Salmonella Controls That Prevent Seasoning Recalls

A Wisconsin seasoning manufacturer is currently pulling products from shelves due to potential Salmonella contamination — and the honest question worth asking isn't "how did this happen to them?" It's "what would have caught this before it reached a recall?"

JCB Flavors, LLC of Watertown, Wisconsin recently issued a voluntary recall of select topical seasoning products after potential Salmonella presence was identified. The FDA recall notice documents the risk clearly: Salmonella can cause serious and sometimes fatal infections in young children, elderly individuals, and immunocompromised people. That's not a boilerplate warning — it's the real downstream consequence of a gap somewhere in the production system.

This article isn't about JCB Flavors. It's about the category of problem they ran into, and the specific controls that exist precisely to prevent it. Dry seasoning and spice manufacturing has a well-documented Salmonella risk profile. The FDA has issued guidance on it. The industry has hard-won best practices around it. And yet recalls in this category keep happening — which tells you the controls are known but not universally implemented.

In my view, the most useful thing a food manufacturer can do with a recall like this is treat it as a case study, not as news. The lesson is right there.

Why Dry Seasonings Have a Persistent Salmonella Problem

It might seem counterintuitive — dry products, low water activity, no obvious growth medium. But Salmonella is remarkably durable in low-moisture environments. According to FDA research, Salmonella can survive for months or even years in dry spice and seasoning matrices, even at water activity levels well below 0.70 aw. The organism doesn't need to grow to cause illness; it just needs to survive in sufficient numbers and reach a consumer.

The contamination pathways in a dry seasoning facility are different from those in a wet-processing plant, but they're not less serious. Raw botanical ingredients — herbs, spices, dried vegetables — arrive with naturally occurring microbial loads from the field and from handling across the supply chain. If those inputs aren't treated, and if the facility environment isn't controlled, the contamination can transfer to finished product even in the absence of any obvious processing failure.

There's also a compounding factor: topical seasonings are often applied to ready-to-eat foods, which means there's no subsequent kill step that would eliminate a pathogen introduced at the seasoning stage. Whatever microbial contamination enters the seasoning ends up directly on the food the consumer eats. That reality makes upstream controls more critical, not less.

The Regulatory Framework Already Addresses This

The FDA's Preventive Controls for Human Food rule under 21 CFR Part 117 — which became effective for most manufacturers in September 2016, with phased compliance through 2018 for smaller operations — directly requires manufacturers to identify and control hazards like Salmonella in low-moisture foods. This isn't a gray area.

Under 21 CFR Part 117 Subpart C, manufacturers are required to conduct a hazard analysis that evaluates biological hazards reasonably likely to occur. For a dry seasoning manufacturer, Salmonella in raw botanical inputs and in the facility environment is exactly the kind of hazard that analysis should surface. Once identified, it requires either a preventive control or documented justification for why one isn't needed.

The specific preventive controls that apply here fall into several categories:

• Process controls — validated pathogen reduction steps applied to raw ingredients or finished product
• Sanitation controls — programs designed to prevent pathogen harborage and cross-contamination in the production environment
• Supply-chain controls — verification that incoming ingredients meet safety specifications, especially for materials that won't receive a kill step in your facility

If any of these three are missing or inadequate for a dry seasoning operation, the hazard analysis didn't do its job — or the facility didn't act on what the analysis found.

What an Effective Hazard Analysis Looks Like for Low-Moisture Foods

The hazard analysis is where a lot of manufacturers lose the thread. It gets treated as a documentation exercise rather than a genuine technical evaluation, and that's where the gap opens between what the paper says and what the facility actually does.

For a spice or seasoning manufacturer, a defensible hazard analysis for Salmonella needs to grapple with several specific questions:

Where does the hazard enter? Raw incoming ingredients — particularly those with agricultural origins — are the primary introduction point. The analysis should identify which incoming materials carry Salmonella risk and what the baseline microbial load looks like for those materials.

