FDA Finds Link Between Strong FSMS and Fewer Foodborne Illness Risk Factors in Retail Delis

The U.S. Food and Drug Administration (FDA) has published the results of a nationwide study of retail food store delis, finding improper holding time and temperature and poor personal hygiene to be the most commonly occurring foodborne illness risk factors. The agency also found that delis with stronger food safety management systems (FSMS) exhibited significantly fewer noncompliant food safety practices.
The technical report summarized FDA data collected at 438 retail food store delis from 2019–2022. The work represented the second of three data collection periods in FDA's ongoing study of trends in foodborne illness risk factors and food safety behaviors at retail food establishments. The third deli data collection period is scheduled for October 2026–September 2027, after which FDA intends to analyze trends over time.
Time and Temperature, Handwashing Pose Challenges for Delis
Among four foodborne illness risk factors examined, improper holding time and temperature had the highest rate of noncompliance observations, seen at 84 percent of delis. Poor personal hygiene was found in 61.9 percent of delis, followed by contaminated equipment/protection from contamination at 52.7 percent.
Inadequate cooking was the best-controlled risk factor, with noncompliance seen at only 9.3 percent of the 344 delis.
Looking at specific food safety practices, employee handwashing had the highest noncompliance rate, at 61.9 percent. Refrigerated foods were not held at the proper temperature at 58.9 percent of delis, while hot holding and cooling were out of compliance at 44 percent and 41.9 percent of delis, respectively.
In contrast, only 1.4 percent of delis were found to be noncompliant with preventing bare-hand contact with ready-to-eat (RTE) foods. Cooking raw animal foods to required temperatures had a noncompliance rate of 4.4 percent.
Stronger Food Safety Management Systems Linked to Better Compliance
FDA's analysis identified FSMS as the strongest predictor of noncompliant food safety behaviors and practices. The agency assessed management systems based on procedures, training, and monitoring, categorizing systems as “nonexistent,” “underdeveloped,” “well-developed,” or “well-developed and documented.”
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Delis with nonexistent FSMS averaged 4.37 noncompliant primary data items, compared with 1.95 among delis with well-developed and documented systems. Regression analysis also showed that each one-unit increase in FSMS score was associated with an approximately 19 percent decrease in the expected number of noncompliant data items, assuming other factors remained constant.
Risk categorization was also a significant predictor. Risk Category 3 establishments had approximately 47 percent more noncompliant data items, on average, than Risk Category 2 establishments after adjustment for other factors included in the model.
Although some individual comparisons showed differences associated with Certified Food Protection Manager (CFPM) status and multiple-unit operations, neither CFPM status nor multiple-unit status remained a significant predictor of out-of-compliance data items when the other studied factors were considered. FDA did, however, find a relationship between CFPM status and stronger FSMS; establishments where a CFPM was also the person in charge were more likely to have well-developed or well-developed and documented management systems.
FDA concluded that the findings support the importance of well-developed and documented FSMS for reducing the occurrence of foodborne illness risk factors in retail delis. The agency also identified employee handwashing and proper cold and hot holding temperatures as areas requiring greater control.








