date or
within the specified time frame. This should be done under the “Summary of Activities” column.
Examples of documents that may be reviewed as part of the self-assessment process:
 Food Safety Brochures or Flyers
 Completed Customer Survey Cards
 Dated pictures of Food Safety Activities such as Fight BAC events held in the community,
display booths at fairs
 Jurisdiction Websites
 Food Safety Newsletters
 Acknowledgement letters thanking members from the regulatory agency for providing food
safety training in forums such as schools, churches, and civic groups
 A listing of scheduled Manager Certification courses
 Sign-in Sheets from Training or Courses offered to consumers and the regulated industry
 Minutes from meetings on food safety with elected officials
 Newspapers with printed food service facility scores
 Agendas from food safety expos

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 7: Industry and Community Relations Self-Assessment Worksheet
It is necessary to maintain records of the Industry and Consumer Interaction forums and of the Educational Outreach activities over
the most recent five-year period. The following chart is used to document the occurrence of those forums and activities. Meeting
minutes, agendas, by-laws, charters, membership criteria and lists, frequency of meetings, roles, performed actions and
documentation of food safety educational efforts must be maintained by the regulatory authority.
PART I-Industry and Consumer Interaction Forums
Forum Title

7-11

Regulatory
Participants by
Organization

Industry Participants
by Organization

Consumer
Participants by
Organization

Meeting
Dates

Summary of Activities
Related to Control of
Risk Factors

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 7: Industry and Community Relations Self-Assessment Worksheet
PART II-Educational Outreach
Dates

7-12

Summary of Activities

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 8 PROGRAM SUPPORT AND RESOURCES
Table of Contents

REQUIREMENT SUMMARY .............................................................................................................................................................................. 2
DESCRIPTION OF REQUIREMENT .................................................................................................................................................................. 2
1.
Staffing Level ............................................................................................................................................ 2
2.
Inspection Equipment ................................................................................................................................ 2
3.
Administrative Program Support ............................................................................................................... 3
4.
Regulatory Foundation .............................................................................................................................. 3
5.
Trained Regulatory Staff ........................................................................................................................... 3
6.
Inspection Program Based on HACCP Principles ..................................................................................... 3
7.
Uniform Inspection Program ..................................................................................................................... 3
8.
Foodborne Illness & Food Defense Preparedness & Response ................................................................. 3
9.
Compliance & Enforcement ...................................................................................................................... 3
10. Industry & Community Relations .............................................................................................................. 3
11. Program Assessment...................................................................................................................................3
12. Accredited Laboratory ................................................................................................................................4
OUTCOME ............................................................................................................................................................................................................. 4
DOCUMENTATION .............................................................................................................................................................................................. 4

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 8 PROGRAM SUPPORT AND RESOURCES
This standard applies to the program resources (budget, staff, equipment, etc.) necessary to support an
inspection and surveillance system that is designed to reduce risk factors and other factors known to
contribute to foodborne illness.
Requirement Summary
The program provides funding, staff, and equipment necessary to accomplish compliance with
the Voluntary National Retail Food Regulatory Program Standards.
Description of Requirement
The program budget provides the necessary resources to develop and maintain a retail food safety
program that meets the following criteria:
1.

Staffing Level
Note: Jurisdictions can achieve conformance using one of two methods. Both methods can be
accessed for downloading from the Conference for Food Protection (CFP) web site:
www.foodprotect.org and located under the icon titled, “Conference Developed Guides and
Documents.”
Option 1: Standard 8 Staffing Level Assessment
A staffing level of one full-time equivalent (FTE) devoted to food for every 280 – 320
inspections performed. Inspections for purposes of this calculation include routine
inspections, re- inspections, complaint investigations, outbreak investigations, compliance
follow-up inspections, risk assessment reviews, process reviews, variance process reviews
and other direct establishment contact time such as on-site training.
A process should exist for the regulated food establishments to be grouped into at least three
categories based on food safety risk (See Standard 3). The number of inspections assigned
per FTE should be adjusted within the 280 – 320 range depending upon the composition of
low- to high –risk establishments in the assigned inventory. When an FTE is divided
between program areas, the total number of food inspections planned for that FTE should be
adjusted to compensate for the additional training time required to maintain competency in
multiple program areas. An adjustment of planned inspections per FTE should also occur
when food establishments are geographically dispersed due to increased travel time.
Through their committee process, the CFP has developed an assessment tool and instruction
guide as resources that can be used by a jurisdiction to calculate the FTE to inspection ratio.
Option 2: Standard 8 Staffing Level Alternative Conformance Method
Jurisdictions may access an alternative model for achieving conformance with Standard 8
from the Conference for Food Protection (CFP) web site: www.foodprotect.org and located
under the icon titled, “Conference Developed Guides and Documents.”