Does the process eliminate the hazard? If there's a validated heat treatment, roasting step, or irradiation program applied to incoming materials or finished product, that's a process preventive control. The validation needs to demonstrate a minimum 5-log reduction in Salmonella — the standard the FDA and the spice industry's own guidance documents point to.

What happens if the treatment fails or isn't present? This is where a lot of facilities have an unexamined assumption sitting quietly in the background. If the process doesn't include a validated kill step, the hazard analysis needs to identify that explicitly, and the supply-chain program needs to carry the weight of verification.

Environmental Monitoring: The Early Warning System Most Facilities Underutilize

Environmental monitoring programs (EMPs) for Salmonella are one of the most direct ways to detect a facility harborage problem before it becomes a product contamination problem. The FDA's guidance on environmental monitoring — including the draft guidance for low-moisture ready-to-eat foods — describes a zone-based sampling approach that, when implemented well, gives manufacturers a genuine early warning system.

The zone framework works like this:

The logic is counterintuitive to some: you sample the outer zones most aggressively because that's where you want to find Salmonella before it migrates inward. Finding a positive in Zone 3 is a corrective action trigger, not a crisis. Finding one in Zone 1 or in finished product is a crisis — and a recall.

According to FDA estimates, roughly 12% of imported spices tested between 2007 and 2009 were contaminated with Salmonella or filth, a finding that drove significant regulatory attention to this category. An environmental monitoring program that's actively searching for the hazard — rather than sampling infrequently and hoping for clean results — is the difference between catching the problem and shipping it.

Supplier Verification: The Control Most Often Delegated Away

For dry seasoning manufacturers who don't have an in-house kill step, the supply-chain program becomes the primary control for Salmonella. That puts significant weight on supplier verification — and supplier verification is one of the most commonly underdeveloped elements I see in food facility quality systems.

A compliant and functional supply-chain applied control under 21 CFR Part 117.135 requires more than a certificate of analysis on file. The FDA's expectation, reinforced through warning letters and import alerts, is that verification activities are actually meaningful — that they have the potential to detect a problem if one exists.

What that looks like in practice:

• Incoming material testing with a statistically defensible sampling plan (not a single-unit swab per lot)
• Supplier audits — either onsite or via a credible third-party — conducted on a risk-based frequency
• Certificate of analysis review against pre-established specifications, with documented out-of-spec handling procedures
• Approved supplier programs that include pathogen-specific requirements, not just general food safety certifications

The FSMA supply-chain provisions under 21 CFR Part 117 Subpart G are specific about what's required when a receiving facility relies on a supplier to control a hazard. The receiving facility can't simply assume the supplier is handling it. There has to be documented evidence of ongoing verification.

Sanitation and the Dry Environment Challenge

Salmonella harborage in dry processing environments has a particular character. Unlike Listeria in wet environments — where condensation, floor drains, and pooled water are the main vectors — Salmonella in a dry spice facility typically establishes itself through:

• Residual product in equipment crevices, joints, and conveying systems
• Dust accumulation in hard-to-reach areas that receives infrequent cleaning attention
• Raw material handling areas that aren't adequately separated from finished product areas
• Condensation events during facility temperature changes (early morning, after washdowns in adjacent areas)

The sanitation program needs to account for all of these pathways, and it needs to be validated — not just scheduled. An SOP that says "clean and sanitize" without specifying method, contact time, concentration, and verification testing is a document, not a program.

A sanitation control is effective when there's data showing it actually reduces microbial load to acceptable levels. That data comes from environmental monitoring results trending toward clean, from pre-operational swabs showing acceptable counts, and from a corrective action log that demonstrates issues are found and resolved rather than ignored.

The Allergen and Cross-Contamination Dimension

Worth noting in the context of topical seasonings specifically: Salmonella isn't the only hazard these facilities need to manage. Seasoning and spice manufacturers frequently work with multiple products on shared equipment, which creates allergen cross-contact risk alongside the microbial risk. A facility that has its Salmonella program dialed in but hasn't adequately evaluated allergen cross-contamination is still exposed.

