TO the honorable members of the Commonwealth Healthcare Corp. Board:
The Rota Chamber of Commerce respectfully requests a review of the long-standing CNMI food handler certification regulations. While these rules were originally intended to protect public health, their current application, particularly for businesses on remote islands such as Rota, has become duplicative, costly, and difficult to sustain.
Below are our primary concerns and the reasons we believe a review and amendments are necessary:
1) Requirements for Non-Food-Handling Employees
Current regulations require food handler certification for employees who do not prepare, cook, or handle unpackaged food. This includes cashiers, stockers, baggers, and clerks who work exclusively with sealed and prepackaged goods.
Requiring these employees to obtain certification provides no measurable health benefit, as they do not engage in any direct food preparation or contact with open food items.
Retail stores are already governed under the Sanitary Permit system, which requires businesses to:
• Maintain proper temperature control for cold and frozen goods
• Implement safe storage practices
• Discount and/or remove expired items within required timeframes
• Ensure overall facility cleanliness
These compliance measures, routinely inspected by CHCC Environmental Health, are sufficient to safeguard consumers in establishments where no food preparation occurs. Extending food handler certification to non-food-handling roles is therefore redundant and unjustified.
2) Annual Recertification
Most U.S. jurisdictions issue food handler cards that are valid for two to three years, recognizing that core food safety practices do not change annually. The CNMI’s one-year renewal requirement places ongoing administrative and financial pressure on both employees and employers without enhancing public health outcomes.
3) Unsupported Medical Screening Requirements
Mandatory annual physicals and TB tests for all certificate holders, regardless of job duties, are not supported by current CDC guidance. Annual TB screening is no longer recommended for asymptomatic individuals who are not in high-risk occupations, and it is not relevant for retail employees who do not prepare food.
4) Duplicate Certification Fees
Employees working in more than one store or holding more than one role are currently required to pay additional certification fees, even when the job functions are identical. For example:
• A cashier working at two convenience stores must obtain a primary certificate and an additional paid “extension” certificate.
• A restaurant employee performing multiple roles within the same establishment is charged separately per role.
These fees have no basis in improving food safety. Rather, they create a financial barrier for workers, especially those in the CNMI who commonly hold multiple jobs.
5) Disproportionate Costs for Rota
While we understand that the higher costs on Rota are not solely the result of CHCC policy, the disproportionate expenses caused by the lack of private clinic options make this a significant concern. The standard food handler certification fee is $35 across the CNMI, and a Rota business must also pay $186.60 per employee for the required physical exam ($159.60) and TB test ($27) at the Rota Health Center, excluding any additional expenses for X-rays ($108.90 per employee) if TB screening requires follow-up. This results in a total cost ranging from $221.60 to $303.50 per employee.
• Tinian Health Center (full certification + exam): $112.65
• Marianas Health (Saipan) physical exam only: $55
• Saipan Health Clinic physical exam only: $85
• Marianas Medical Clinic (Saipan) physical exam only: $65.00
This significant disparity places an undue and inequitable financial burden on Rota’s already limited and resource-constrained business community.
With these concerns in mind, we respectfully request the following reforms to update regulations while maintaining essential public health protections:
1) Limit certification requirements to employees who directly handle unpackaged or ready-to-eat food. Cashiers, stockers, and employees who work exclusively with sealed and prepackaged goods should be exempt.
2) Recognize the existing Sanitary Permit requirements as sufficient oversight for retail stores that do not prepare food.
3) Extend certification validity to three years to align with national standards and reduce administrative burden.
4) Eliminate mandatory physicals and TB testing for employees who do not engage in food preparation, aligning CNMI practices with current CDC recommendations.
5) Remove duplicate certification charges for employees working in multiple locations or performing multiple roles where the duties are substantially the same.
These reforms would maintain essential public health protections while reducing unnecessary burdens on small businesses throughout the CNMI. By updating these regulations, we can work together to support our islands’ health and strengthen our business community during ongoing economic uncertainty.
Thank you for your time, leadership, and consideration. We look forward to continued collaboration on this important matter.
Best regards,
ROTA CHAMBER OF COMMERCE
cc: Rota Mayor Aubry M. Hocog, Rota Sens. Donald M. Manglona, Ronnie M. Calvo, Paul A. Manglona and Rota Rep. Julie Marie A. Ogo