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Inspection Equipment
Inspection equipment of each inspector to include head covers, thermocouples, flashlights,
sanitization test kits, heat sensitive tapes or maximum registering thermometers, necessary
forms, and administrative materials. The following equipment must be available for use by
inspectors when needed: computers, cameras, black lights, light meters, pH meters, foodborne
illness investigation kits, sample collection kits, data loggers and cell phones.

Administrative Program Support
Equipment for administrative staff to include computers, software and/or items
necessary to support the record keeping system utilized by the program. A system is in
place to collect, analyze, retain, and report pertinent information.

Regulatory Foundation
Staff and resources to adopt a sound, science-based regulatory foundation for the public health
program and the uniform regulation of industry required in Standard No. 1.

Trained Regulatory Staff
Training and training documentation for all regulatory staff to meet the level specified in
Standard No. 2.

Inspection Program Based on HACCP Principles
Staff to meet all of the requirements in Standard No. 3, inspection based on HACCP
principles.

Uniform Inspection Program
Administrative and supervisory staff to administer and monitor a uniform inspection
program based on HACCP principles that meet Standards No. 3 and 4.

Foodborne Illness & Food Defense Preparedness & Response
Staff and resources to maintain a foodborne illness investigation and response system that
meets Standard No. 5.

Compliance & Enforcement
A program that demonstrates follow-though on all compliance and enforcement actions
initiated according to the written step-by-step procedures required in Standard No. 6.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

10. Industry & Community Relations
An industry and consumer relations program as specified in Standard No. 7.
11. Program Assessment
Sufficient staff and resources to conduct regular program self-assessment and risk factor
surveys as specified in Standard No. 9.
12. Accredited Laboratory
Funds to provide access to accredited laboratory resources in support of the program as
specified under these nine Standards.
The essential program elements required to demonstrate compliance with this standard are:
A. Full-time equivalent (FTE) personnel to inspections accomplished ratio as described in

section 1.

B. Inspection equipment assigned or available as described in section 2.
C. Equipment and/or supplies required for administering the program as described in Section

D. A full and accurate completion of the Standard 8: Self-Assessment Worksheet or

equivalent whether or not those standards are met.
Outcome

The desired outcome of this standard is that resources are available to support a risk-based retail
food safety program designed to reduce the risk factors known to contribute to foodborne illness.
Documentation
The quality records needed for this standard include:
1. Documentation of FTE to inspections ratio,
2. Inventory of assigned and available inspection equipment,
3. Documentation and demonstration of records system and adequacy of support,
4. The completed Standard 8 Self-Assessment Worksheet
[*NOTE: An average workload figure of 150 establishments per FTE with two inspections per year
was originally recommended in the 1976 Food Service Sanitation Manual, the standard originating
from a book entitled, “Administration of Community Health Services.” Annex 4 of the Code since 1993
has included a recommendation that 8 to 10 hours be allocated for each establishment per year to
include all the activities reflected here in the definition of an inspection. The range of 280 – 320
broadly defined inspections per FTE is consistent with these previous recommendations. A measure of
resources defined as inspections per FTE rather than establishments per FTE allows for the same unit
of measure to be used for any jurisdiction regardless of the frequency of routine inspections conducted
among the various priority categories.]
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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 8 – PROGRAM SUPPORT AND RESOURCES
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment & Verification Audit Form

The Standard 8: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process. The form is included at the end of
these instructions. Whether one is performing a program self-assessment or conducting a verification
audit, it is recommended that the form be available as a reference to the Standards 8 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of Standard 8 must indicate on the form if each of the criteria
is met. The self-assessor must record their findings under the column “Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use the form. An equivalent form or process is acceptable provided that
the results of the jurisdiction’s self-assessment for the specific Standard 8 criteria listed on the form are
available for review.
The self-assessor must review each Standard 8 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must place
an “X” in the “YES” box under the “Jurisdiction’s Self-Assessment” column of the Standard 8 Program
Self-Assessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 8 criteria are met, the
self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column of
the Standard 8: Program Self-Assessment and Verification Audit Form. The self-assessor may specify
why the criteria are not met in the box provided.
The self-assessor should review the findings on the Standard 8: Program Self-Assessment and
Verification Form to ensure accuracy. The jurisdiction will be required to provide the auditor with their
completed Standard 8: Program Self-Assessment and Verification Audit Form and any documents used
to support and demonstrate that the Standard 8 criteria have been met.
Once all the criteria have been reviewed and documented on the form, the self-assessor must complete the
Program Self-Assessment Summary section on page one of the Standard 8: Program Self-Assessment and
Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 8 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 8 criteria.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 8: Program
Self-Assessment and Verification Audit Form to the auditor for review. The auditor must indicate on the
Program Self-Assessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that
the Standard criteria are met, the verification auditor places and “X” in the “NO” box under the
“Auditor’s Verification” column of the form. The verification auditor must specify why the criterion is
not met in the box provided. Supplemental pages may be used to explain findings.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the verification audit. Ample time
should be allotted to ensure that there is a clear understanding of the reasons for the “non-conforming”
finding. The auditor should be prepared to identify the elements required for the jurisdiction to meet the
Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on the first page of the Standard 8: Program Self-Assessment and Verification
Audit Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 8 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 8 criteria if the auditor does not confirm the self-assessment
findings.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 8: Program Support and Resources
Program Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 8 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 8
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 8 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 8 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
8 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 8 is true and correct.
Signature of the Verification Auditor:

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 8: Program Support and Resources
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: _________________________________________________________________________________________________________
Criteria

1. Staffing Level

Element
a) The jurisdiction has written
documentation, calculations, or a
program resource assessment that
demonstrates a staffing level of
one FTE for every 280-320 retail
food program inspections
performed or the staffing level
set by the jurisdiction.
Note: The jurisdiction may use
an alternative for determining
and calculating staffing level. It
should be indicated within the
Self-Assessment General
Comments section.

2. Inspection
Equipment

8-8

a) The jurisdiction can show
through written records,
equipment inventories, or actual
observations that each retail food
program inspector has a head
cover, thermocouple, flashlight,
sanitization test kit, heat sensitive
tapes or maximum registering
thermometer, and necessary
forms and administrative
materials.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
Verification Verification
YES
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

b) The jurisdiction has written
procedures for obtaining the use
of computers, cameras, black
lights, pH meters, foodborne
2. Inspection
illness kits, sample collection
Equipment
kits, data loggers, and cell
phones should this equipment not
be part of the agency's general
inventory.
a) The jurisdiction has written
documentation,
calculations, or a program
3. Administrative resource assessment that
Program Support demonstrates sufficient
equipment is available to support
the record keeping system
utilized by the program.
b) The jurisdiction has a system
in place to collect, analyze,
3. Administrative
retain, and report pertinent
Program Support
information required to manage
and implement the program.

4. Program
Resource
Assessment

a) The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #1 Regulatory Foundation.

4. Program
Resource
Assessment

b) The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #2 Trained Regulatory Staff.

8-9

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
Verification Verification
YES
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

4. Program
Resource
Assessment

c) The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #3 Inspection Program Based on
HACCP Principles.

4. Program
Resource
Assessment

d) The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #4 Uniform Inspection Program.

4. Program
Resource
Assessment

e) The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #5 Foodborne Illness and Food
Security Preparedness and
Response.

4. Program
Resource
Assessment

f) The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #6 Compliance and Enforcement.

4. Program
Resource
Assessment

g) The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #7 Industry and Community
Relations.

8-10

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
Verification Verification
YES
NO

If NO, Auditor is to
specify why criterion is
not met

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

4. Program
Resource
Assessment

Element

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
Verification Verification
YES
NO

If NO, Auditor is to
specify why criterion is
not met

h. The jurisdiction has
conducted an assessment to
determine if the agency has the
budget, staffing, and equipment
necessary to meet Standard #9 Program Assessment.
GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

