Evaluating Manufactured Food Inspection Program New Hire Training Costs and Staff Turnover in Select AFDOSS States

Matt Colson

Environmental Administrator

Florida Department of Agriculture and Consumer Services

International Food Protection Training Institute (IFPTI)

2014 Fellow in Applied Science, Law, and Policy: Fellowship in Food Protection

Correspondence regarding this article should be addressed to Matt Colson Matthew.Colson@FreshFromFlorida.com

Abstract

This study compared training costs for onboarding new inspectors among the Association of Food and Drug Officials of Southern States (AFDOSS) of Florida, Georgia, North Carolina, Tennessee, and Virginia to meet nationally recognized Manufactured Food Regulatory Program Standards (MFRPS). Data were gathered through electronic surveys and telephone interviews, as well as in-person interviews, and adjusted for policy and program differences. The study concluded the total cost of training a new manufactured food inspector over the entire onboarding process can be over $235,000. The author recommends that states with high turnover rates identify the causes for their turnover and suggests that there is a need to investigate funding models to leverage training resources for state inspection programs. Finally, the study recommends that the Manufactured Food Regulatory Program Alliance (MFRPA) conduct a similar, expanded study to determine training costs and turnover rates on a national level and then determine possible solutions with the Food and Drug Administration (FDA). The states in this study represent 16.5% of the population in the United States (U.S. Census Bureau, 2015), therefore the impact of training costs at a national level would be much greater. Limitations of the study included lack of prior research, and inspection program differences.

Keywords: Onboarding, training

Background

The Manufactured Food Regulatory Program Standards (MFRPS) were developed by the FDA in conjunction with state program managers to serve as a foundation for manufactured food inspection programs and to promote the continuous improvement of these programs (MFRPS, 2007). The MFRPS consist of ten standards that establish requirements necessary for regulatory programs to protect the public from foodborne illness and injury (MFRPS, 2007). One goal of the MFRPS is to establish uniform risk-based inspection programs throughout the United States, which will result in a safer, more secure food supply (MFRPS, 2007). A second goal of the MFRPS is to improve communication between state and federal partners. Interagency communication is crucial for the development of an integrated food safety system, and will be an integral part of implementing the Food Safety Modernization Act (FSMA).

The MFRPS were first piloted in 2007, and, starting in 2008, states were able to enroll in the MFRPS as part of the Rapid Response Team (RRT) cooperative agreement (FDA, 2008) or through a state food inspection contract. Standard 2 of the MFRPS outlines a training program for manufactured food inspectors consisting of coursework and field training that must be completed within the first 24 months of the inspector’s start date. Standard 2 defines the basic training elements for a manufactured food inspector. However, the actual training elements required by each inspection program can vary. The cost of training new inspectors to achieve this level of competency can be a significant expense for manufactured food inspection programs. These costs are multiplied by staff turnover. State manufactured food inspection programs will likely play a key role in the implementation of new regulations created by the passage of FSMA. As a result, state programs will require additional training that will further increase training costs for all states. Understanding the absolute and relative costs of such training would aid food program managers in better understanding the true cost of their programs.

Problem Statement

The cost of training new employees in the AFDOSS region to meet the MFRPS Standard 2 training requirements is unknown. 

Research Questions

1.     What is the cost for state programs of training a new employee to meet MFRPS Standard 2 requirements?

2.     What is the average annual turnover rate for state programs?

3.     What are the total annual program costs for training new employees?

Methodology

In an effort to understand these annual costs, manufactured food program managers within state departments of agriculture in the Association of Food and Drug Officials of the Southern States (AFDOSS) region were surveyed to estimate training costs. Each of the programs surveyed are enrolled in the MFRPS. The AFDOSS states consist of 11 states and the U.S. Commonwealth of Puerto Rico. Departments of agriculture in the states of Florida, Georgia, North Carolina, Tennessee, and Virginia were selected for the survey in order to keep the sample a manageable size, given the research project’s resources. These states represent 16.5% of the population in the United States (U.S. Census Bureau, 2015).

A questionnaire was developed and designed to capture program information including: the length of time a state has been enrolled in the MFRPS; the size of the food safety program (number of regulated food establishments and number of manufactured food inspectors); the training timeline and requirements; training costs; and inspection staff turnover. The questionnaire was delivered via email to manufactured food program managers in the AFDOSS region, who were all pre-existing contacts of the author. Follow-up telephone interviews were conducted to expand upon their questionnaire responses.

A cost calculation was performed to capture the expenses incurred over the entire training period. In the training period during the onboarding process, the employee acquires the knowledge, skills, and abilities necessary to become a competent manufactured food inspector. Therefore, the entire period was evaluated rather than just looking at the costs associated with a series of individual training events. The elements factored into the training cost calculation over the onboarding period included: 1) inspector salaries, 2) inspector benefits, 3) salaries and benefits for trainers’ time spent with the inspector, 4) travel costs, and 5) indirect costs.

Annual turnover rate was calculated by dividing the number of inspectors who left each program annually since enrolling in the MFRPS by the number of full-time manufactured food inspector positions available. Average annual turnover (the average number of inspectors who left each program annually) was calculated by dividing the number of inspectors who left since enrolling in the MFRPS by the number of years enrolled. Total annual training costs were calculated by multiplying the annual training cost per new inspector by the average annual turnover (See Figure 1).

In three of the five programs, there are no staff dedicated solely to performing manufactured food inspections. All inspectors in these programs perform both retail and manufactured food inspections. To account for this, a Full Time Equivalent (FTE) calculation was performed to determine the number of personnel available for performing manufactured food inspections. The number of manufactured food FTEs was calculated by determining the number of hours used in performing manufactured food inspections annually, using inspection data provided by the program managers.