The same zone logic applies: shared equipment, inadequate cleaning validation between runs, and inadequate label controls can create an allergen hazard in a product that never triggered a positive environmental swab. Both programs need to be functional, not just documented.

What a First-Time Audit Pass Actually Requires in This Category

At Certify Consulting, I've worked with food manufacturers across categories, and dry seasoning and spice operations are among the most technically demanding from a food safety program perspective precisely because the hazard is subtle. The pathogens survive in conditions that feel safe. The contamination routes are diffuse. And the regulatory expectations — between FSMA Part 117, the FDA's low-moisture food guidance, and the GFSI scheme requirements many buyers now require — are genuinely complex.

What I've seen is that the facilities that pass first-time and stay in compliance long-term share a few things in common. They treat the hazard analysis as a living document that actually reflects their process, not a template they filled out once. They have environmental monitoring data that shows real sampling events, real positive findings, and real corrective actions — not a clean log with no positives across years of operation, which is itself a red flag. And their supplier verification records show engagement with the hazard, not just administrative compliance.

The FDA's own enforcement data shows that warning letters in the food manufacturing space increasingly cite inadequate preventive controls verification and environmental monitoring gaps. These aren't new requirements — FSMA's preventive controls rule has been in force for nearly a decade — but enforcement attention to them has intensified as the agency has moved beyond initial compliance deadlines into active verification mode.

Practical Steps for Dry Seasoning and Spice Manufacturers Right Now

If you're manufacturing topical seasonings, dry spice blends, or similar low-moisture products, here's where I'd focus attention in light of the current enforcement environment:

1. Audit your hazard analysis for Salmonella specifically. Does it identify raw botanical ingredients as a potential source? Does it evaluate whether your process includes a validated kill step? If you're relying on a supplier to control the hazard, does it say that explicitly and point to your supply-chain program?

2. Review your EMP for zone coverage and sampling frequency. If you haven't had a Salmonella positive in Zone 2 or Zone 3 in the last two years, that may be a sampling design problem rather than evidence of a clean facility.

3. Pull your supplier verification records and ask: would this actually catch a contaminated lot? A certificate of analysis is a start, not a finish. What's your incoming testing program? When did you last audit your highest-risk suppliers?

4. Verify your sanitation program has validation data behind it. The SOP is the instruction. The validation data is the evidence that it works. Both need to exist.

5. Confirm your corrective action records reflect real events. Facilities with no deviations, no near-misses, and no corrective actions in their quality records aren't necessarily cleaner than facilities with active records — they may just be less engaged with their own data.

If you want a structured gap assessment against 21 CFR Part 117 requirements — or against GFSI/SQF/BRC requirements if your buyers require scheme certification — Certify Consulting offers food safety compliance consulting with a track record of 100% first-time audit pass rates across 200+ clients.

The Broader Pattern

Recalls in the dry seasoning and spice category are not rare events. The FDA has documented Salmonella in imported spices consistently over more than a decade of targeted surveillance. The science of the hazard is well-established. The regulatory framework — 21 CFR Part 117, the supply-chain provisions under Subpart G, the EMP guidance — exists precisely to prevent the outcome that a recall represents.

In my view, what the JCB Flavors recall illustrates isn't a novel or unusual failure. It illustrates how a known hazard in a well-characterized product category, managed with controls that weren't adequate to the risk, produces exactly the outcome the regulations are designed to prevent. The lesson isn't complicated. The execution is where it gets hard.

The question every manufacturer in this space should be sitting with right now is simple: if FDA walked in tomorrow and asked to see my hazard analysis, my EMP data, and my supplier verification records for Salmonella in my incoming botanical ingredients, what would they find?

If you're not confident in the answer, that's where to start.

For more on building a compliant preventive controls program or preparing for an FDA inspection, visit certify.consulting.

Last updated: 2026-05-20