Note: To Meet Standard 8 a “yes” affirmation to all elements under Criteria 1 - 4 is required. Answering “yes” to all elements under Criteria 1 -3 reflects the fact
that the jurisdiction has conducted an assessment of Criteria 1 - 3 and also has met all the elements under these Criteria. Answering “yes” to all elements under
Criteria 4 reflects the fact that the jurisdiction has conducted an assessment of all elements under Criteria 4. For Criteria 4, as long as an assessment of each
element is conducted a “yes” affirmation can be made, whether or not the jurisdiction has sufficient budget, staffing and equipment necessary to meet Standards 1
-7, and 9. For all Criteria (1 - 4), if an item contains multiple questions, then all questions must be answered in the affirmative in order to meet that element of the
Standard. The source documents, such as the various policies and procedures, that support this summary record must be maintained in good order by the
regulatory authority and must be made available upon request for purposes of a verification audit.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 8 – PROGRAM SUPPORT AND RESOURCES
INSTRUCTIONS AND WORKSHEET FOR CONDUCTING A SELFASSESSMENT
STEP 1 – Review Staffing Level
The jurisdiction must have written documentation, calculations, or a program resource assessment that is
used to determine staffing levels for retail food inspections. To meet the Standard 8 criteria, a jurisdiction
must 1) determine their FTE (Full-Time Equivalent) per Inspections Performed and show an Inspectionto-FTE Ratio between 280 and 320 inspections per FTE, or 2) show they have met the jurisdictional
requirement for adequate staffing levels.
The “FTE per Inspections Performed” is the measure of a program’s capacity to fulfill its inspection
obligations.
FTE is defined as the number of productive hours (conducting retail food inspections) contributed by one
person working full-time for one year.
Determine Number of Inspections: For the purposes of this standard, “inspections” are defined as routine
inspections, re-inspections, complaint investigations, outbreak investigations, compliance follow-up
inspections, risk assessment reviews, process reviews, variance process reviews, foodborne illness
complaint response, final construction inspections and other direct establishment contact time such as onsite training that is performed by the field inspection staff. If the same personnel who conduct inspections
of the fixed-site establishments also conduct the inspections of temporary events and mobile units, then
these inspection events should also be counted as “inspections” for purposes of calculating the workload
ratio.
FTEs per Inspection Performed: The jurisdiction must estimate the number of on-site contacts made in a
year. The Inspection-to-FTE Ratio is then calculated as the total number of inspections (or on-site visits)
divided by the number of FTE's.
Jurisdictional Requirement for Adequate Staffing Levels: Jurisdictions can set their own requirement for
the number of inspectors needed to demonstrate adequate staffing and use a calculation method deemed
acceptable to the jurisdiction.
For those jurisdictions interested in using the assessment tool provided as part of Issue 2020-II-018, it can
be accessed on the CFP website at www.foodprotect.org.
 Standard 8 – Example of Standard 8 Alternative Assessment Tool
The CFP’s Program Standard Committee has designed additional resource tools for assisting jurisdictions
with calculating if jurisdictions are adequately staffed:
 Standard 8 – Staffing Level Assessment Workbook
 Standard 8 – Staffing Level Assessment Workbook; Instruction Guide
 Standard 8 - Staffing Level Alternative Conformance Method PowerPoint
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Voluntary National Retail Food Regulatory Program Standards – January 2022

 Standard 8 - Re-Evaluation of Staffing Level Model Pilot Study Report
The above resources are available on the CFP web site: www.foodprotect.org.
STEP 2 – Review Inspectional Equipment Documentation
 Documentation for inspection equipment: The self-assessor must confirm that the jurisdiction has
documentation to verify that necessary inspection equipment is provided and assigned to each
inspector, including head covers, thermocouples, flashlights, sanitization test kits, heat sensitive tapes
or maximum registering thermometers, necessary forms, and administrative materials.
 Documentation for accessing use of additional equipment: The self-assessor must confirm that the
jurisdiction has documentation for obtaining use of equipment that may not be part of standard
equipment issued for inspection purposes, such as computers, cameras, black lights, light meters, pH
meters, foodborne illness investigation kits, sample collection kits, data loggers and cell phones.
STEP 3 – Review Administrative Program Support Documentation
 Documentation of equipment/supplies for maintaining program records: The self-assessor must confirm
that the jurisdiction has documentation that equipment and/or supplies required for administering the
program, including computers, software, and other items necessary to support the record keeping
system utilized by the program, are available.
 System to analyze data: The self-assessor must verify that a system is in place to collect, analyze,
retain, and report pertinent information about the program.
STEP 4 – Program Resource Assessment
The Standard 8 self-assessment worksheet is designed to assist jurisdictions with maintaining
documentation and information required for assessing funding, staffing, and equipment needs associated
with Standards 1 through 7 and Standard 9. The worksheet is included with these instructions.
There is no penalty for a jurisdiction’s failure to meet Standards 1 through 7 or Standard 9. Moreover, there
is no penalty for failing to have the necessary funding and support under the criteria required in the
Program Resource Assessment portion of the Standard 8: Program Self-Assessment and Verification Audit
Form. The intent is for the jurisdiction to perform the assessment to determine if program resources are
sufficient for each standard.
The self-assessor must document on the Standard 8: Self-Assessment Worksheet if the jurisdiction has
sufficient funding, staff, and equipment to achieve each of the Standards listed on the worksheet. Each of
the three resource areas (funding / staff / equipment) is assessed separately for each of the Standards. A
check mark in the “YES” column indicates that the jurisdiction has sufficient resources. A check mark in
the “NO” column indicates that the jurisdiction does not have sufficient resources. A “NO” response
require an explanation as to what additional resources may be needed to assist the jurisdiction with meeting
the Standard.
At the bottom of the worksheet, the self-assessor will indicate if the jurisdiction meets the Standard 8
requirements by checking either “YES” or “NO”. Upon completing the worksheet, the self-assessor must
sign and date it. The self-assessor must retain the worksheet with the other Standard 8 self- assessment
documentation
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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 8: Program Support and Resources
Self-Assessment Worksheet
Jurisdiction Name: ______________________________________________________________________________________________________
Standard #