Four of the five programs in the study population are enrolled in the Voluntary National Retail Food Regulatory Program Standards (VNRFRPS) in addition to the MFRPS. For these programs, the training path for a manufactured food inspector begins with completing the basic training required in Standard 2 of the VNRFRPS. The retail training costs for these programs were included in the study because they are a pre-requisite for entering the manufactured food training program.

Results

The programs in the study were found to vary greatly in size and structure. The earliest enrollee in the MFRPS was North Carolina in 2007, with the most recent program being Tennessee, which enrolled in 2012. The number of manufactured food firms regulated by each program ranged from 1,297 to 5,500. The number of manufactured food FTEs ranged from 7 to 29. Four of the five programs had a three-tiered risk-based inspection frequency, while one program had a two-tiered risk-based inspection frequency. Inspection frequencies ranged from once every 24 months, to four times per year (See Figure 3). Four of the five programs indicated that they need at least one additional FTE, and as many as 19 additional FTEs, to meet current inspection frequencies.

The programs in the study spend an average of $146,276 on training each new manufactured food inspector, with the lowest cost being $106,714 and the highest being $235,828. The average inspector annual salary was $49,993, including benefits. The average indirect cost rate was 20.19%. The average annual inspector turnover rate was 6.84%, with the lowest turnover rate being 2.12% and the highest being 13.0%. After factoring in the cost per inspector and annual turnover rates, the average total annual program cost of training new manufactured food inspectors was $84,395, with the lowest being $19,572 and the highest being $202,637 (See Figure 4).

Conclusions

There were several limitations to this study, the first being the lack of available research on the subject. A keyword search with different variations of the terms “food, inspector, training, cost” was performed using several research databases including JSTOR and EBSCO, with no relevant results returned. There were also differences in program structure and policy that had to be accounted for, such as inspectors performing both retail and manufactured food inspections in some programs, and only either retail or manufactured food inspections in other programs. Another limitation was that all of the programs did not enroll in the MFRPS at the same time, so the programs were at different stages of conformance, and turnover calculations were based on different timeframes.

There were extensive variations among the programs in the costs for training new inspectors. The two greatest contributors to these variations were the training period, which ranged from nine to 36 months, and the differences among the programs in required courses. For example, inspectors in one state may be required to complete multiple advanced FDA courses. In another state, advanced training is required based on geographic need, and in another state, advanced training is only required for higher-level inspector positions.

Recommendations

1.     Further research is needed to determine the costs associated with the time spent only on training, as opposed to costs associated with the entire onboarding period.

2.     Florida and Georgia, whose turnover rates are 11% and 13% respectively, should evaluate the causes for their turnover rates, which were higher than the other states in the study. Similarly, other states outside of AFDOSS should consider performing assessments of their programs in order to determine the causes of their turnover. These assessments may help identify actions that could reduce high turnover rates, or otherwise lower costs.

3.     States should perform assessments to determine the additional training needs and other resources required for the implementation of FSMA, and the costs associated with those resources. These assessments may assist states with resource allocation as they prepare for FSMA implementation.

4.     Given the high agency cost for training a manufactured food inspector, there is a need to investigate funding models to leverage training resources for state inspection programs.

5.      The Manufactured Food Regulatory Program Alliance (MFRPA) should consider conducting a similar study to determine training costs and turnover rates on a national level, and then determine possible solutions with the FDA.

Acknowledgments

I would like to acknowledge the following people for their assistance with this study: my mentor Joseph Corby, IFPTI Mentor and AFDO Executive Director; Dr. Paul Dezendorf, IFPTI Research Subject Matter Expert; Dr. Craig Kaml, IFPTI Sr. Vice President of Curriculum; IFPTI staff; and all of the Cohort IV Mentors and Fellows. I would also like to thank the following State manufactured food program managers who participated in the survey: Jim Melvin, North Carolina Department of Agriculture and Consumer Services; Natalie Adan and Craig Nielsen, Georgia Department of Agriculture; Pam Miles and Courtney Mickiewicz, Virginia Department of Agriculture and Consumer Services; and Shanna Lively and Jolene Berg, Tennessee Department of Agriculture. I would like to thank the following Florida Department of Agriculture and Consumer Services staff for their support of my participation in the Fellowship: Dr. Lisa Conti, Deputy Commissioner; Dr. Tiffiani Miller Onifade, Division of Food Safety Director; Lee Cornman, Division of Food Safety Assistant Director; Dr. John Fruin, Chief Science Advisor; and special thanks to Brenda Morris, Bureau of Food and Meat Inspection Chief, for her continued support throughout the Fellowship. Special thanks also go out to Gerald Wojtala and IFPTI for allowing me the privilege of participating in the Fellowship.

References

Florida Department of Agriculture and Consumer Services. (2008). FL-FOOD-2008. (Contract Number HHSF223200840156C).

United States Census Bureau. (2015). Easy Stats. Retrieved from http://www.census.gov/easystats/

U. S. Food and Drug Administration. (2007). Manufactured Food Regulatory Program Standards. Retrieved from http://www.fda.gov/downloads/RegulatoryInformation/Guidances/UCM125448.pdf

U.S. Food and Drug Administration. (2008). Food Protection Rapid Response Team and Program Infrastructure Improvement Prototype Project (U18). Request for Applications (RFA) Number RFA FD08-007. Federal Register, 73(126), 36878-36880. Retrieved from http://www.gpo.gov/fdsys/pkg/FR-2008-06-30/pdf/FR-2008-06-30.pdf