8-14

Funding
(Yes/No)

Staffing
(Yes/No)

Equipment
(Yes/No)

EXPLANATION – OTHER RESOURCES NEEDED

Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard #

Funding
(Yes/No)

Staffing
(Yes/No)

Equipment
(Yes/No)

EXPLANATION – OTHER RESOURCES NEEDED

***

9
****Other shared resources

*Do you meet the full time equivalent (FTE) staff to inspection ratio as required in Standard 8?
**Do your inspectors have the equipment provided and available as required in Standard 8?
***Does your Department have the equipment and supplies necessary to maintain the records and reports system that supports the program as required in Standard 8?

File Meets the Standard 8 Criteria: _______ YES _______ NO

Signature:______________________________
8-15

Title:______________________________

Date:___________________________

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 9 PROGRAM ASSESSMENT
Table of Contents

9-1

Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 9 PROGRAM ASSESSMENT
This Standard applies to the process used to measure the success of a jurisdiction’s program in
reducing the occurrence of foodborne illness risk factors to enhance food safety and public health
in the community.
Requirement Summary
Program management must ensure that:
1. A RISK FACTOR STUDY on the occurrence of the five foodborne illness risk factors is
conducted and repeated at least once every 60 months to measure trends in the occurrence
of the risk factors;
2. An analysis is made of the data collected and a report on the outcomes and conclusions of
the RISK FACTOR STUDY is written; and
3. A targeted intervention strategy designed to address the occurrence of the risk factors(s)
identified in their RISK FACTOR STUDY is implemented and the effectiveness of such
strategy is evaluated by subsequent RISK FACTOR STUDIES or other similar tools.
Description of Requirement
To achieve the criteria of Standard 9, a jurisdiction must ensure that:
A. A RISK FACTOR STUDY and report on the occurrence of the five (5) foodborne illness risk
factors must be completed. A RISK FACTOR STUDY serves two purposes:
1. To identify risk factors most in need of priority attention in order to develop strategies
to reduce their occurrence.
2. To evaluate trends over time to determine whether progress is being made toward
reducing the occurrence of foodborne illness risk factors. Studies designed to measure
trends require analysis of data over a period of time, and no single point in time can be
used to derive trend conclusions.
B. The RISK FACTOR STUDY includes all facility categories under regulation by the
jurisdiction.
It is recommended that a jurisdiction’s first RISK FACTOR STUDY be conducted as soon as
possible following its first SELF-ASSESSMENT, before programmatic changes are made.
There is value in using the first study to establish a “baseline” against which future
performance can be measured. Program improvements and changes may then be reflected
in subsequent studies.
C. The RISK FACTOR STUDY information is to be updated at least once every 60 months to
measure trends specific to the occurrence of the five (5) foodborne illness risk factors.
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Voluntary National Retail Food Regulatory Program Standards – January 2022

The data collection and analysis may occur at various times over the 60-month period, as
long as all facility categories under regulation are included in the 60-month cycle. The 60month study update is required to maintain achievement of Standard 9. The subsequent
studies and reports indicate if there has been a net change in the occurrence of the risk
factors.
The four (4) facility categories are:
1.
2.
3.
4.

Health Care;
Schools (K-12);
Restaurants;
Retail Food Stores.

D. A jurisdiction may use routine inspection data or may conduct a separate data collection in
completing a RISK FACTOR STUDY. A data collection instrument similar to the FDA Model
Data Collection Form using the IN, OUT, NA, and NO convention, is required.
E. Failure to use this convention skews the data toward either IN compliance or OUT of
compliance. The FDA data collection instrument is not intended as an inspection form.
However, jurisdictions that have developed an inspection form using the IN, OUT, NA
and NO convention may use that inspection form as a survey instrument.
If the jurisdiction uses a different form, the data may be difficult to compare with the data
from the FDA National Foodborne Illness Risk Factor Studies or with data from other
jurisdictions.
F. A jurisdiction must ensure that a targeted intervention strategy designed to address the
occurrence of the risk factor(s) identified in their Risk Factor Study is implemented and
the effectiveness is evaluated by subsequent Risk Factor Studies or other similar tools.
Jurisdictions are encouraged to incorporate various types of interventions such as code
changes, educational and training activities, enforcement, and compliance strategies, etc.
The purpose of the intervention strategy is to attempt to affect improvement in reducing
priority risk factor(s) occurrence rates between measurement intervals and assess their
effectiveness.
Outcome
The desired outcome of this Standard is to enable managers to measure their program against national
criteria and to demonstrate improvement in food safety. The process identifies program elements that
may require improvement or be deserving of recognition.
Documentation
The quality records required for this standard include:
1. Survey reports on the occurrence of risk factors and FDA Food Code interventions
identified in their RISK FACTOR STUDY,
2. Survey collection tools or inspection sheets used for the data collection,
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Voluntary National Retail Food Regulatory Program Standards – January 2022

3. Documentation that each facility category regulated by the jurisdiction is surveyed during
the 60-month survey cycle,
4. Documentation of performed interventions, actions or activities designed to improve the
control of risk factors,
5. Documentation that the effectiveness of performed interventions is evaluated.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

STANDARD 9 – PROGRAM ASSESSMENT
INSTRUCTIONS FOR COMPLETING THE PROGRAM SELF-ASSESSMENT
AND VERIFICATION AUDIT FORM
Program Self-Assessment & Verification Audit Form
The Standard 9: Program Self-Assessment and Verification Audit Form is designed to document the
findings from the self-assessment and the verification audit process. The form is included at the end of
these instructions. Whether one is performing a program self-assessment or conducting a verification
audit, it is recommended that the form be available as a reference to the Standards 9 criteria.
Using the Program Self-Assessment and Verification Audit Form
Documenting the Findings from the Self-Assessment
Jurisdictions conducting a self-assessment of the Standard 9 Program Assessment component must
indicate on the form if each of the criteria is met. The self-assessor must record their findings under the
column “Jurisdiction’s Self-Assessment.”
Jurisdictions are not obligated to use the form. An equivalent form or process is acceptable provided
that the results of the jurisdiction’s self-assessment for the specific Standard 9 criteria listed on the form
are available for review.
The self-assessor must review each Standard 9 criterion and determine if the jurisdiction’s source
documents confirm that the Standard criteria are met. If the criteria are met, the self-assessor must
place an “X” in the “YES” box under the “Jurisdiction’s Self-Assessment” column of the Standard 9:
Program Self-Assessment and Verification Audit Form.
If a review of the jurisdiction’s source documents does not confirm that the Standard 9 criteria are met,
the self-assessor must place an “X” in the “NO” box under the “Jurisdiction’s Self-Assessment” column
of the Standard 9: Program Self-Assessment and Verification Audit Form. The self-assessor may
specify why the criteria are not met in the box provided.
The self-assessor should review the findings on the Standard 9: Program Self-Assessment and
Verification Form to ensure accuracy. The jurisdiction will be required to provide the auditor with
their completed Standard 9: Program Self-Assessment and Verification Audit Form and any
documents used to support and demonstrate that the Standard 9 criteria have been met.
Once all the criteria have been reviewed and documented on the form, the self-assessor must complete
the Program Self-Assessment Summary section on page one of the Standard 9: Program SelfAssessment and Verification Audit Form. The self-assessor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 9 criteria in the appropriate boxes; and
• Sign the form where indicated.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 9 criteria.
Documenting the Findings from the Verification Audit
The jurisdiction requesting the verification audit must provide their completed Standard 9: Program SelfAssessment and Verification Audit Form to the auditor for review. The auditor must indicate on the
Standard 9: Program Self-Assessment and Verification Audit Form if the criteria were met.
If a review of the jurisdiction’s source documents confirms the self-assessment conclusion that the
Standard criteria are met, the verification auditor places an “X” in the “YES” box under the “Auditor’s
Verification” column of the form.
If a review of the jurisdiction’s source documents does not confirm the self-assessment conclusion that
the Standard criteria are met, the verification auditor places and “X” in the “NO” box under the
“Auditor’s Verification” column of the form. The verification auditor must specify why the criterion
is not met in the box provided. Supplemental pages may be used to explain findings.
The verification auditor must discuss their findings with the program manager or their appointed
representative and provide constructive feedback at the conclusion of the verification audit. In
particular, any Standard 9 criteria for which the auditor cannot confirm through a review of the selfassessment should be thoroughly discussed. Ample time should be allotted to ensure that there is a
clear understanding of the reasons for the “non-conforming” finding. The auditor should be prepared
to identify the elements required for the jurisdiction to meet the Standard.
Once the close out interview has been conducted, the auditor must complete the Verification Audit
Summary section located on the first page of the Standard 9: Program Self-Assessment and
Verification Audit Form. The auditor must:
• Enter their contact information;
• Document if the jurisdiction met the Standard 8 criteria in the appropriate boxes; and
• Sign the form where indicated.
It then will be up to the jurisdiction to determine its action plan and time frame for correcting any
deficiencies in order to meet the Standard 9 criteria if the auditor does not confirm the self-assessment
findings.

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 9: Program Assessment
Program Self-Assessment and Verification Audit Form
PROGRAM SELF-ASSESSMENT SUMMARY
Printed Name of the Person who conducted the Self-Assessment:
Self-Assessor's Title:
Jurisdiction Name:
Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Standard 9 Self-Assessment was Completed:
Self-Assessment indicates that the Jurisdiction MEETS the Standard 9
criteria (indicate YES/NO):
I affirm that the information represented in the Self-Assessment of Standard 9 is true and correct.
Signature of the Self-Assessor:

VERIFICATION AUDIT SUMMARY
Printed Name of the Person who conducted the Verification Audit:
Verification Auditor’s Title:
Auditor’s Jurisdiction Name:
Auditor’s Jurisdiction Address:
Phone:
Fax:
E-mail:
Date the Verification Audit of Standard 9 was Completed:
Verification Audit indicates that the Jurisdiction MEETS the Standard
9 criteria (indicate YES/NO):
I affirm that the information represented in the Verification Audit of Standard 9 is true and correct.
Signature of the Verification Auditor:

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Voluntary National Retail Food Regulatory Program Standards – January 2022

Standard 9: Program Assessment
Program Self-Assessment and Verification Audit Form
Jurisdiction Name: _________________________________________________________________________________________________________
Criteria

Element

1. Risk Factor
Study

a) A study on the occurrence
of foodborne illness risk
factors has been completed
and includes data for each
facility type regulated by the
jurisdiction collected over the
study cycle.

1. Risk Factor
Study

b) The data collection form
includes items pertaining to
the following Center for
Disease Control and
Prevention (CDC) identified
contributing factors to
foodborne illness.
1. Food from Unsafe
Sources;
2. Improper Holding/Time
and Temperature;
3. Inadequate Cooking;
4. Poor Personal Hygiene;
and
5. Contaminated equipment
/ Protection from
contamination.

1. Risk Factor
Study

c) The data collection form
provides for marking actual
observations of food practices
within an establishment (IN,
OUT, NO, and NA).

9-8

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

Voluntary National Retail Food Regulatory Program Standards – January 2022

Criteria

Element

2. Report of
Analysis and
Outcome

a) A report is available that
shows the results of the data
collection from the
jurisdiction's foodborne
illness risk factor study.

2. Report of
Analysis and
Outcome

b) The report provides
quantitate measurements upon
which to assess the trends in
the occurrence of foodborne
illness risk factors over time.

3. Intervention
Strategy

a) A targeted intervention
strategy designed to address
the occurrence of the risk
factor(s) identified in their
risk factor study is
implemented and the
effectiveness of such strategy
is evaluated by subsequent
risk factor studies.

3. Intervention
Strategy

b) Documentation is provided
of performed interventions,
action, or activities designed
to improve control of
foodborne illness risk factors.

Jurisdiction’s
Jurisdiction’s
Self-Assessment Self-Assessment
YES
NO

Self-Assessor's General
Comments

Auditor’s
Auditor’s
If NO, Auditor is to specify
Verification Verification
why criterion is not met
YES
NO

GENERAL NOTES PERTAINING TO THE PROGRAM SELF-ASSESSMENT OR THE VERIFICATION AUDIT

9-9

Voluntary National Retail Food Regulatory Program Standards – January 2022

APPENDIX 1: SUMMARY OF CHANGES
This summary provides a synopsis of the changes made to the 2022 edition of the Voluntary
National Retail Food Regulatory Program Standards. The primary intent of this record is to
capture the nature of the changes found in the 2022 edition of the Voluntary National Retail Food
Regulatory Program Standards rather than to identify every word or editing change. This record
should not be relied upon as an absolute comparison that identifies each and every change.
Changes Recommended by the Conference for Food Protection (CFP)
FDA works closely with stakeholders through the biennial Conference for Food Protection
(CFP) to review proposed changes to the Voluntary National Retail Food Regulatory Program
Standards. Changes may be proposed by FDA, or by stakeholder groups such as academia,
industry, consumer groups, and regulatory officials. The CFP provides an opportunity for
stakeholders to provide comments about proposed changes.
The following changes reflect the recommendations from the Conference for Food Protection,
2020 biennial meeting.
Updates to Standard 2 Appendix B-1 format
What changed in Standard 2?
Appendix B-1: Curriculum for Retail Food Safety Inspection Officers has been reformatted into
a table with curriculum topics as headers, followed by a table with the course title in one column
and the course numbers in another column.
How do these changes affect your jurisdiction?
Jurisdictions are encouraged to reference the updated Appendix B-1 when evaluating courses
needed to fulfill the requirements of Standard 2.
How will I be able to access and complete these forms?
These forms are available on FDA’s website.
(CFP Issue 2020-II-024)

Voluntary National Retail Food Regulatory Program Standards – January 2022
Updates to Standard 2 – Amend Standard 2 curriculum to replace select courses with
updates
What changed in Standard 2?
Replacement of FD252 Allergen Management with B2 Allergens (CC8029W)

How do these changes affect your jurisdiction?
The replacement of this Allergen course will allow jurisdictions an alternative selection for
FSIO's to complete coursework toward achieving conformance with Standard 2.
How will I be able to access and complete these forms?
The B1 Appendix - Curriculum for Retail Food Safety Inspection Officers is available on FDA’s website.

(CFP Issue 2020-II-025)
Updates to Standard 2 – Amend Standard 2 to increase time for completion of Steps 1-4
What changed in Standard 2?
VNRFRPS Standard 2 Trained Regulatory Staff has been amended to increase the timeframe for
completion of Steps 1 – 4 from 18 months to 24 months.
How do these changes affect your jurisdiction?
The amendment to Standard 2 allows jurisdiction’s FSIO’s an additional 6 months to
complete Steps 1-4 of the five-step training and standardization process. It allows jurisdictions
additional time to complete the required elements within Standard 2.
How will I be able to access and complete these forms?
These forms are available on FDA’s website. Enrollees can print out the forms and complete
them by hand. Alternatively, these forms can be completed electronically and saved.
(CFP Issue 2020-II-027)

Voluntary National Retail Food Regulatory Program Standards – January 2022
Standard 6: Compliance and Enforcement
What changed in Standard 6?
Standard 6 Compliance and Enforcement was amended to allow jurisdictions to assess the
effectiveness of their compliance and enforcement program using an alternative sampling method
that provides the same level of statistical confidence as the currently prescribed method in the
VNRFRPS Standard 6.
How do these changes affect your jurisdiction?
Jurisdictions now have the option to use either the current sampling method as prescribed in
VNRFRPS Standard 6 or an alternative sampling method that provides the same level of statistical
confidence. The change increases the flexibility for jurisdictions seeking conformance with
VNRFRPS Standard 6.
How will I be able to access and complete these forms?
These forms are available on FDA’s website. Enrollees can print out the forms and complete
them by hand. Alternatively, these forms can be completed electronically and saved.
(CFP Issue 2020-II-032)

Voluntary National Retail Food Regulatory Program Standards – January 2022
Standard 8: Program Support and Resources
What changed in Standard 8?
The VNRFRPS Standard 8 staffing level element has been amended to allow jurisdictions to use
alternative methods for determining staffing levels.
How do these changes affect your jurisdiction?
Jurisdictions will now have the option to determine staffing levels using the current VNRFRPS
Standard 8 method or using an alternative method. An example of an alternative method was
submitted as part of Issue 2020-II-018 during the 2020 Conference for Food Protection biennial
meeting.
How will I be able to access and complete these forms?
Jurisdictions may access an example of an alternative model for achieving conformance with the
VNRFRPS Standard 8 staffing level element from the Conference for Food Protection (CFP) web
site: www.foodprotect.org located under the icon titled, “Conference Developed Guides and
Documents.”
(CFP Issue 2020-II-018)

Voluntary National Retail Food Regulatory Program Standards – January 2022
Other Changes made by FDA
FDA made a number of editorial and formatting changes to the Voluntary National Retail
Food Regulatory Program Standards. These changes are described below.
Formatting Changes
Program Self-Assessment and Verification Audit Forms for all nine Standards and most of
the corresponding Worksheets were reformatted to be accessible in their layout and follow a
logical reading order. Font size and type, page margins, and paragraph spacing and text
spacing were also reformatted to be more consistent and readable.

The 2022 Voluntary National Retail Food Regulatory Program Standards workbook primarily reflects an
incorporation of the recently approved changes that resulted from the 2020 Conference for Food Protection held in
Richmond, VA. In addition to these recommendations and changes from FDA, the workbook also contains editorial
corrections throughout to correct for spelling, grammar, and date errors from previous editions.

File Type	application/pdf
File Title	2022 Voluntary National Retail Food Regulatory Program Standards
Subject	2022 Voluntary National Retail Food Regulatory Program Standards
Author	FDA National Retail Food Team
File Modified	2022-10-24
File Created	2022-06-10